Recent upheaval within the Education Department and student lending program could end up creating new problems for borrowers as collections on defaulted loans resume.

In all, some 42 million borrowers owe more than $1.6 trillion in student debt, according to the DOE. If the borrowers currently in late-stage delinquency were to default on their own loans, it would bring the share of borrowers in default to nearly 25%.

Involuntary collection begins May 5. For some students, it will be the first time they've ever had to confront the obligation of repaying their debt.