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The Bureau believes that most lenders making covered longer-term loans already have the ability to comply with this provision, with the possible exception of lenders with affiliates that are run as separate operations.
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The Bureau solicits comment on whether to permit open-end loans to be made under this conditional exemption; whether lenders would choose to make open-end loans under this conditional exemption if permitted to do so; and what the benefit for consumers would be of permitting such loans and what additional conditions may then be appropriate for proposed § 1041.
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