What they told me was that this particular loan (the one last summer) was exempt from this regulation because it was over the $25K threshold for Reg Z (we only had one title loan on the books at the time).
We just booked another to a person for business equipment, and I'm trying to make sure it's exempt (the lender wasn't supposed to make it for a term less than 181 days just in case, but of course he did it anyways)...
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The beatings will continue until morale improves...