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Regulatory tracker · primary-source links

Commercial Financing & MCA Laws by State: 2026 Disclosure & Broker Tracker

Eleven states now have enacted disclosure requirements affecting covered commercial or revenue-based financing transactions. This tracker shows where the rules apply, which states require broker registration, the disclosure model used, and the 2026 deadlines brokers and business owners should know.

Last reviewed: August 18, 2026 Coverage: 11 enacted-state regimes Method: statutes + regulator materials By: Elite Funders Editorial Team
Answer first

The commercial financing law landscape in 60 seconds

The rules are not uniform. Some states require an APR-style metric, others use a total-cost model, several regulate broker conduct, and four states in this tracker require brokers to register for covered activity.

Direct answers to the questions brokers ask most
Each answer is self-contained; the full table and primary sources are below.
1
How many states are in this tracker?

11: California, Connecticut, Florida, Georgia, Kansas, Louisiana, Missouri, New York, Texas, Utah and Virginia.

2
Which states require broker registration?

Texas, Virginia, Connecticut and Missouri have broker-registration requirements for covered activity described here. Utah registers covered providers.

3
Which states use APR-style disclosures?

California and New York are the clearest APR-style regimes in this tracker. Other states generally use total-cost or sales-based financing disclosure models.

4
What is the biggest 2026 deadline?

Texas OCCC registration. Applications begin through NMLS September 1, 2026, and covered providers and brokers must register by December 31, 2026.

5
What changed in Louisiana?

Act 198 added a written disclosure requirement for revenue-based financing, effective August 1, 2025. It belongs in a current 2026 state tracker.

11
states tracked with enacted disclosure requirements
4
states in this tracker with broker-registration requirements
2
major APR-style regimes: California + New York
2027
Vermont commercial-financing provisions take effect
Freshness matters

What changed for 2026

Regulatory answers age fast. These are the changes that landed in the last twelve months, each linked to its primary source.

Jan. 1, 2026

California SB 362 became effective

California now expressly restricts deceptive use of “interest” or “rate” and requires APR to accompany certain pricing statements after a specific offer is extended.

California Legislature →
July 9, 2026

Texas CSBF rules took effect

OCCC lists the commercial sales-based financing rules as effective July 9, 2026, with registration required by December 31, 2026.

Texas OCCC rules →
Sept. 1, 2026

Texas NMLS applications open

OCCC says businesses that need a Commercial Sales-Based Finance registration can begin applying through NMLS on September 1.

Texas registration page →
Added to tracker

Louisiana Act 198

Louisiana’s revenue-based financing disclosure statute took effect August 1, 2025 and is now included as the 11th state in this 2026 tracker.

Louisiana Act text →
State-by-state comparison

Commercial financing disclosure requirements by state

Use the filters to isolate broker-registration states or disclosure models. The table is a practical summary; the source links and full statutes control.

State Law / status Core disclosure model Transaction scope Registration Primary source
California
APR-style
CFDL / Financial Code Div. 9.5; SB 362 effective Jan. 1, 2026 Amount provided, total dollar cost, term, payments, prepayment policy and annualized rate. SB 362 adds restrictions around misleading “rate”/“interest” language. Recipients presented covered offers of ≤ $500K, subject to exemptions. Disclosure statute is provider-focused; separate California Financing Law licensing questions can apply depending on activity. CA Financial Code
New York
APR-style
Commercial Finance Disclosure Law; 23 NYCRR Part 600 APR / estimated APR methodology plus itemized commercial financing disclosures. Covered commercial financing transactions up to the statutory threshold, subject to exemptions. No broker registration; NYDFS enforces. The NY Attorney General's Yellowstone case ($1.065B judgment, Jan. 2025) is the largest MCA enforcement action to date. NY DFS
Texas
Broker registration
HB 700 / Texas Finance Code Ch. 398; rules effective July 9, 2026 Total financing, disbursement, finance charge, total repayment, payment mechanics, fees and other required terms. Texas does not use California’s APR model for this regime. Covered commercial sales-based financing under Chapter 398; transaction-specific exemptions apply. Providers and brokers. OCCC registration through NMLS begins Sept. 1, 2026; required by Dec. 31, 2026. Civil penalties up to $10,000 per violation. Texas OCCC
Virginia
Broker registration
Va. Code § 6.2-2228 et seq.; effective 2022 Sales-based financing disclosures include amount, finance charge, total repayment, estimated payments and other costs. Sales-based financing to Virginia recipients; chapter excludes a single transaction over $500K and other exempt activity. Providers and brokers register with the State Corporation Commission. Virginia Code
Connecticut
Broker registration
PA 23-201; disclosures effective July 1, 2024; registration effective Oct. 1, 2024 Commercial financing / sales-based financing disclosure requirements under the Connecticut framework. Covered transactions and thresholds are defined by Connecticut law and exemptions. Providers and brokers have separate registration categories with the Department of Banking. CT DOB
Missouri
Broker registration
RSMo § 427.300 et seq.; operative framework reflected in 2025 source material Total-cost disclosure model for covered commercial financing activity. Covered commercial financing transactions, subject to statutory definitions and exemptions. Brokers register; source draft also notes a $10,000 surety bond requirement. Missouri statute
Utah
Provider registration
Utah Code Title 7, Chapter 27; effective Jan. 1, 2023 Commercial financing disclosures under Utah’s Registration and Disclosure Act. Covered commercial financing of $1M or less, subject to exemptions. Covered commercial financing providers register through Utah DFI / NMLS. Utah DFI
Florida
Total-cost model
Fla. Stat. §§ 559.961–559.9615; compliance since 2024 Commercial financing disclosures plus broker conduct restrictions, including advance-fee and misrepresentation provisions. Covered business-purpose commercial financing transactions; exemptions and provider-volume rules apply. No separate broker registration is described in this disclosure statute. Florida Legislature
Georgia
Total-cost model
O.C.G.A. § 10-1-393.18; effective 2024 Required commercial financing transaction disclosures; broker restrictions are included in the statutory framework. Covered commercial financing, subject to Georgia definitions and exemptions. No broker registration is described in the source material used for this tracker. Georgia enrolled bill
Kansas
Total-cost model
Commercial Financing Disclosure Act, SB 345; effective July 1, 2024 Funds provided/disbursed, total payments, payment mechanics and prepayment disclosures; broker conduct guardrails. Covered commercial financing transactions; exemptions in the Act apply. No broker registration requirement in SB 345; brokers are subject to conduct restrictions. Kansas Legislature
Louisiana
Added
Act 198 (HB 470), R.S. 9:3137.10; effective Aug. 1, 2025 Revenue-based financing must include a written disclosure at or before consummation: amount provided, amount disbursed when different, total amount paid, total dollar cost, payment mechanics and prepayment information. Revenue-based financing transaction as defined by R.S. 9:3137.10. The enacted section does not state a dollar threshold. No registration requirement appears in R.S. 9:3137.10 itself. Louisiana Act 198

Tracker note: “Registration” is not synonymous with every license that could apply to a financing business. This table focuses on registration obligations tied to the commercial-financing / sales-based-financing regimes summarized here.

High-impact regimes

Three states worth reading in full

These are the most useful places to go beyond the table because they capture three different regulatory patterns: registration, APR-centered disclosure, and a newer revenue-based financing disclosure statute.

Texas · registration deadline

HB 700 / Chapter 398

Texas is one of the most consequential 2026 operational changes for sales-based financing businesses because covered providers and brokers must register with OCCC.

NMLS applicationsBegin Sept. 1, 2026
Registration deadlineDec. 31, 2026
Who registersCovered providers + brokers
RegulatorTexas OCCC

Read OCCC’s current CSBF registration guidance →

California · APR context

SB 362 + Division 9.5

California’s 2026 change is best described precisely: a provider may not use “interest” or “rate” deceptively, and after a specific offer is extended, certain pricing statements must be accompanied by APR.

SB 362 effectiveJan. 1, 2026
Core metricAnnualized rate / APR
Covered offer amount≤ $500K
RegulatorCalifornia DFPI

Read SB 362 →

Louisiana · newly added to tracker

Act 198 / R.S. 9:3137.10

Louisiana’s statute specifically addresses revenue-based financing and requires one written disclosure at or before consummation of the transaction.

EffectiveAug. 1, 2025
Product focusRevenue-based financing
Disclosure timingAt or before consummation
Dollar threshold in sectionNot stated

Read enrolled HB 470 →

New York · enforcement benchmark

CFDL + the Yellowstone judgment

New York pairs APR-style disclosure rules (23 NYCRR Part 600) with the most aggressive enforcement in the country: in January 2025 the New York Attorney General obtained a $1.065 billion judgment against Yellowstone Capital, including more than $534 million in merchant debts cancelled.

DFS compliance sinceAug. 1, 2023
Core metricAPR / estimated APR
Yellowstone judgment$1.065B (Jan. 2025)
Merchant debts cancelled$534M+

Read the NY AG announcement →

For brokers & ISOs

What a commercial financing broker should review now

This is a practical checklist, not a substitute for counsel. The point is to identify the highest-risk operational questions before a file reaches the offer stage.

01

Map merchant-state exposure

Track where the recipient is located and which products you are brokering. State definitions and triggers differ, and the broker’s office location is not the only fact that matters.

02

Confirm registration obligations

Pay particular attention to Texas, Virginia, Connecticut and Missouri. Texas OCCC opens CSBF registration applications on September 1, 2026.

03

Audit pricing language

For California-covered offers, do not treat a factor rate as if it were a stand-alone substitute for the required annualized cost information. Review pages, emails, scripts and offer communications.

04

Use state-aware disclosure workflows

A single generic packet is not a compliance strategy. Product type, recipient location, transaction size and provider role can change the disclosure requirements.

Partner with a funding desk built around documented workflows

Elite Funders works with ISO and referral partners across multiple commercial financing products. The partner program gives brokers one place to submit opportunities, track activity and work through product- and state-specific requirements with the funding desk.

For business owners

What merchants should use these disclosures for

Disclosure laws are designed to make cost and payment terms easier to compare. If you receive multiple financing offers, compare the amount you actually receive, total payback or total dollar cost, payment amount and frequency, prepayment terms, and any annualized cost metric the state requires.

Useful comparison tools

Use the factor-rate-to-APR calculator to understand how a factor rate translates into an annualized cost estimate, or model payment and payback scenarios with the MCA calculator.

Watch list

Upcoming commercial-financing regulation

Not yet effective, but close enough to plan for. These stay off the 11-state count until they're live.

2027

Vermont Act 142 (H.648)

Vermont approved H.648 on June 16, 2026. The sections concerning commercial financing are scheduled to take effect July 1, 2027, so Vermont belongs on the watch list rather than in the current 11-state count.

Vermont Legislature →

Live

Texas implementation calendar

The law is already in effect, but the operational registration window is still unfolding: OCCC’s current page says NMLS applications begin September 1 and registration is required by year-end.

Texas OCCC →

Direct answers

Commercial financing law FAQs

Short, self-contained answers are useful to readers and make the page easier for search and AI systems to extract accurately.

Which states currently have commercial financing disclosure laws?
As of August 17, 2026, this tracker identifies 11 states with enacted disclosure requirements affecting covered commercial or revenue-based financing transactions: California, Connecticut, Florida, Georgia, Kansas, Louisiana, Missouri, New York, Texas, Utah and Virginia. Coverage, exemptions, thresholds and product definitions vary by state.
Which states require MCA or sales-based financing brokers to register?
Texas, Virginia, Connecticut and Missouri have broker-registration requirements for covered activity summarized in this tracker. Utah requires registration of covered commercial financing providers. Registration terminology, scope and exemptions vary, so confirm the specific activity with the state regulator and counsel.
What is the Texas HB 700 registration deadline?
The Texas Office of Consumer Credit Commissioner lists registration as required by December 31, 2026. Its current Commercial Sales-Based Finance page says businesses that need to register can begin applying through NMLS on September 1, 2026.
Does California ban factor rates?
Not in those words. California SB 362 prohibits deceptive use of “interest” or “rate.” After a provider extends a specific offer, whenever it states a charge, pricing metric or financing amount during the application process, it must also state the annual percentage rate using “annual percentage rate” or “APR.” California’s existing commercial financing disclosure law also requires an annualized cost disclosure for covered offers.
What does Louisiana require for revenue-based financing?
R.S. 9:3137.10 requires a written disclosure at or before consummation of a revenue-based financing transaction. The disclosure includes the total amount provided, the amount disbursed if different, the total amount to be paid, total dollar cost, payment mechanics and whether there are prepayment costs or discounts.
Is an MCA automatically a loan under these state laws?
No single answer applies across every law or dispute. Several state statutes expressly regulate sales-based or revenue-based financing without necessarily treating every transaction as a loan. Separately, courts may analyze whether a particular agreement functions as a true receivables purchase or a loan based on its terms and operation.
Does Elite Funders provide legal advice?
No. Elite Funders is a business funding brokerage/marketplace. This page is educational information intended to help brokers and business owners identify issues to research with the relevant regulator or qualified counsel.
Research record

Primary sources used for this update

Direct statute and regulator links make it easier to verify the summary and keep the tracker current when rules change.

Texas — OCCC Commercial Sales-Based Finance

Current registration instructions, NMLS timing and regulator guidance.

occc.texas.gov/…/commercial-sales-based-finance/
Texas — Recent & Upcoming Rules

Lists CSBF rules effective July 9, 2026 and registration due Dec. 31, 2026.

occc.texas.gov/publications/legal/rules/
California — SB 362

Official bill text covering deceptive “interest”/“rate” usage and APR re-disclosure circumstances.

leginfo.legislature.ca.gov — SB 362
California — Financial Code Division 9.5

Commercial Financing Disclosures statutory text.

California Financial Code
Louisiana — Act 198 / HB 470

Enrolled act adding R.S. 9:3137.10 for revenue-based financing transactions.

Louisiana Legislature — enrolled HB 470
Virginia — Sales-Based Financing Providers

Definitions, broker/provider registration, exemptions and disclosure requirements.

Virginia Code Chapter 22.1
Connecticut — Commercial Financing Registration

Department of Banking registration information for commercial financing providers and brokers.

Connecticut DOB
New York — Commercial Financing Regulation

NYDFS regulatory activity and 23 NYCRR Part 600 materials.

New York DFS
Utah — Commercial Financing

DFI registration and disclosure resources for Title 7, Chapter 27.

Utah DFI
Kansas — SB 345

Official bill page for the Commercial Financing Disclosure Act.

Kansas Legislature
Florida — Commercial Financing Disclosure Law

Official Florida statutes, Part XIII of Chapter 559.

Florida Legislature
New York — AG Yellowstone Judgment

January 22, 2025 press release: $1.065B judgment, $534M+ merchant debts cancelled.

ag.ny.gov — Yellowstone announcement
Vermont — H.648 / Act 142

Approved June 16, 2026; commercial-financing sections scheduled for July 1, 2027.

Vermont Legislature
Legal / editorial disclaimer: This page is educational information, not legal advice or a legal opinion. It is a high-level tracker and does not reproduce every definition, exemption, threshold, licensing rule, enforcement provision or regulatory interpretation. Laws and regulator guidance can change. Verify the controlling statute and current regulator guidance and consult qualified counsel for a specific transaction or business model.