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Your firm represents a national bank (“Bank”). The Bank has many consumer lending products. Your firm reviewed one such consumer lending product and and is now in the hands of Plaintiffs’ counsel since the Product is the target of civil litigation (which is not going well). There is no dispute th 12 U.S.C. §5481(4). There is no dispute that the Product is a “consumer transaction”. See 12 U.S.C. §5481(5). The issue in dispute is whether under Section 1036 of Title X of Dodd-Frank your firm is liable. Specifically whether your firm “knowingly or recklessly” provided “substantial assistance” to a covered person or service provider that engages in any unfair deceptive or abusive act or practice. Legal malpractice aspects are being handled by another attorney. Your sole function is to evaluate whether your firm ha the Plaintiffs’ attorneys note that 12 U.S.C. Section 5536 provides “(a) In general … It shall be unlawful for— … (3) any person to knowingly or re or any rule or order issued thereunder and notwithstanding any provision of this title