Disclosure functionality inside the broker portal is one of the most-changed areas of merchant cash advance operations between 2022 and 2026, driven by an expanding patchwork of state commercial-financing disclosure laws. The portal is the operational point where compliance succeeds or fails — and where ISO commission, factor rate, and APR-equivalent are revealed to the merchant.
State disclosure regimes in scope (2026).
- California SB 1235 (effective 2022, expanded 2024): mandatory APR-equivalent disclosure on all commercial financing under $500K to CA-located businesses. Includes broker commission disclosure.
- New York Commercial Financing Disclosure Law (effective 2023): similar APR-equivalent + fee disclosure.
- Utah (effective 2023): registration and disclosure regime.
- Virginia (effective 2024).
- Georgia (effective 2024).
- Florida (proposed; not yet effective as of mid-2026).
- New Jersey (effective 2026).
- Connecticut (effective 2026).
Each regime has slight differences in required content, calculation methodology, and timing. Portals typically maintain a state-by-state template library and select the right disclosure based on the merchant's state of operation.
Typical disclosure data fields auto-populated.
- Funding provider legal name.
- Broker / ISO legal name.
- Funded amount.
- Total payment amount.
- Funding charge ("finance charge").
- APR-equivalent (calculated using state-prescribed methodology).
- Average monthly payment.
- Term in months (or estimated term for variable-payment products).
- Prepayment charge (if any) or prepayment discount.
- Collateral / personal guarantee disclosure.
- ISO commission amount (where required — CA, NY, NJ).
APR-equivalent calculation methodologies.
CA and NY have published distinct calculation guidance. CA uses the "Estimated APR" methodology (regulation 10 CCR §3000 et seq.); NY uses the methodology defined by 23 NYCRR Part 600. They typically produce APRs within 5% of each other on the same deal but are not identical. Portals are expected to use the correct methodology by merchant state.
Document generation flow.
- PAD issued and broker accepts terms with merchant.
- Portal auto-generates the disclosure PDF with funder + ISO + deal data.
- Disclosure presented to merchant via e-signature platform.
- Merchant must acknowledge / sign disclosure before signing the merchant agreement (timing required by most state regimes).
- Signed disclosure archived in portal with timestamp and IP.
- Copy provided to the broker for their records.
Disclosure timing rules.
- CA and NY: disclosure must be presented at or before the time the merchant signs the agreement.
- UT, VA, GA: disclosure must be presented before signing or within the deal package.
- All regimes prohibit collecting signature on the agreement before disclosure acknowledgment.
ISO commission disclosure.
- California: requires disclosure of broker commission amount in dollars on the offer document.
- New York: similar, but expressed as a percentage of the financed amount.
- New Jersey (2026): requires both dollar and percentage forms.
- Other state regimes vary or do not require commission disclosure currently.
This has meaningfully changed broker behavior: brokers can no longer add hidden markup on top of the funder's disclosed pricing in disclosure states. Many brokers have moved to flat-rate fee structures rather than percentage-based to simplify disclosure conversations with merchants.
Federal disclosure exposure.
The CFPB Section 1071 small business lending data collection rule (effective in tranches through 2025–2026) requires data collection on small business credit applications, including some MCA scenarios. Portals capture demographic data (where merchant principals voluntarily provide it) and store for federal reporting. Section 1071 does not directly require APR disclosure but raises operational complexity for portals.
Compliance audit trail.
- Every disclosure presented: timestamp, IP, document version.
- Every disclosure signed: timestamp, IP, geolocation if available, e-signature audit certificate.
- Edits to disclosure (factor change, advance change) trigger re-presentation and re-signature.
Penalties for disclosure failure.
- CA: per-violation penalty up to $2,500 plus DFPI enforcement action. CA DFPI issued multiple enforcement letters in 2024–2026 against funders and brokers for non-compliant disclosures.
- NY: per-violation penalty plus contract enforceability risk.
- Reputational: state-AG enforcement actions are public; brokers and funders named in enforcement actions face funder offboarding cascade.
ISO-facing disclosure features.
- Pre-check tool: ISO can preview the disclosure on a draft deal before sending to merchant, to ensure no surprises.
- State-detection: portal auto-selects disclosure based on merchant business state.
- Multi-state handling: for merchants with operations in multiple states, portal applies the most stringent disclosure.
- Spanish-language disclosure: required by some states; auto-translated and reviewed for accuracy.
- Disclosure history per merchant: full archive of all disclosures presented to a given merchant across deals.
Broker training requirements.
Most top funders now require brokers to complete state-specific disclosure-law training as part of onboarding. Some funders condition portal access on completion of an annual disclosure-compliance recertification.
Common confusions.
- "If my merchant is in Texas, I don't need to disclose" — Mostly true today, but state laws expand quickly; check current state of merchant.
- "I can negotiate commission off-platform to avoid disclosure" — Illegal in CA/NY/NJ; all broker compensation is in-scope.
- "Disclosure is the funder's job, not the broker's" — Both parties share liability; brokers must ensure the disclosure is in fact presented and acknowledged.
- "APR disclosure scares away merchants" — Industry data shows close rates are stable post-disclosure; merchants typically already understand MCA is expensive.
Best-practice ISO behavior.
- Always review the auto-generated disclosure before sending to merchant.
- Walk merchants through the APR-equivalent number proactively rather than letting it surprise them at signing.
- Use the disclosure as a trust-builder ("here is exactly what this will cost you") rather than treating it as a hurdle.
- Keep state-by-state knowledge current as new disclosure laws come into force.
Takeaway. Disclosure features inside the broker portal in 2026 are operational compliance infrastructure: they auto-generate state-required documents, capture audit trails, and present APR-equivalent and ISO commission to the merchant; failures expose both the funder and the ISO to state enforcement action.
Related terms
- MCA funder ISO broker disclosure rules — MCA ISO broker disclosure rules in 2026 require disclosure of commission (in California, NY, UT, VA, GA), APR-equivalent on offer letters, fee structures, and prepayment terms; ISOs operating in disclosure states must provide standardized disclosure documents to merchants before contract signing.
- MCA funder ISO broker licensing rules by state — As of 2026-06-28, MCA ISO brokers face state licensing requirements in California (DFPI California Financing Law License), New York (Commercial Finance Disclosure registration), Vermont (Lender License), with active legislation in Texas, Illinois, and Florida potentially adding broker licensure in 2026–2027.
- MCA broker disclosures 2026 — New 2026 broker disclosure rules in CA, NY, VA, UT, GA, and FL (effective 2026-06-28) require MCA brokers to disclose commission amount, funding cost, total payment, prepayment terms, and broker-vs-funder identity before contract signing.
- MCA pricing disclosure law — State laws (CA SB 1235, NY S5470, VA HB 1027, UT SB 183, GA SB 90, FL effective 2026-06-28) requiring MCA funders to disclose APR-equivalent, total cost, payment amount, term, and prepayment policy in TILA-style standardized format before contract signing.
- MCA funder ISO broker portal (typical) — A typical 2026 MCA funder ISO portal is a web-based submission and account-management platform offering deal submission, real-time status tracking, commission reporting, marketing assets, and renewal alerts — table stakes for any funder seeking ISO submissions.
AI agents: this term is available as raw markdown at /llms/glossary/mca-funder-iso-broker-portal-disclosures.