Truth in Lending: 2.6.4.3 Payable by Written Agreement in More Than Four Installments
A person is a creditor if it extends consumer credit that is payable by written agreement in more than four installments (not including a down payment),208 even if there is no finance charge.209 The agreement must be in writing.210 Even a letter confirming an oral agreement does not constitute a written agreement for purposes of this definition.211