ivision would not have considered appellants' intent or purpose, but only the legal terms of the lease agreements and that would have inexorably led to the conclusion that appellants were offering sale-leasebacks and not loans to consumers.
But the issue before us is not which lawthe UCC or the Consumer Loan Lawoffers the most "explicit standards" for determining what is or is not a loan but rather which law prevails when the two conflict. To answer that question, *229 we need look no further than the provisions of the UCC, which categorically declare that, in such instances, the Consumer Loan Law prevails. See UCC §§ 2A-104(2), 9-201(c)(1) (providing that in case of a conflict between a consumer protection statute and either Title 2A, dealing with leases or Title 9, dealing with secured transactions, the consumer protection statute controls). And that law unquestionably permits the Division to look beneath the formal terms of an agreement and to consider the substance of that agreement in determining whether it constitutes a "loan."
Moreover, unlike appellants, we do not find the Consumer Loan Law is too vague to apply. Maryland's Consumer Loan Law applies to loans having "an original amount or value which does not exceed $6,000." CL § 12-303(a). Thus the "loans" made by appellants, which never exceeded $100 per appliance, were covered by this law. The law further provides that "[a] person may not engage in the business of making loans under this subtitle unless the person is licensed under or is exempt from the licensing requirements of Title 11, Subtitle 2 of the Financial Institutions Article, the Maryland Consumer Loan Law-Licensing Provisions." Id. § 12-302. There is no dispute that appellants did not have lending licenses. And finally, the law defines "lender" as "a person who makes a loan under this subtitle," § 12-301(c), and "loan" as "any loan or advance of money or credit made under this subtitle," § 12-301(e).
We turn now to the provision that appellants maintain is too vague for applicatio