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March 16, 2009



First, congratulations to Mandy and Anthony!! Da Twins are beautiful!
I need some reassurance re: this Higher Ed Act. I see that as an FCU, we are subject to the rule. Our education loans are revolving, open-end while the student is in school, which exempts us from the rule. What I can't figure out for absolute surety is: I think that even though our open-end loans are converted to closed-end after the student has completed school, we are still exempt because we are not directly issuing the loan expressly for educational purposes. Thoughts?

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