You can’t hold equity in a person, because that is slavery. All consumer liabilities are thus a form of debt. The characteristics that matter most are whether it is secured, the schedule of repayment, and the schedule of fees (interest being amongst the fees). Everything else is window dressing after those three parameters, and the label you stick on the box matters the least of all. Consequently, undischarged debt is indistinguishable from a loan, which is rather the CFPB’s point.
When push comes to shove, the substance of a thing matters much more than the attempt to relabel the thing.
When push comes to shove, the substance of a thing matters much more than the attempt to relabel the thing.