Ed you might want to refer to the following to re-think your answer:
§969.6. Definitions
(9) "Consumer loan" means a loan of money or its equivalent made by a lender, the
proceeds of which are used by the consumer to purchase or refinance the purchase of a motor
vehicle, or which proceeds are used for personal, family, or household purposes, including debts
created by the use of a lender credit card, revolving loan account, or similar arrangement, as well
as insurance premium financing, with the lender acquiring a purchase money security interest in
the purchased motor vehicle. A consumer loan may be secured by other collateral in addition to the
purchased vehicle.