A person may not use any device, subterfuge, or pretense to evade the application of this subchapter. A device, subterfuge, or pretense includes any transaction that in form may appear on its face to be something other than a pawn transaction, but in substance meets the definition of a pawn transaction as defined in the Texas Pawnshop Act, §371.003(8).
7 Tex. Admin. Code § 85.103