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The Dodd-Frank Act does not define “payday loans,” and the Bureau is not proposing to do so in this rulemaking.
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Like the prior comment, the Bureau is including this comment in an abundance of caution lest some lenders seek to justify a decision to make, for example, a multi-payment, interest-only loan with a balloon payment on the ground that during the interest-only period the consumer will be able to accumulate savings to cover the balloon payment when due.
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