A commercial financing disclosure law requires providers of business loans, merchant cash advances, and similar sales-based financing to give recipients written, consumer-style disclosures — typically total cost, payment terms, and (in most but not all states) an APR-equivalent rate — before the transaction is finalized. These laws exist because merchant cash advances are structured as a purchase of future receivables, not a loan, so they fall outside the federal Truth in Lending Act (TILA). States have stepped in individually to fill that gap, and each has written its own rules — there is no single federal standard.
The Compliance Matrix
Verified against each state's actual statutory text and primary legal-analysis sources, not secondary summaries. Full citations and sources are listed in the methodology section below.
| State | Statute | Effective | Threshold | APR Required? | Registration |
|---|---|---|---|---|---|
| California | SB 1235 — Cal. Fin. Code §22800 et seq. | Dec 9, 2022 | ≤$500,000 | Yes (estimated APR) | No new registration under this law |
| New York | CFDL — NY Fin. Serv. Law Art. 8 | Aug 1, 2023 | ≤$2,500,000 | Yes (APR + finance charge) | No new registration under this law |
| Utah | SB 183 — Utah Code §7-27-101 et seq. | Jan 1, 2023 | Not capped by dollar amount | Yes (cost of capital) | Yes — provider registration |
| Virginia | HB 1027 — Va. Code §6.2-2228 et seq. | Jul 1, 2022 | ≤$500,000 | No — explicitly not required | Yes — SCC registration |
| Georgia | SB 90 — O.C.G.A. §10-1-393.18 et seq. | Jan 1, 2024 | ≤$500,000 | Yes (estimated APR) | No |
| Florida | HB 1353 — Fla. Stat. §559.961 et seq. | Jul 1, 2023 (transactions from Jan 1, 2024) | ≤$500,000 | Yes (total cost of capital) | No |
| Texas | HB 700 — Tex. Fin. Code Ch. 398 | Sep 1, 2025 (registration by Dec 31, 2026) | <$1,000,000 | Yes (finance charge, total repayment) | Yes — OCCC registration |
| Connecticut | Public Act 23-201 (SB 1032) | Jul 1, 2024 | ≤$250,000 | No — explicitly not required | Yes — DOB registration |
| Missouri | SB 1359 — Mo. Rev. Stat. §427.300 | Feb 28, 2025 | Not capped by dollar amount | Yes (total cost disclosure) | Yes — broker registration + $10,000 bond |
Also enacted, not detailed in the matrix above: Kansas (SB 345, effective July 1, 2024, ≤$500,000 threshold) and Louisiana (HB 470, effective August 1, 2025, no dollar threshold). Most other states have not enacted a commercial financing-specific disclosure statute as of this writing — general consumer protection, usury, and UCC filing law still applies everywhere regardless.
State-by-State Detail
California — SB 1235
The original commercial financing disclosure law, signed in 2018; final DFPI regulations took effect December 9, 2022. Requires a column-by-column, TILA-style disclosure box with estimated APR, total cost, and payment schedule for financing of $500,000 or less. The first state to require this and the most heavily litigated/analyzed of the group.
New York — Commercial Finance Disclosure Law (CFDL)
Effective August 1, 2023, with the highest threshold of any enacted state ($2.5 million). Requires TILA/Reg Z-style terms: Amount Financed, Annual Percentage Rate, and Finance Charge. Providers and brokers must retain disclosure records for at least 4 years.
Utah — Commercial Financing Registration and Disclosure Act (SB 183)
Effective January 1, 2023. Distinctively pairs disclosure requirements with an actual provider registration obligation with the Utah Department of Financial Institutions — most states with disclosure laws do not require registration at all.
Virginia — Sales-Based Financing Providers Law (HB 1027)
Effective July 1, 2022. Targets "sales-based financing" specifically (MCA and revenue-share products) under $500,000. Requires disclosure of total financing amount, finance charge, and total repayment amount — notably does not require APR disclosure, unlike California, New York, Georgia, and Florida. Both providers and brokers must register with the Virginia State Corporation Commission.
Georgia — SB 90
Signed May 1, 2023; applies to transactions consummated on or after January 1, 2024, for financing of $500,000 or less. Codified within Georgia's Fair Business Practices Act, requiring providers with more than 5 Georgia transactions/year to disclose estimated APR and cost of capital.
Florida — Commercial Financing Disclosure Law (HB 1353)
Law effective July 1, 2023; applies to transactions consummated on or after January 1, 2024. Covers loans, open-end credit, and accounts receivable purchases of $500,000 or less. Exempts banks, licensed money transmitters, and real-estate-secured loans. Enforced exclusively by the Florida Attorney General.
Texas — Commercial Sales-Based Financing Law (HB 700)
Signed June 20, 2025; disclosure requirements effective September 1, 2025, for sales-based financing under $1 million. The most recently enacted of the nine. Provider and broker registration with the Texas Office of Consumer Credit Commissioner is required by December 31, 2026 — currently the newest registration deadline on this list.
Connecticut — Public Act 23-201
Effective July 1, 2024 (regulator granted a no-enforcement grace period through October 1, 2024), for sales-based financing of $250,000 or less — the lowest threshold of any enacted state. Like Virginia, does not require APR disclosure. Providers must register annually with the Connecticut Department of Banking.
Missouri — Commercial Financing Disclosure Law (SB 1359)
Effective February 28, 2025, after the state's Division of Finance did not issue implementing regulations within the statute's conditional window. Requires broker registration with the Missouri Division of Finance and a $10,000 surety bond — a distinctive requirement not seen in most other enacted states.
Why These Laws Differ So Much
There is no federal template for commercial financing disclosure — each state legislature wrote its own bill, often modeled loosely on California's or New York's, but with meaningful differences:
- Dollar thresholds vary by 10x — from Connecticut's $250,000 to New York's $2.5 million. A transaction exempt in one state may be fully covered in another.
- Not all require APR — Virginia and Connecticut deliberately excluded an APR-equivalent requirement, focusing instead on total cost and payment terms.
- Registration is inconsistent — Utah, Virginia, Texas, Connecticut, and Missouri require provider or broker registration; California, New York, Georgia, and Florida do not add a new registration scheme.
- Enactment is ongoing — nine states in four years (2022-2025), with more states introducing similar bills each legislative session. This list will need updating; treat any "complete" state disclosure list, including this one, as a snapshot, not a permanent fact.
How T.A.G. Approaches Compliance
T.A.G. Business Funding is a commercial capital broker (ISO) — not a direct lender, and generally not the party required to register as a "provider" under most of these statutes; that obligation typically falls on the funding source itself. We work with a network of funding partners and require compliance with the disclosure and registration rules applicable in a merchant's state as a condition of the referral relationship. This page is provided for informational purposes and is not legal advice — commercial financing law changes; confirm current requirements with a qualified attorney or the relevant state regulator before relying on any specific figure here.
→ For the underlying MCA structure and cost math these disclosures describe, see what is a merchant cash advance and the factor rate to APR calculator.
Frequently Asked Questions
Which states require commercial financing disclosure for merchant cash advances?
As of 2026, nine states have enacted commercial financing disclosure laws that apply to merchant cash advances and similar sales-based financing: California (SB 1235), New York (CFDL), Utah (SB 183), Virginia (HB 1027), Georgia (SB 90), Florida (HB 1353), Texas (HB 700), Connecticut (Public Act 23-201), and Missouri (SB 1359). Kansas (SB 345) and Louisiana (HB 470) have also enacted similar laws. Most other states have not enacted commercial financing-specific disclosure statutes, though general consumer protection and UCC filing law still applies everywhere.
Do all these states require APR disclosure?
No. California, New York, Georgia, and Florida require an APR-equivalent or estimated cost-of-capital disclosure. Virginia and Connecticut explicitly do NOT require APR disclosure -- both states require total cost and payment-term disclosure instead. This is a meaningful, deliberate difference between these states' laws, not an oversight.
Is T.A.G. registered or licensed under these state laws?
T.A.G. Business Funding is a commercial capital broker (ISO), not a direct lender or a party required to register as a "provider" under most of these statutes -- that obligation generally falls on the funding source itself. T.A.G. works with a network of funding partners and requires compliance with disclosure and registration rules applicable in the merchant's state as a condition of the referral relationship.
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