The Recreation Vehicle Dealers Association (RVDA) filed its fourth set of federal comments this week with the Consumer Financial Protection Bureau (CFPB), asking for clarification on the issue of whether RVs constitute “dwellings” and, more importantly, whether the CFPB has the legal authority to regulate RV dealers under Regulation Z.

According to an article in RV Executive Today Online, RVDA provided numerous justifications why all RV sales should be treated as motor vehicle sales and not as mortgage-type transactions, and why RV dealers should face only one set of regulations enforced by the FTC, rather than an additional set of rules and regulations administered by the CFPB.

In 2010, RV dealers were given an exemption from CFPB oversight in return for more vigorous scrutiny and enforcement by its current regulators – the Federal Trade Commission enforcing rules established by the Federal Reserve. Now, however, it appears that the CFPB is formalizing a back route to regulate RV dealers when they sell RVs to full-timers, since this may be seen as a mortgage type transaction on a dwelling rather than a traditional vehicle sale. This would bring RV dealers back into CFPB oversight. RVDA is highlighting the difficulties and expenses this would cause to the industry.

RVDA said that RV dealerships, which are overwhelmingly small-business enterprises, would face unconscionable financial risks and logistical difficulties when selling an RV to a full-timer unless the CFPB clarifies that an RV is not a dwelling when sold to a small market niche of RV enthusiasts.