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As a result, if the definition of payment under the covered short-term loan did not specify assumptions about consumer utilization and repayment under a line of credit, there would be uncertainty as to the amounts and timing of payments to which the ability-to-repay requirement applies.
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As detailed further below, the Bureau is proposing to specify requirements as to the format in which certain records are retained.
The reason is that lenders are associated credit risk.
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"Borrowers perceive the loans to be a reasonable short-term choice but express surprise and frustration at how long it takes to pay them back," Pew reported last year.
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