Pain and Gain is also a comedy of sorts, which is not really a first, because Bay pretty clearly takes great, smug pleasure in the ample, amped-up comic relief of all of his movies save Pearl Harbor (even The Island has plenty of nudge-nudge shtick). Even more than his sometimes incoherent cutting, his embarrassingly cornporne (and dubiously sincere) jingoism, and his inability to make actors better rather embrace their worst instincts, the worst fucking thing about Bay is how hilarious he thinks he is. A buddy of mine recently pointed out that one of Bay's comic tics, his immediate clarification of what he's referencing (in Bad Boys, Martin Lawrence screaming out "Wesley Snipes! Passenger 57!" during a fight scene: a topical reference then; a Family Guy-ish non sequitur with age; in Armageddon, jokes about Chewbacca or giant needles in the heart unable to pass without explicitly saying the words "Star Wars" and "Pulp Fiction") is actually shared with The Office's Michael Scott. Come to think of it, so is Bay's all-in-good-fun racism, which reached a nadir in the second Transformers picture but is present in the majority of his movies (he seems to find hollering black people inherently funny).
There's also a strain of nasty dark humor running through much of his work: it was there as far back as The Rock, which settled on gruesome slapstick for a few scenes in between operatically serious action and wacky buddy comedy, all part of that movie's underreported tonal whiplash; and it got a bigger showcase in the corpse-filled Bad Boys II. So, as explosion-light as Pain and Gain may be, I fully expect it to be recognizably Bay, which is to say I'm afraid it's basically going to be like rewatching Peter Berg's atrocious Very Bad Things. (Berg certainly did his best Bay impression for Battleship last year.)