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Firms that already obtain independent assessments of their information security programs at least biennially, similar to those contemplated in the proposed rule, would incur very limited cost.
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The Bureau believes that this broad definition of prepayment penalty is necessary to capture all situations in which a lender may attempt to penalize a consumer for repaying a loan more quickly than a lender would prefer.
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In accordance with this proposed finding, a lender would be generally prohibited under proposed § 1041.
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