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The APR is not just the rate of interest; it also includes any other fees and charges applicable to the loan.
To effectuate this test, the Bureau would need to define, in ways that lenders could implement, what would be a qualifying “unusual and non-recurring expense,” a means of assessing whether a new loan was attributable to such an expense rather than to the unaffordability of the prior loan, and standards for how such an unusual and non-recurring expense could be documented (e.
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That's why they're willing to pay people to test these websites out to see how they function.