Goodnight! That sounds like some contorted logic. Check cashers, car title lenders, Carshields, rent-to-own businesses preying on the underbanked, are in fact, pursuing a CD purpose. Just my opinion, but I don't see the FDIC accepting this explanation for qualifying a loan as CD.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.