The Commentary is your best place to start:
Section 226.3—Exempt Transactions
3(a) Business, commercial, agricultural, or organizational credit.
1. Primary purposes. A creditor must determine in each case if the transaction is primarily for an exempt purpose. If some question exists as to the primary purpose for a credit extension, the creditor is, of course, free to make the disclosures, and the fact that disclosures are made under such circumstances is not controlling on the question of whether the transaction was exempt.
2. Factors. In determining whether credit to finance an acquisition--such as securities, antiques, or art--is primarily for business or commercial purposes (as opposed to a consumer purpose), the following factors should be considered:
• The relationship of the borrower's primary occupation to the acquisition. The more closely related, the more likely it is to be business purpose.
• The degree to which the borrower will personally manage the acquisition. The more personal involvement there is, the more likely it is to be business purpose.
• The ratio of income from the acquisition to the total income of the borrower. The higher the ratio, the more likely it is to be business purpose.
• The size of the transaction. The larger the transaction, the more likely it is to be business purpose.
• The borrower's statement of purpose for the loan.
Examples of business-purpose credit include:
• A loan to expand a business, even if it is secured by the borrower's residence or personal property.
• A loan to improve a principal residence by putting in a business office.
• A business account used occasionally for consumer purposes.
Examples of consumer-purpose credit include:
• Credit extensions by a company to its employees or agents if the loans are used for personal purposes.
• A loan secured by a mechanic's tools to pay a child's tuition.
• A personal account used occasionally for business purposes.
Based on that, I would say that #1, #2, & #4 are exempt transactions and #3 is not-exempt from Reg. Z.
Transaction #2 - 91% of the money is for commercial purpose. I think it can be safely argued that the primary purpose is business.
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'