The Recreation Vehicle Dealers Association (RVDA) is investigating why the Consumer Financial Protection Bureau (CFPB) intends to regulate recreational vehicles even though Congress specifically exempted traditional RV dealers and the products they sell from CFPB oversight.

In 2010, RV dealers were given a pass from CFPB oversight in return for more vigorous scrutiny by the Federal Trade Commission (FTC). Now, however, RVDA said it appears that the CFPB is formalizing a back route to regulate RV dealers when they sell RVs to full-timers.

The bureau intends to adopt a slightly modified version of the Truth-In-Lending-Act’s Regulation Z that may draw RV dealers back into its purview in certain sales transactions. At issue, once again, is whether recreational vehicles are considered dwellings.

RVDA is drafting its fourth set of federal comments to clarify the “dwelling” issue and, more importantly, whether the CFPB has the legal authority to regulate RV dealers under Regulation Z.