I plan to include it even though in the most technical sense, we could exempt it per Reg Z based on disclosure language and 'right to obtain your own' which is hogwash, because you can't! So I include it and will include it for MAPR as well. I'm not sure MLA would even allow that particular exemption Reg Z allows, to be honest.
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My opinion only. Not legal advice.
Say you'll haunt me - Stone Sour