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While Regulation Z provides that these calculation methods are optional, these calculation methods would be required to determine coverage of loans under proposed § 1041.
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Section 1031 of the Dodd-Frank Act empowers the Bureau to prescribe rules to identify and prevent unfair, deceptive, or abusive acts or practices associated with consumer financial products or services.
But as discussed in connection with the Bureau's preliminary abusiveness finding regarding short-term covered loans, the Bureau does not believe that such a generalized understanding suffices to establish that consumers understand the material costs and risks of these loans.
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