Answer:
12 CFR 1026.1(c)(1) specifies four criteria that together determine whether Reg Z applies. You probably meet items (i), (ii), and (iv) for this transaction. But item (iii) says the transaction must either be subject to a finance charge or be payable by a written agreement in more than four installments. You only have one payment, so the second part of (iii) is not met. The only question remains is is there a finance charge. There is no interest, so that's normally the biggest part of the finance charge. If you are not charging the borrower any other finance charge on this transaction, I would say that you have not met (iii) and therefore Regulation Z does not apply to that transaction. If Regulation Z does not apply, no TIL is required.
First published on BankersOnline.com 4/15/13
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