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Two clarifying questions regarding MLA applicability:
1. Is an auto loan refinance exempt from MLA because the transaction is not financing the “purchase” of the automobile?
2, Does MLA applicability differ if the borrower owns the automobile free and clear versus paying off another lender with the auto loan refinance?1. Is an auto loan refinance exempt from MLA because the transaction is not financing the “purchase” of the automobile?
A transaction to refinance the purchase of an automobile does not meet one of the exceptions and, therefore, would be a covered transaction under the MLA.
2, Does MLA applicability differ if the borrower owns the automobile free and clear versus paying off another lender with the auto loan refinance?
If the borrower already owns the automobile and it putting it up as collateral for a loan (vehicle title loan) that would be covered transaction under the MLA.
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