Single Pay Loans

Within the MLA it states a number of excluded transactions, with one of those being a loan not subject to a finance charge and re-payment in 3 or fewer installments. Are these two exclusions to be tied together with the word OR? Since our single pay loans are re-paid in less than 3 installments one would think the single pay loan is excluded, but on the other hand the single pay loan is subject to a finance charge...so then it's in?

How are others handling single pay loans in your institution?

We considered them as covered because of finance charge.

I would consider it covered. When I think of 'no finance charge and [I believe it's 4 or less] installments, I think of common repayment plans on certain overdraft courtesy programs developed to avoid Z on those features.

Reg Z coverage requirements, note my emphasis:

(c) Coverage. (1) In general, this part applies to each individual or business that offers or extends credit, other than a person excluded from coverage of this part by section 1029 of the Consumer Financial Protection Act of 2010, Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law 111–203, 124 Stat. 1376, when four conditions are met:

(i) The credit is offered or extended to consumers;

(ii) The offering or extension of credit is done regularly;

(iii) The credit is subject to a finance charge or is payable by a written agreement in more than four installments; and

(iv) The credit is primarily for personal, family, or household purposes.