For MLA purposes, the definition of consumer credit 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.

Does this mean MLA will not apply to Single Pay or 90 Day loans? This seems odd to me since these were the type transactions covered in the initial rule. Is this right?

Thanks, but I answered my own question. I missed the (OR) in the definition, so in our case those loans are subject to a finance charge and they will be covered products.