CLARK, Circuit Judge:
These consolidated appeals involve actions brought by borrowers who have defaulted on loans granted under the Consolidated Farm and Rural Development Act (CFRDA), 7 U.S.C. § 1921 et seq. (1982). These borrowers challenge the Farmers Home Administration's (FmHA) implementation of loan servicing and foreclosure avoidance mechanisms contained in 7 U.S.C. § 1981a.
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