MLA Exemptions

You are correct that the exceptions state "a dwelling" must be included as a residential mortgage exception (2)(i). The other possible exception in a consumer loan otherwise applicable to the MLA could be purchased personal property securing the loan. There is no commentary to clearly indicate here if real and personal property are separate for these purposes but (2)(iii) seems broad and why would an appliance (for example) be allowed an exception but not real property being financed? When in doubt disclosures may always be made, or an offocial opinion could be requested from the DoD.

https://www.bankersonline.com/regulations/32-232-003

(2) Exceptions. Notwithstanding paragraph (f)(1) of this section, consumer credit does not mean:

(i) A residential mortgage, which is any credit transaction secured by an interest in a dwelling, including a transaction to finance the purchase or initial construction of the dwelling, any refinance transaction, home equity loan or line of credit, or reverse mortgage;

(ii) Any credit transaction that is expressly intended to finance the purchase of a motor vehicle when the credit is secured by the vehicle being purchased;

(iii) Any credit transaction that is expressly intended to finance the purchase of personal property when the credit is secured by the property being purchased;

(iv) Any credit transaction that is an exempt transaction for the purposes of Regulation Z (other than a transaction exempt under 12 CFR 1026.29) or otherwise is not subject to disclosure requirements under Regulation Z; and

(v) Any credit transaction or account for credit for which a creditor determines that a consumer is not a covered borrower by using a method and by complying with the recordkeeping requirement set forth in § 232.5(b).