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There are a couple reasons why some merits are restricted. Some the HST prefers to be awarded for exceptional and epic roleplay. Others can be taken but only if a character is found/made that will serve the role and develop the story. Others have criteria like a specific breed, tribe, etc.,

HST Rewarded MeritsEdit

Elder's Favor (1-3) Player's Guide to Garou p. 162

Geas (1-5) Player's Guide to the Changing Breeds p. 164)

Notoriety (3) Player's Guide to Garou p. 162

Reputation (2) Player's Guide to Garou p. 162

Require Played Character MeritsEdit

True Love (4) Player's Guide to Garou p. 165