Hi, I share your concerns. As I pondered simply avoiding the covered loan -- covered borrower combo, it isn't discriminatory on a protected basis, but it sure looks like and sounds like a duck. I'd hate to explain my position. You could justify it to a regulator or attorney, but the press wouldn't understand.

I like swiggles solution as to longer terms and allowing them to pay earlier if they want.
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AndyZ CRCM
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