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Moreover, the fact that the proposal would have such a disruptive impact on these lenders' current source of revenue does not, in the Bureau's view, detract from the appropriateness of these provisions to prevent the unfair and abusive practice that the Bureau has preliminarily identified.
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The Bureau is also concerned about the further complexity that would result from attempting to craft additional rule provisions designed to prevent other conduct taken with the intent of evading the proposed rule.
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