Just found out that the PA DOB has reversed their position (one more time!)and is again allowing contracts written under the MVSFA to allow up to 45 days to first payment and allow finance charges to be charged on the full number of days up to 45. They issued an interpretive letter on 3/19/04 that supersedes all prior letters regarding the subject. Here's a link to the new letter (hope it works- it's under section 613):

http://www.banking.state.pa.us/banking/cwp/view.asp?a=1296&q=528209