nc. v. People's Counsel, 336 Md. 569, 577, 650 A.2d 226 (1994). Substantial evidence is "`such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.'" Md. State Police v. Warwick Supply & Equip. Co., 330 Md. 474, 494, 624 A.2d 1238 (1993) (quoting State Admin. Bd. of Election Laws v. Billhimer, 314 Md. 46, 58, 548 A.2d 819 (1988)).
In making this determination, we must give "`deference ... not only [to the agency's] fact-findings, but to the drawing of inferences from the facts as well.'" Id. (quoting Billhimer, 314 Md. at 59, 548 A.2d 819). We must also accord deference to the agency's "`application of law to those [factual findings], if reasonably supported by the administrative record, viewed as a whole.'" Berkshire Life Ins. Co. v. Md. Ins. Admin., 142 Md.App. 628, 653, 791 A.2d 942 (2002) (quoting Ins. Comm'r v. Engleman, 345 Md. 402, 411, 692 A.2d 474 (1997)). "`When, however, the agency's decision is predicated solely on an error of law, no deference is appropriate and the reviewing court may substitute its judgment for that of the agency.'" Warwick, 330 Md. at 494, 624 A.2d 1238 (quoting Billhimer, 314 Md. at 59, 548 A.2d 819). Thus, if the agency's decision "`is not predicated solely on an error of law, we will not overturn it if a reasoning mind could reasonably have reached the conclusion reached by the agency.'" Id. (quoting Billhimer, 314 Md. at 59, 548 A.2d 819).

Discussion

I.
Appellants contend that the Division applied the wrong law and the wrong legal standard in concluding that their sale-leaseback transactions were really "loans," not leases. It should have applied, according to appellants, the more "explicit" standards of the Maryland Uniform Commercial Code, Md.Code (1975, 2002 Repl. Vol., 2003 Supp.) §§ 1-101 to 10-112 of the Commercial Law Article ("UCC"), rather than the "pretended purchase" provision of the Consumer Loan Law, which appellants insist "lack[s] any explicit criteria for a `pretended purchase.'" Had it done so, appellants maintain, the D