On June 10, 2024, the Connecticut Department of Banking (“Department”) issued guidance (the “Guidance”) to give direction on required consumer-like disclosures in certain commercial financing offers.

As background on the Guidance, Connecticut’s commercial financing disclosure law, An Act Requiring Certain Disclosures, was signed into law on June 28 2023, and will become effective on July 1, 2024 (the “Statute”).… Continue Reading

New York Senator James Sanders Jr. recently proposed Senate Bill 1450A (“S1450”), which would require those making or soliciting “commercial financing products” in New York State to obtain a license and comply with specified requirements.

Section 363-A of proposed S1450 defines a “commercial financing product” as any advance of funds to a commercial or business enterprise made for the purpose of assisting the business with its capital needs. … Continue Reading