An alternative reading from area 3709(a)(1) and you can (a)(2) is the fact that these clauses would be interpreted differently given that Congress phrased the fresh new clauses in another way. Not as much as for example a discovering, loan providers manage approve so you’re able to Virtual assistant about you to definitely band of fees, closing costs, and you will expenditures because the revealed inside the subsection (a)(1). Really the only costs is included in the recoupment age three years, although not, will be subsection (a)(2)’s the reason every costs and you will sustained costs, in which sustained costs was a clearly the and you will vague title. Quite simply, the various phrasing in the subsection (a)(2) manage do one minute and distinctive line of recoupment practical together with the one to given when you look at the subsection (a)(1).
Virtual assistant thinks one to demanding one or two ent requirements due to the fact aftereffects of a good unmarried legal phrase manage shoot unnecessary complexity on the legal program. It is VA’s condition that the text message off point 3709(a)is the reason anti-predatory lending system instead produces a harmonious, albeit not always textually obvious, recoupment important to own stakeholders. Come across Societal Laws 115-174 309, Protecting Veterans away from Predatory Lending (); Gustafson v. Alloyd Co., 513 You.S. 561, 569 (1995) (holding one to process of law must interpret laws due to the fact a shaped and you will defined regulatory system); FTC v. Mandel Brothers, Inc., 359 U.S. 385, 389 (1959) (directing process of law to fit, if possible, all the parts [of a statute] to your an good whole).
In seeing obtain will set you back as a reference to an earlier utilized name instead of the advent of a special that, VA’s translation manage eliminate the significance of system participants to visit outside of the statutory words and you will hypothesize and you may discussion Congress’s purpose. อ่านเพิ่มเติม