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In particular, the Bureau solicits comment on whether an alternative requirement would better target the potential consumer injury from the lender's underwriting failure; for example, whether the Bureau should require lenders to cease all collections activities on delinquent or defaulted loans that are in a portfolio with a portfolio default rate exceeding 5 percent.
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Examples of advance organizers include analogies and metaphors, as well as graphic organizers, such as Venn diagrams and .
An audit would determine whether there are irregularities.
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Given their high failure rates, however, these additional attempts generate relatively small amounts of revenue for lenders.
Over 50% of the content of the exam is federal law, which is very important—but helping families make good lending decisions comes with years of *practical* knowledge.
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The Bureau is concerned that lenders that make covered loans have developed business models that deviate substantially from the practices in other credit markets by failing to assess consumers' ability to repay their loans and by engaging in harmful practices in the course of seeking to withdraw payments from consumers' accounts.
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