MLA- Applicable to Auto Leases?

Posted By: Permissible Purpose

MLA- Applicable to Auto Leases? - 12/03/20 11:35 PM

Hello all,

Quick question- is the MLA applicable to auto leases?

I am assuming yes so long as the lease contains a finance charge, has more than 4 installments, and has an applicable purpose. An auto lease seems to fit the criteria listed within the definition of "consumer credit" and does not meet the exceptions listed 232.2(2)(i) through (iv).

Thoughts are greatly appreciated!

Thanks!
Posted By: Andy_Z

Re: MLA- Applicable to Auto Leases? - 12/04/20 07:09 PM

Leases are not covered under the MLA. It includes credit and Reg Z type products. Consumer leases are under Reg M.

The MLA does not include residential or vehicle leases. The SCRA can, but there is no MLA requirements here.