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Commercial Loans Financial Services Industry Disclosure Requirements

Womble Bond Dickinson

Insurance Premium Finance Exemption Enacted - Missouri Commercial Finance Disclosure Law

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As we reported last year, Missouri introduced its version of Commercial Finance Disclosure Law (“CFDL”) legislation, following the lead of other states with laws requiring consumer-like disclosures in certain commercial...more

Holland & Knight LLP

Texas Governor Signs Commercial Sales-Based Financing Legislation Into Law

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Texas Gov. Greg Abbott signed House Bill (HB) 700 into law on June 20, 2025, despite significant opposition from industry with respect to one critical legislative provision. This follows the legislation's approval by the...more

Sheppard Mullin Richter & Hampton LLP

Texas Legislature Proposes Disclosure Rules for Commercial Financing 

The Texas House and Senate introduced House Bill 700 and Senate Bill 2677 to regulate commercial sales-based financing transactions. The proposed legislation would impose standardized disclosure requirements, require broker...more

Womble Bond Dickinson

Insurance Premium Finance Exemption - Maryland Commercial Finance Disclosure Legislation

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Maryland recently introduced Commercial Finance Disclosure Law (“CFDL”) legislation in both the House (HB 693) and Senate (SB 754), following a path of other states with laws requiring consumer-like disclosures in certain...more

Alston & Bird

Missouri Enacts Commercial Financing Law

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What Happened? As we have previously apprised you, California, New York, Utah, Virginia, Georgia, Florida, Connecticut, and Kansas have enacted laws that require certain commercial financing “providers” to furnish certain...more

Hudson Cook, LLP

Featuring BizFinLaw - November 2024

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In Texas Bankers Association v. Consumer Financial Protection Bureau, the U.S. District Court for the Southern District of Texas denied a summary judgment motion by the Texas Bankers Association and other plaintiffs to set...more

Alston & Bird

States Impose Commercial Financing Disclosure Requirements

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What Happened: In a little-noticed development, eight states have enacted legislation that requires specific disclosures for commercial non-real estate secured financing transactions....more

Husch Blackwell LLP

Missouri Enacts New Commercial Finance Disclosure Law

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Missouri is now part of the growing list of states who have introduced commercial finance disclosure requirements. Additionally, the statute – Section 427.300 of Missouri Senate Bill 1359 – contains substantial requirements,...more

Sheppard Mullin Richter & Hampton LLP

Kansas Enacts Earned Wages Access Law

On April 19, less than a month after Wisconsin’s enacted legislation, Kansas has followed suited by enacting comprehensive earned wages access legislation. Kansas’ law is set to take effect immediately upon publication....more

Sheppard Mullin Richter & Hampton LLP

Kansas Introduces New Commercial Financing Disclosure Law

On April 17, the Kansas Legislature signed SB 345, to become the most recent state to enact disclosure requirements for small business lenders. The law’s requirements apply to “providers” which are defined as persons who...more

Orrick, Herrington & Sutcliffe LLP

California enacts law to extend commercial financing cost disclosure requirement

On October 7, the California governor signed SB 33 to, among other things, continue to require covered providers offering commercial loans to disclose the total cost of financing expressed as an annualized rate indefinitely....more

BCLP

New York’s Detailed Commercial Finance Disclosure Requirements Take Effect

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Compliance with the requirements of New York Financial Services Law sections 801-811 (the Commercial Finance Disclosure Law or “NYCFDL”) as implemented by the New York Department of Financial Services (“DFS”) becomes...more

Alston & Bird

Georgia, Florida, Connecticut Enact Commercial Financial Disclosure Laws

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Our Financial Services & Products Group illuminates three new state laws in Georgia, Florida, and Connecticut requiring provider disclosures in commercial financing transactions....more

Orrick, Herrington & Sutcliffe LLP

Florida is next state to enact commercial financing disclosure requirements

On June 23, the Florida governor signed HB 1353 (the “Act”), creating the Florida Commercial Financing Disclosure Law and imposing several requirements on commercial financing providers and brokers. The Act defines a...more

Orrick, Herrington & Sutcliffe LLP

Georgia enacts commercial financing disclosure requirements

On May 1, the Georgia governor signed SB 90 to, among other things, require disclosures in connection with commercial financing transactions. The amendments modify the existing state Fair Business Practices Act and apply to...more

Orrick, Herrington & Sutcliffe LLP

What Commercial Finance Companies Need to Know About New Commercial Financing Disclosure Rules

There has been increased focus on commercial financing transactions over the past few years. States have been moving to introduce consumer lending disclosure regimes to commercial financing. Several states, including...more

Holland & Knight LLP

New York's "Small Business" Commercial Financing Disclosure Law

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If you are a nonbank finance company that makes commercial loans of $2.5 million or less in New York or represent such a company, this Holland & Knight alert is for you. There has been a growing concern expressed over the...more

Goodwin

New York Finalizes Commercial Financing Disclosure Regulations

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On February 1, 2023, the New York State Department of Financial Services (DFS) adopted final regulations relating to New York’s Commercial Finance Disclosure Law (CFDL), which requires providers of commercial financing,...more

Moore & Van Allen PLLC

States Look to Impose Financing Disclosure Requirements on Commercial Loans and the CFPB Considers Potential TILA Preemption...

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In December 2021, the Bureau of Consumer Financial Protection (or the “CFPB”) issued a notice and request for comment (the “Notice”) on its intention to make a preemption determination regarding the Truth in Lending Act...more

Ballard Spahr LLP

Utah and Virginia enact registration and disclosure requirements for providers of merchant cash advances

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Utah and Virginia recently became the first two states to require the registration of providers of merchant cash advances.  The new laws also include disclosure requirements.  (Although laws requiring disclosures for merchant...more

Sheppard Mullin Richter & Hampton LLP

Utah Enacts Commercial Financing Disclosure Requirement

On March 24, Utah Governor Spencer Cox signed SB 183 into law making Utah the third state in the country to enact a Truth in Lending-like commercial financing disclosure law.  Utah joins California and New York to adopt such...more

Mayer Brown

Utah Enacts Commercial Financing Disclosure Law with a Registration Obligation

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Utah has followed California and New York by enacting its own Truth in Lending-like commercial financing disclosure law, but with an additional twist—Utah’s new law has a registration requirement. On March 24, Utah Governor...more

Miles & Stockbridge P.C.

Maryland Joins Other States Proposing Commercial Finance Disclosure Laws: Truth-in-Lending Type Disclosures in Commercial Loans

Earlier this month, Maryland State Senator Benjamin K. Kramer introduced Senate Bill 825 titled “Consumer Credit - Commercial Financing Transactions.” Although not obvious from the bill’s title, it contains legislation...more

Miles & Stockbridge P.C.

New York Moves Forward to Regulate Commercial Loan Disclosures to Small Businesses

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In the absence of a federal law requiring disclosures be provided to small businesses, regulators in California in 2018, and now New York, have jumped into the void. With the Enactment of the New York Commercial Finance...more

Miles & Stockbridge P.C.

Commercial Lender Licensing and Commercial Loan Disclosures in New York

To date, the licensing and disclosure obligations for lenders and brokers of commercial loans, (including commercial mortgage loans and non-real estate-secured commercial or business purpose loans) have not received the...more

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