My armchair opinion as to why Buyback is opening up pre-120 months

So this a guess but allowing people to buy back those months ahead of time makes sense as far as government accounting.

When they forgive a 100k debt the balance sheet basically says they lost 100k that day. It doesn't say "money we never intended to get back" and/or "a portion of this would never be collectable" and/or "money in lieu of having to pay a much higher salary" it's just minus 100k.

Now combine that with the number of us who experience negative amortization because we are paying the minimum. The longer the government holds that debt, the bigger it will be come forgiveness time. Thus if they can put the pieces in place for it to happen quicker after the ten years the balance sheet shows a smaller "loss."

Further, after the SAVE forbearance it will allow a temporary influx of cash in the immediate aftermath (also making it look like more of a net positive). And remember those were interest free months so any payment ahead of time for those months reduces the end balance at 10 years.

In short (in my amateur opinion) allowing early buyback makes the program "look" like it costs less.