There are only 2 examples in this video at 0:52 and 1:05, but I don't think anyone will argue that they are NOT megaloops... and yet, the kiter is never above the kite. What DOES happen, is that as the kite is climbing to the zenith
after it's pulled the rider horizontally, the rider is free-falling until the kite catches him/her.
Kite lower than the rider is a sub-sub-type... the psycho loop!