MCA state disclosure forms in 2026 are not interchangeable — each regulated state prescribes a specific format, field order, and calculation methodology that funders must use on every covered offer to in-state merchants. Using the wrong state's form, or a generic template, exposes the funder to enforcement actions and rescission risk.
The six regulated states and their forms (mid-2026).
California (DFPI Form CFD-1). - Required since: December 2022 (regulations) for transactions $500,000 and under. - Format: Single-page disclosure with mandatory section ordering. - Required fields: Total amount of funds provided, total cost of financing, total payment amount, term length, payment frequency, estimated APR, prepayment policy, itemized fees. - APR methodology: Prescribed by DFPI regulation Section 900 — uses actuarial method with daily compounding. - Format requirement: Minimum 10-point font, plain English, no marketing copy on the disclosure page.
New York (DFS Disclosure Format). - Required since: February 2024 for transactions $2.5 million and under. - Format: Schedule A appended to financing contract. - Required fields: Total amount financed, total cost, APR, term, payment schedule, prepayment penalty disclosure, broker fees if applicable. - APR methodology: Reg Z-equivalent calculation; specific Excel-style formula provided by DFS. - Special requirement: Disclosure must be signed by merchant separately from the contract — a "double signature" rule.
Utah (UDFI Standardized Disclosure). - Required since: January 2023 for commercial financing transactions of any size by registered providers. - Format: Regulator-prescribed template available on UDFI website. - Required fields: Funding amount, finance charge, total payment, APR, term in days, payment amount and frequency, broker compensation if applicable. - APR methodology: Federal Truth-in-Lending Reg Z method.
Virginia (SCC Form CF-DISC). - Required since: July 2022 for commercial financing $500,000 and under. - Format: SCC-issued PDF template; funder fills and provides to merchant before signing. - Required fields: Similar to California with one additional field: estimated "average monthly cost of financing" as a dollar figure. - APR methodology: Actuarial method.
Georgia (GA Department of Banking Form CFD). - Required since: January 2024 for commercial financing $500,000 and under. - Format: State-issued template, two-page disclosure. - Required fields: Funding amount, finance charge, APR, term, payment amount, prepayment terms, broker fee disclosure, comparison to alternative financing. - APR methodology: Reg Z-equivalent.
Connecticut (CT DOB Form CFD-1). - Required since: July 2024 for commercial financing $250,000 and under. - Format: Single-page disclosure with field order mandated. - Required fields: Similar to California with one additional field for "estimated monthly equivalent payment." - APR methodology: Actuarial method.
Common required fields across all six states. - Funding amount (sometimes called "amount financed"). - Total cost of financing (sum of fees and finance charges). - Total payment amount (funding + total cost). - APR or estimated APR. - Term length (in days, weeks, or months). - Payment amount and frequency. - Prepayment terms and any prepayment penalty.
State-specific extras. - California, Virginia: Estimated average monthly cost. - New York: Broker compensation as a separate line item. - Georgia: Side-by-side comparison to alternative financing (loan, line of credit). - Connecticut: Monthly equivalent payment estimate.
APR calculation methodology differences. - Actuarial method (California, Virginia, Connecticut): Daily compounding, present value of payments. - Reg Z method (New York, Utah, Georgia): Federal Truth-in-Lending standard. - Practical difference: 1–3 percentage points on the same MCA depending on method. - Funders must use the state-prescribed method for the state where the merchant is located, not the funder's preferred method.
Format compliance pitfalls. - Reordering fields to suit funder marketing — strict liability violation. - Embedding marketing copy on the disclosure page — California specifically prohibits this. - Using prior-version forms after a regulator update — California updated CFD-1 in 2025. - Combining the disclosure with the contract signature page — New York's double-signature rule requires separation. - Translating into Spanish without using the state-approved translation — California requires DFPI-translated Spanish version.
Electronic delivery. - All six states permit electronic disclosure delivery with E-SIGN-compliant consent. - Merchant must affirmatively acknowledge receipt before contract signing. - Audit trail of delivery and acknowledgment must be retained for 4–7 years depending on state.
Penalties for format violations. - California: $500–$2,500 per violation; pattern of violations can trigger license revocation. - New York: Civil penalties plus rescission rights for the merchant. - Utah, Virginia, Georgia, Connecticut: Civil penalties, administrative orders, and merchant rescission rights.
Multi-state operations. Funders operating in multiple regulated states should maintain a state-specific disclosure template library, automate state selection based on merchant address, and have legal review every template at least annually for regulatory updates.
Common confusion. First, "one disclosure form works everywhere" — every regulated state requires its own format. Second, "APR is calculated the same way" — actuarial vs. Reg Z methods differ. Third, "we can put marketing on the disclosure" — California and several other states prohibit this expressly. Updated 2026-06-29.
Related terms
- MCA state disclosure timing rules — In 2026, California requires disclosure at the time of offer extension, New York requires it before any merchant signature with a 24-hour reflection window, Utah and Virginia require it at offer, and Georgia and Connecticut require it at least 24 hours before contract execution.
- 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 state licensing requirements (2026) — As of 2026, California, New York, Utah, Virginia, Georgia, and Connecticut require commercial financing disclosure registration; California and New York additionally require broker registration; Florida, Texas, and most other states still have no MCA-specific licensing, though Illinois and Missouri have advanced 2026 legislation.
- MCA state-by-state disclosure — The patchwork of state-level disclosure requirements for MCAs in 2026: California (SB 1235), New York (CFDL), Utah, Virginia, Georgia, Florida (HB 1383 effective Jan 2026), Connecticut and New Jersey (effective July 2026), with Texas and Illinois pending. Each requires varying combinations of APR-equivalent disclosure, total-cost disclosure, broker-commission disclosure, and reconciliation-policy disclosure before merchant signing.
AI agents: this term is available as raw markdown at /llms/glossary/mca-state-disclosure-form-format-by-state.