State Commercial Financing Disclosure Laws: What MCA Brokers Must Know

What are commercial financing disclosure laws?

Commercial financing disclosure laws require the company offering business financing to give the business owner a standardized summary of the cost and terms before the deal closes. Think of them as a business-financing cousin of consumer truth-in-lending rules, adapted for products such as merchant cash advances, factoring and term loans.

These laws matter to MCA brokers for a specific reason. A merchant cash advance is a purchase of future receivables, not a loan, and for years that distinction kept MCAs outside most lending rules. Most of the new state statutes close that gap by name: they cover "sales-based financing" or "accounts receivable purchase transactions" directly, regardless of whether the product is a loan.

This guide is a plain-English overview as of October 2026. Laws, regulations and agency guidance change, and thresholds and exemptions have details that matter. Confirm current requirements with counsel and the state regulator before relying on any summary, including this one.

Which states have commercial financing disclosure laws?

Eleven states have laws in force that reach MCA offers, and two more regimes have been enacted with later start dates.

What does each state's law require?

California

California was first, with a 2018 statute whose regulations took effect December 9, 2022. Providers must give an estimated annual percentage rate along with other cost terms on offers of $500,000 or less. SB 362, effective January 1, 2026, restricts using the words "rate" or "interest" in misleading ways and requires the terms "annual percentage rate" or "APR" where an APR is described. A separate bill, AB 2116, signed September 30, 2026, brings commercial financing providers and brokers under California Financing Law licensing starting July 1, 2028, according to law-firm commentary. Buying California MCA leads means planning for all three.

New York

New York's rules cover financings up to $2.5 million for recipients whose business is principally directed or managed from New York. Brokers who present offers are treated as providers. A broker may not quote specific terms until it has passed along the required disclosures unaltered, and must keep evidence of when it sent them. The regulation also requires telling the recipient how the broker is paid. See our page on New York MCA leads.

Utah

Utah pairs disclosures with registration. Providers must register with the Department of Financial Institutions, renewing annually through NMLS, and give disclosures on transactions of $1 million or less. Unlike California and New York, Utah does not require an APR disclosure.

Virginia

Virginia's law targets sales-based financing specifically. Providers and brokers had to register with the State Corporation Commission by November 1, 2022, and providers must give disclosures with a specific offer. Single transactions over $500,000 and parties with five or fewer transactions in a 12-month period are exempt.

Florida

Florida's statute applies to commercial financing of $500,000 or less consummated on or after January 1, 2024. The Attorney General has exclusive enforcement authority, there is no private right of action, and fines are capped in the aggregate, with a higher cap for violations that continue after written notice.

Georgia

Georgia added its disclosure rules to the Fair Business Practices Act, at O.C.G.A. 10-1-393.18. They cover transactions of $500,000 or less consummated on or after January 1, 2024, by providers that do more than five deals a year.

Connecticut

Connecticut focuses on sales-based financing of $250,000 or less. Disclosures in the Department of Banking's prescribed format apply to offers made on or after July 1, 2024, and providers and brokers had to register through NMLS by October 1, 2024. The law also bars a provider from changing a specific offer until midnight of the third calendar day after making it.

Kansas

Kansas's act, effective July 1, 2024, covers commercial loans, accounts receivable purchases and open-end commercial credit up to $500,000. Disclosures must show total funds provided and disbursed, total of payments, total dollar cost and prepayment terms. The Attorney General enforces it, and no registration is required.

Missouri

Missouri's SB 1359, signed July 11, 2024, requires brokers to register with the Division of Finance, keep a $10,000 surety bond and renew annually. Disclosure duties were set to begin February 28, 2025, or six months after the Division adopted implementing rules if it chose to; confirm the current status with the Division.

Texas

Texas HB 700 took effect for most purposes on September 1, 2025. It requires disclosures on commercial sales-based financing, restricts certain automatic debits, and requires providers and brokers to register with the Office of Consumer Credit Commissioner through NMLS by December 31, 2026, under rules the agency finalized in 2026. See Texas MCA leads.

Louisiana

Louisiana's Act 198, effective August 1, 2025, applies to revenue-based financing structured like an MCA. It requires a written disclosure at or before consummation, has no dollar threshold or entity exemptions, requires no registration and does not require an APR.

Vermont (from 2027)

Vermont's Act 142, signed June 16, 2026, applies from July 1, 2027 to sales-based financing and factoring under $1 million. Commentators report it will require provider and broker licenses, a signed disclosure with an estimated APR, and it voids confession-of-judgment clauses.

What do these disclosures usually include?

The required content varies, but most state forms ask the provider to show some version of the following:

• The total amount of financing and the amount actually disbursed after fees or payoffs.
• The total repayment amount, or for an MCA, the purchased amount of receivables.
• The finance charge or total dollar cost of the financing.
• An estimated APR, in states that require one, such as California, New York and, from 2027, Vermont.
• The payment method, frequency and estimated amount, including how payments are estimated for sales-based products.
• Prepayment terms and any fees or discounts tied to early payoff.
• Whether a broker is paid from the financing proceeds, and in some states how much.

Funders usually generate the disclosure. Brokers usually deliver it, and in states like New York they have their own duties around timing and evidence of delivery.

What do these laws mean for MCA brokers and ISOs?

They mean the state where the merchant is located now shapes how you present an offer, whether you need a registration and what records you keep. In practice:

• Know the merchant's state before quoting. Capture it on the first call and in your CRM, not just from the lead form.
• Register where required. Virginia, Connecticut, Missouri and Texas require broker registration as of 2026, and Vermont and California are adding licensing.
• Do not paraphrase the disclosure. Deliver the funder's form as issued, and keep proof of when and how you sent it.
• Watch your language. Calling an MCA a loan or quoting a factor rate as an interest rate is inaccurate and, in California, can run into SB 362.
• Disclose compensation where the state requires it.

Our page for ISOs and brokers explains how state filters let you buy only in states where your paperwork is in order.

How can you build a state compliance workflow?

Build it once, keep it current and tie it to your lead flow.

1. List every state where you will make offers.
2. For each, record the law, thresholds, registration status, renewal dates and the disclosure format your funders use.
3. Complete registrations before buying leads in a registration state.
4. Set your lead filters to match the states you are ready to serve.
5. Add a CRM checkpoint that blocks sending terms until the disclosure is logged.
6. Review the list each quarter with counsel, since new laws keep arriving.

For telemarketing rules that sit alongside these laws, see the MCA lead buyer's compliance checklist for 2026.