It is exceedingly frustrating to me how we are evidently supposed to constantly reference preambles. These things should be clearly stated in the regulation and OSC IMHO.

Adam,

Thank you so much for all the detail. I do appreciate it.

Great point raithjay. I've been saying the same thing since the CFPB took over the rule making. The regulation should be clear. When it's not, the commentary should be used to clarify. The preamble should only be used to explain intent (the spirit of the rule), not be the regulation. We should be able to read the regulation and know what we're required to do. Why is that so hard?

thank you everyone.

Thank you all