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as far as I can tell, VW doesn't need any special logic around the steer req frames. It only sets HCA_ENABLED to false when apply_steer is zero, which is fine in the current panda logic:
https://github.com/commaai/openpilot/blob/master/selfdrive/car/volkswagen/carcontroller.py#L56
https://github.com/commaai/panda/blob/master/board/safety.h#L573