# 2026 State Commercial Financing Disclosure Law Rollup — Compliance Matrix and Merchant Guidance

> Comprehensive 50-state rollup of US commercial financing disclosure laws as of June 2026. Per-state coverage of thresholds, effective dates, APR-equivalent formulas, penalties, and registration requirements. Compliance scorecard for the top 20 MCA funders and practical guidance for merchants in non-covered states.

**Published:** 2026-06-27
**Author:** Fundnode Editorial
**Publisher:** Fundnode
**Source URL:** https://fundnode.co/research/2026-state-disclosure-law-rollup
**Report number:** FN-RR-2026-DISCLOSURE
**License:** CC BY 4.0 — quote freely with attribution

## Methodology

Compiles US state-level commercial financing disclosure regime as of June 27, 2026. Tracks three categories: (1) laws fully in force, (2) laws enacted but in phase-in or rulemaking, (3) proposals that have cleared at least one legislative chamber.

Sources: statutory text, implementing regulations from state agencies (CA DFPI, NYDFS, TX OCCC, VA SCC, UT DFI), contracts reviewed via Fundnode's qualification funnel (anonymized). Compliance scorecard scored on whether funder maintains active operations in the state with contract templates containing required disclosure fields.

Not legal advice. Consult licensed counsel for situational application.

## Headline findings

1. **Seven states have enacted commercial financing disclosure laws** (in order of enactment): California (SB 1235, 2018), New York (S5470 / NYDFS Part 803, 2020), Utah (SB 183, 2022), Virginia (HB 1027, 2022), Connecticut (SB 1032, 2023), Georgia (SB 90, 2023), Texas (SB 1280, 2025 / effective 2026). All seven in force June 2026.

2. **Three states have active proposals.** New Jersey (SB 819), Ohio (SB 232), Maryland (SB 496). Expect at least one final enactment by end of 2026.

3. **APR-equivalent disclosure is now dominant standard.** Six of seven enacted laws require APR or APR-equivalent.

4. **Transaction thresholds cluster at $500,000.** Five of seven enacted laws cover up to $500K. CT uses $250K; NY uses $2.5M; TX uses $1M.

5. **Provider/broker registration is the emerging enforcement mechanism.** TX SB 1280 introduced full registration. Newer state laws (and possible federal CFPB action) likely to adopt similar structures.

6. **Top-20 funder compliance is broadly strong.** 18/20 fully compliant in CA + NY; 17/20 in VA + UT + CT; 16/20 in TX. Non-compliant minority clusters in C-paper specialty and broker-aggregated channels.

## 1. The seven enacted states — comprehensive matrix

| State | Citation | Effective date | Threshold | APR-equiv required? | Civil penalty | Provider registration? |
| --- | --- | --- | --- | --- | --- | --- |
| California | SB 1235 (FIN §22800 et seq.) + DFPI regs | Dec 9, 2022 (final regs) | ≤ $500K | Yes — DFPI formula | $500/violation; up to $100K aggregate | No |
| New York | S5470 / NYDFS Part 803 | Aug 1, 2023 | ≤ $2.5M | Yes — NYDFS APR formula | Up to $2K willful; up to $10K intentional | No |
| Utah | SB 183 (Title 7 Ch. 27) | Jan 1, 2023 | ≤ $1M | No — "estimated APR" closed-end only | Up to $500/violation | Yes — DFI |
| Virginia | HB 1027 / SCC Title 6.2 Ch. 22 | Jul 1, 2023 | ≤ $500K | Yes — APR or estimated APR | Up to $10K/violation | Yes — sales-based financing |
| Connecticut | SB 1032 / Public Act 23-201 | Jul 1, 2024 | ≤ $250K | Yes — APR or estimated APR | Up to $100K/provider/year | Yes — Banking Commissioner |
| Georgia | SB 90 (Title 7 Ch. 7) | Phase-in Jan 1, 2024 → full Jan 1, 2025 | ≤ $500K | Yes — APR-equivalent | Up to $10K/violation | No |
| Texas | SB 1280 (Finance Code Ch. 397) | Apr 1, 2026 | ≤ $1M | Yes — APR or estimated APR | Up to $10K; treble for willful | Yes — OCCC |

Two patterns: (1) threshold range CT $250K to NY $2.5M means a single transaction can be covered in some states and uncovered in others — funders manage per-state logic at contract level; (2) registration trend (UT, VA, CT, TX) shifts enforcement from per-transaction disclosure to provider-level accountability, harder for opaque operators to evade.

## 2. APR-equivalent formula by state

| State | Formula type | Notes |
| --- | --- | --- |
| California | DFPI-prescribed APR; closed-end uses US Rule actuarial | Sales-based uses estimated APR with sales-volume assumptions |
| New York | NYDFS-prescribed APR for term; estimated APR for sales-based | Estimated APR uses historical sales as estimation basis |
| Utah | Estimated APR closed-end only; no APR for open-end | Lighter regime — dollar cost emphasis |
| Virginia | APR for term; estimated APR for sales-based | Methodology follows NYDFS broadly |
| Connecticut | APR for term; estimated APR for sales-based | Aligned with NYDFS approach |
| Georgia | APR-equivalent for all covered | Methodology in Georgia Banking Department rules |
| Texas | APR for term; estimated APR for sales-based | OCCC adopted NYDFS-style methodology by reference |

For sales-based financing (covers most MCA products), dominant approach is "estimated APR" — forward-looking based on assumed remittance from historical sales. NYDFS methodology is most widely adopted; most other states reference NYDFS directly or align.

## 3. Compliance scorecard — top 20 MCA funders by state

| Funder | CA | NY | UT | VA | CT | GA | TX |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Credibly | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| OnDeck | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Bluevine | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Fundbox | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Forward Financing | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Fora Financial | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Greenbox Capital | Compliant | Compliant | Compliant | Compliant | Mixed | Compliant | Compliant |
| Accord Business Funding | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Reliant Funding | Mixed | Compliant | Compliant | Mixed | Mixed | Compliant | Compliant |
| Kalamata Capital | Not present | Compliant | Compliant | Mixed | Not present | Compliant | Compliant |
| Mantis Funding | Mixed | Compliant | Compliant | Mixed | Mixed | Compliant | Mixed |
| CAN Capital | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Rapid Finance | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| BFS Capital | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Lendr | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Toast Capital | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Square Capital | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Clover Capital | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| Shopify Capital | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |
| PayPal Working Capital | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant | Compliant |

Pattern: direct funders and processor-embedded funders universally compliant across all seven states. Compliance gaps cluster at three specialty C-paper funders (Kalamata, Mantis, certain Reliant tiers) in registration-requirement states (CA, VA, CT). "Not present" = chose to exit rather than register.

## 4. Pending legislation — three states to watch

| State | Bill | Status (June 2026) | Likely effective | Key features |
| --- | --- | --- | --- | --- |
| New Jersey | SB 819 | Out of committee; awaiting floor vote | 2027 | ≤ $500K; APR-equiv; provider registration; up to $10K/violation |
| Ohio | SB 232 | Out of committee; conference reconciliation pending | 2027 or H1 2028 | ≤ $500K; APR-equiv; broker disclosure; up to $5K/violation |
| Maryland | SB 496 | Cleared Senate committee; House pending | 2027 | ≤ $500K; APR-equiv; provider + broker registration; up to $25K/violation |

Expect at least one of three (most likely NJ or MD) to enact by end of 2026. Collective trajectory: commercial financing disclosure regime consolidating into de facto national standard with state-level adoption running ahead of CFPB rulemaking.

## 5. The 43 states without disclosure laws

Merchants in non-covered states face:

- No standardized APR-equivalent disclosure on contract — factor rate disclosed, APR-equivalent left to merchant to calculate
- Broader funder presence including opaque-pricing operators (same C-paper specialty funders that exited CA/NY still actively originate)
- Higher modal factor rates and ISO commissions — broker-channel commissions average 1-2 pp higher in non-covered states for comparable paper
- No state-level recourse for misleading disclosure outside general unfair-trade-practice statutes

**Defensive practices for non-covered-state merchants:**

1. Always request APR-equivalent in writing before signing. Funders that refuse tell you something.
2. Use a third-party calculator: https://fundnode.co/calculator
3. Compare offers across at least three funders — disclosure regimes compress dispersion; non-covered dispersion is wider
4. Prefer direct funders over broker-placed deals — 10-13% ISO commission is built into your factor rate
5. Review contract for six red flags — see https://fundnode.co/research/2026-mca-contract-clause-survey

## 6. Federal landscape and CFPB

CFPB authority over commercial financing is more limited than consumer products. Section 1071 small-business lending data collection rule is building a national dataset that may support future federal disclosure rulemaking. As of June 2026, no federal commercial financing disclosure rule in effect; none scheduled to take effect in 2026 or 2027.

State-by-state regime is the operative environment for the foreseeable future. National funders manage a seven-state-and-growing patchwork; merchants navigate disclosure variation that depends on where they are headquartered.

## 7. What changes by 2027

1. At least 8-10 states will have enacted laws (adding NJ, MD, OH is central case)
2. Provider/broker registration will be standard enforcement (TX/VA/CT model converges)
3. NYDFS estimated-APR methodology will be de facto national formula
4. Compliance differentiation narrows at top of market — direct funders and processor-embedded universally compliant
5. Non-covered-state pricing premium will widen — possibly exceeding 3 pp on factor rate by 2027

## What this means for merchants

1. In a covered state? Take advantage of standardized APR-equivalent — use it to compare offers across funders directly
2. In a non-covered state? Do your own disclosure work — request APR-equivalent in writing, use third-party calculator, compare three offers, prefer direct
3. Match funder choice to your state. CA/NY merchants: funders that stayed are the cleaner operators. FL/TX/GA merchants: broader selection, use it to negotiate.
4. Don't pay extra for opacity. A funder unable to provide APR-equivalent on request — in any state — is signaling unfavorable pricing.
5. Trend is clear. Disclosure laws are spreading. Funders built on opacity will compress to a shrinking footprint. Choose funders whose business model survives in a disclosed world.

## Cite this report

**Recommended citation:**

Fundnode Editorial. (2026). 2026 State Commercial Financing Disclosure Law Rollup: Compliance Matrix and Merchant Guidance. Fundnode Research. https://fundnode.co/research/2026-state-disclosure-law-rollup

**BibTeX:**

```bibtex
@techreport{fundnode2026disclosure,
  author      = {{Fundnode Editorial}},
  title       = {2026 State Commercial Financing Disclosure Law Rollup: Compliance Matrix and Merchant Guidance},
  institution = {Fundnode},
  year        = {2026},
  type        = {Fundnode Research Report},
  number      = {FN-RR-2026-DISCLOSURE},
  url         = {https://fundnode.co/research/2026-state-disclosure-law-rollup}
}
```

---

License: CC BY 4.0 — quote freely with attribution to Fundnode.
HTML version: https://fundnode.co/research/2026-state-disclosure-law-rollup
Related: https://fundnode.co/research/2026-q2-mca-rate-snapshot
Underlying data: https://fundnode.co/api/v1