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Since the inception of the Consumer Financial Protection Bureau (CFPB or Bureau), much debate has occurred over a key threshold question: how should regulators or lawmakers decide that a novel product constitutes a “lending product”? Is the product at issue in the bailiwick of banking or insurance regulators? Not only has the question (“is it credit”?) been unfolding recently in regards to potential regulation of fintech providers and certain earned wage access products, this classification question also often arises with respect to brick-and-mortar outlets, point-of-sale transactions, or products that have otherwise been around for some time, e.g., rent-to-own or pension-advance services and structured settlements.