The New York Department of Financial Services has issued a proposed regulation to implement S 5470–B, which requires consumer-like disclosures for “commercial financing” transactions of $2.5 million or less.  The proposed regulation would give the provisions added by S 5470-B to the Financial Services Law the title “Commercial Finance Disclosure Law” (CFDL).  The CFDL

The California Department of Financial Protection and Innovation (DFPI) has issued an invitation for comments from interested parties on draft rules to implement certain provisions of the California Consumer Financial Protection Law (CCFPL) which became effective on January 1, 2021.  The CCFPL provisions that the draft rules would implement deal with (1) procedures for a

The California Department of Financial Protection and Innovation (DFPI) has issued second modifications to its proposed regulations to implement SB 1235, the bill signed into law on September 30, 2018 that requires consumer-like disclosures to be made for certain commercial financing products, including small business loans and merchant cash advances.

SB 1235, codified at

In our recent webinar, “The Consumerization of Small Business Lending: Significant Developments and Trends,” Ballard attorneys were joined by special guest Malini Mithal, Associate Director of the Federal Trade Commission’s Division of Financial Practices.  Mark Furletti, Co-Chair of the firm’s Consumer Financial Services Group also participated in the webinar, together with John Socknat, a partner

The California Department of Business Oversight (DBO) has issued proposed regulations to implement SB 1235, the bill signed into law in September 2018 that requires consumer-like disclosures to be made for certain commercial financing products, including small business loans, merchant cash advances, and factoring.  The law contains exemptions and carve-outs for, among other things,

It appears likely that California Governor Jerry Brown will sign a bill passed on August 31 by the state’s Senate, Senate Bill 1235, which would create consumer-style disclosure requirements for certain commercial loans and other finance products, such as merchant cash advances and factoring transactions.

Notably, the new disclosure requirements would apply to sponsors of