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Sixth, the Secretary of Education, as junkyard dog, should revise Lynn Mahaffie's 2015 letter outlining when DOE will not oppose bankruptcy discharge of student loans to clarify to the federal courts that DOE supports a bankruptcy discharge of student loans under the same terms that apply to other unsecured consumer debt.

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Loans with the same interest rate, terms and out of pocket costs should be treated the same under the rule regardless of the organizational structure or business model of the lender.

The Bureau revised: The Assumption disclosures under § § 1026.37 (m) and 1026.38 (l) so that the language between the two disclosures would match; the reference language in the Loan Terms table under § § 1026.37 (b) and 1026.38 (b) so that the reference to the estimated total payment monthly payment used the same term as in the Projected Payments table under § § 1026.37 (c) and 1026.38 (c), and to put the language in sentence case to increase readability; the checkboxes in the Escrow Account disclosure on the Closing Disclosure under § 1026.38 (l)(7) to delete the «require or» from the second checkbox; change the «Agent» label on page 1 of the Closing Disclosure under § 1026.38 (a) to «Settlement Agent» to match the Contact Information table under § 1026.38 (r); removed the word «Borrower» from the «Borrower's Loan Amount» label under § 1026.38 (j) to match the term used in the Loan Terms table under § § 1026.37 (b) and 1026.38 (b); and changed the labels of the row headings in the Escrow Account disclosure on page 4 of the Closing Disclosure under § 1026.38 (l)(7) to include the word «escrow.»