If it were in my shop, I would probably agree with 1a2 for loan 1. As far as loan 2, I would also want to review my state usury laws...here in Missouri, it speaks to that situation and the loan amount helps us determine what we are dealing with.
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Born once? Die twice.
Born twice? DIE ONCE!
Loan Review, HMDA, ALLL
Opinions are my own and do not reflect any others