I was in a discussion recently addressing personal property and cars. The rule separates vehicles from personal property. Excepted are cars, so RVs, 4 wheelers and the sort are separated from cars by definition. That means they are not excluded as cars.

Are they now exempted as personal property? They are not real estate, they are personal property. But since vehicles are separated from personal property, and cars are separated from other vehicles, are these other vehicles actually covered? They were separated from personal property and they were separated from cars, leaving them, in some opinions, as covered items.
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(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;
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19. Under 32 CFR 232.3(f)(2)(ii) and 232.8(f) what methods of transportation are
included within the definition of a “vehicle”?
Answer: For purposes of the MLA, the term “vehicle” means any self-propelled
vehicle primarily used for personal, family, or household purposes for on-road
transportation. The term does not include motor homes, recreational vehicles (RVs), golf
carts, or motor scooters.

We are currently operating under the idea that RVs, etc are personal property.

An attorney once told me that everything in the world is either personal property or real property. Therefore an RV is personal property. I have wondered why the DOD made the distinction. Perhaps it was to make a stated difference between a "title loan" with someone's means of transportation at stake, as opposed to everything else? But typically, in consumer lending....if a bank is going to extend a purchase money loan secured by the item being purchased, OR a loan to be secured by an already-owned item, the item is likely to be a "titled" item such as an RV, motorcycle or a boat.

My initial thought was it would be personal property but I had two legal minds indicate it must be separated for a reason. Unfortunately I can see the DoD opining either way based on whatever its intent was. Opinions issued are not always making issues clear.

We are going with personal property for boats, rvs, etc.. We researched state law for a definition of "personal property" and found over 10 different definitions.

I finally decided the rule was written to separate automobiles from all other personal property, because certain lenders are not allowed to take a vehicle title as security for a loan. The rule is trying to protect the borrower's method of transportation to and from work and the grocery store and such. I'm considering all those things that aren't defined as vehicle's as personal property. I'm at the point where I need to make a common sense decision on the parts of the rule that aren't clearly written.