The AO addresses whether private education loan consolidation products that satisfy and replace multiple federal, or federal and private education loans, and private education loan refinance products that satisfy and replace a single federal or private education loan are "private education loans" for purposes of the disclosure and other requirements applicable to "private education loans" under TILA and Regulation Z. The AO sets forth the Bureau's legal analysis on which it bases its conclusion that such private education loan refinance or consolidation products are covered under the term "private education loan" in TILA and Regulation Z and therefore subject to TILA and Regulation Z's requirements in subpart F.
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