[tlogue]

I received a checklist from FIS today stating that a land only loan is NOT covered under MLA, but I understood when I veiwed Military Lending Act Essentials that is was covered. Can someone clarify this for me? Thank you.

[rcooper]

There is not an exception for vacant land. The definition of consumer credit from the final rule is:
f)(1) Consumer credit means credit
offered or extended to a covered
borrower primarily for personal, family,
or household purposes, and that is:
(i) Subject to a finance charge; or
(ii) Payable by a written agreement in
more than four installments.
(2) Exceptions. Notwithstanding
paragraph (f)(1) of this section,
consumer credit does not mean:
(i) A residential mortgage, which is
any credit transaction secured by an
interest in a dwelling, including a
transaction to finance the purchase or
initial construction of the dwelling, any
refinance transaction, home equity loan
or line of credit, or reverse mortgage;

(ii) Any credit transaction that is
expressly intended to finance the
purchase of a motor vehicle when the
credit is secured by the vehicle being
purchased;
(iii) Any credit transaction that is
expressly intended to finance the
purchase of personal property when the
credit is secured by the property being
purchased;
(iv) Any credit transaction that is an
exempt transaction for the purposes of
Regulation Z (other than a transaction
exempt under 12 CFR 1026.29) or
otherwise is not subject to disclosure
requirements under Regulation Z; and
(v) Any credit transaction or account
for credit for which a creditor
determines that a consumer is not a
covered borrower by using a method
and by complying with the
recordkeeping requirement set forth in
§ 232.5(b).

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