15 million student-loan borrowers have at least one of 5 big risk factors that could lead them down 'a difficult road' once payments resume, Biden's top consumer watchdog says

• Biden recently extended the pause on student-loan payments again, through August 31.
• The CFPB warned of challenges borrowers may struggle with once that relief expires.

President Joe Biden just $4 the pause on student-loan payments for a fourth time, but his consumer watchdog emphasized there's still work to be done to protect millions of borrowers once payments resume.

On Thursday, the Consumer Financial Protection Bureau released an $4 detailing the challenges borrowers might face when student-loan payments are set to resume after August 31. According to the analysis, while the pause on payments may have improved borrowers' financial standing during the pandemic, not all borrowers were better off, with some remaining delinquent on their payments.

Financial strains, along with changes in the student-loan industry itself caused by multiple companies announcing an end to their federal contracts, brings a lot of uncertainty as to what might happen when payments resume, and CFPB's head Rohit Chopra wrote on Twitter "there's more work to be done."

—Rohit Chopra (@chopracfpb) $4

"With the record number of borrowers entering repayment at once, recent servicing changes, and many unresolved financial difficulties from well before the pandemic, millions of borrowers might face a difficult road after pandemic-related relief expires," the analysis said.

Leading up to May 1, when the prior pause on payments was set to expire, the CFPB and other $4 warned of risks borrowers might face should they be thrown into repayment too early.

Thursday's analysis built on those risks — it identified five potential risk factors that could increase difficulties for borrowers in September, and it found that 15 million borrowers have at least one of the risk factors, with 5 million having at least two.

Here are the five characteristics of student-loan borrowers who might face hardship once relief expires:

1. Being delinquent on student loans pre-pandemic
2. Having assistance with student-loan repayment pre-pandemic
3. Having student loans under multiple different companies
4. Being delinquent on other credit products since the pandemic began
5. And experiencing new third-party collections on debt since the pandemic began.

Confusion surrounding transfers to a different student-loan company, and having debt held by multiple companies, is something the CFPB has been keeping a close eye on over the past year.

Major companies, including $4 and $4, announced they would be ending their federal contracts, and the CFPB wrote in its analysis that while having multiple servicers "does not necessarily mean borrowers will face greater difficulties," they may be at increased risk of confusion and lack of clarity surrounding repayment and loan forgiveness programs.

And falling behind on payments has remained a big issue. The California Policy Lab recently found $4 student-loan borrowers were at "high risk" of being unable to pay if payments were to resume in May, following a similar $4 from the Government Accountability Office.

In an attempt to help those behind on payments, the Education Department announced a plan to $4 all those in default on their debt to good standing before they would have to reenter repayment, but it's unclear what impact that will have after payments resume.

Over recent months, the CFPB has $4 against student-loan companies accused of lying to borrowers and misrepresenting repayment options, and Chopra made clear that enforcement will continue leading up to repayment.

"The $4's findings put renewed emphasis on our concerns that servicing failures can hamper borrowers' access to available loan relief and cancellation options," Chopra wrote on Twitter. "The CFPB will continue to take action to ensure that student loan servicers follow the law."