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Supervisory Highlights, at 16 (Spring 2017) (“At multiple lenders, policies and procedures for record retention either did not exist or were not followed, leading to incomplete record destruction logs and improperly destroyed records.
The Bureau acknowledges that for this group of “false negatives” there may be significant benefits of being able to obtain covered loans without having to demonstrate their ability to repay in the way prescribed by proposed § 1041.
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Approximately 387,000 borrowers were positively identified in the first set of matches which were conducted in December 2017 and March 2017.
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