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Financing Disclosure Requirements Financial Institutions

Troutman Pepper Locke

Texas Introduces Legislation to Regulate Sales-Based Commercial Financing

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Last month, the Texas legislature introduced two companion bills, S.B. No. 2677 and H.B. No. 700, to regulate sales-based commercial financing. For purposes of the proposed legislation, sales-based financing is a transaction...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

Venable LLP

New Commercial Financing Requirements Become Effective in Connecticut and Kansas

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Over the past several years, many states have considered and enacted requirements requiring commercial financing providers to give disclosures when extending commercial financing....more

Ballard Spahr LLP

Connecticut Department of Banking issues guidance on consumer-like disclosures in sales-based financing offers

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On June 10, 2024, the Connecticut Department of Banking (“Department”) issued guidance (the “Guidance”) to give direction on required consumer-like disclosures in certain commercial financing offers....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

Troutman Pepper Locke

Connecticut Becomes Latest State to Enact a Commercial Financing Disclosure and Registration Law

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On June 28, Connecticut Governor Ned Lamont signed into law Senate Bill 1032 entitled An Act Requiring Certain Financing Disclosures, which requires certain providers of commercial financing to make various disclosures and...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

Cadwalader, Wickersham & Taft LLP

New York Department of Financial Services Issues Regulations Regarding Commercial Finance Disclosures

The State of New York passed a law in December 2020 – the Commercial Finance Disclosure Law (“CFDL”), with an effective date of June 2021 – that prescribed required disclosures for commercial finance transactions that are...more

Goodwin

New York Finalizes Commercial Financing Disclosure Regulations

Goodwin on

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

Ballard Spahr LLP

New York Department of Financial Services issues final regulations for consumer-like disclosures for commercial financing

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The New York Department of Financial Services (DFS) has issued final regulations implementing the state’s Commercial Finance Disclosure Law (CFDL) which requires consumer-like disclosures for “commercial financing”...more

Mayer Brown

The Suspense Is Over – NYDFS Adopts Final Commercial Financing Disclosure Rules, Announces Effective Date, and Provides New...

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Small business financers and brokers (“providers”) active in New York are officially on notice to finalize their preparations to comply with New York’s Commercial Finance Disclosure Law (“CFDL”) by August 1, 2023, the new...more

Orrick, Herrington & Sutcliffe LLP

NYDFS finalizes commercial financing disclosures

On February 1, NYDFS adopted a final regulation (23 NYCRR 600) outlining disclosure requirements for commercial financing transactions in the state. Under the state’s Commercial Finance Disclosure Law (CFDL)—which was enacted...more

Husch Blackwell LLP

Commercial Financing Disclosure and Broker Registration Bill Introduced in Missouri

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On January 5, 2023, a bill was introduced in the Missouri legislature that would require non-depository financial institutions to provide disclosures at or before consummation of certain commercial financing products....more

Morrison & Foerster LLP

Square Peg, Round Hole: MCA Disclosures Under the California Commercial Financing Disclosure Regulations

In the third in our series on the California Commercial Financing Disclosure Regulations, we focus on the disclosure requirements for merchant cash advances (MCAs)....more

Katten Muchin Rosenman LLP

Utah Becomes Third State to Enact Smaller Commercial Transaction Disclosure Law

On March 24, Utah Governor Spencer Cox signed into law SB 183, a bill that contains certain commercial transaction disclosure requirements applicable to prescribed providers of many forms of "smaller" business credit. Utah...more

Hudson Cook, LLP

Utah Enacts Commercial Financing Disclosure Law

Hudson Cook, LLP on

On March 24, Utah Governor Spencer Cox signed S.B. 183, the Commercial Financing Registration and Disclosure Act ("CFRDA"). This makes Utah the third state to adopt a commercial financing disclosure law, following California...more

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