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Financial Transactions Disclosure Requirements

Mayer Brown

Missouri Regulates Providers and Brokers Under New Commercial Financing Law

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Missouri has enacted the nation’s ninth state commercial finance disclosure law, regulating the providers and brokers of certain commercial financing transactions. Signed by Governor Mike Parson on July 11, 2024, Missouri...more

Ballard Spahr LLP

Connecticut Department of Banking issues guidance on consumer-like disclosures in sales-based financing offers

Ballard Spahr LLP on

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....more

Cozen O'Connor

The State AG Report – 4.11.2024

Cozen O'Connor on

Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: •CFPB Not Playing Games with Financial and Privacy Risks - ...more

Troutman Pepper

Proposed Legislation in Louisiana Aims to Regulate Commercial Financing Transactions

Troutman Pepper on

On March 1, Senate Bill (SB) 335 was introduced, which, if passed, would impose certain requirements on “commercial financing transactions.” Recently, multiple states have enacted disclosure regulations for commercial...more

Cadwalader, Wickersham & Taft LLP

ISDA Publishes Updated General Disclosure Statement for Transactions

In 2013, the International Swaps and Derivatives Association (“ISDA”) started publishing the General Disclosure Statement for Transactions document (“General Disclosure”) with annexes containing disclosures of risks that are...more

Manatt, Phelps & Phillips, LLP

California Imposes More Regulation on Commercial Financing

After being the first state to impose disclosure requirements on small business finance transactions, California has now added an annual reporting requirement and subjected commercial finance companies to UDAAP claims. On...more

Mayer Brown

Connecticut and Florida Join the Fray, Enact Commercial Finance Disclosure Laws

Mayer Brown on

Following closely on the heels of a Georgia law enacted in May, Connecticut and Florida have become the latest states to enact laws requiring providers of small business financing to provide disclosures to recipients—and in...more

Buchalter

Florida Enacts Commercial Financing Disclosure Law, Mandatory Compliance Date January 1, 2024

Buchalter on

Florida has enacted its own Commercial Financing Disclosure Law (“CFDL”) that is similar to California and New York’s disclosure laws. The Florida CFDL applies to covered “Commercial Financing Transactions” consummated on or...more

Paul Hastings LLP

Finance Providers Need to Be Aware of New Commercial Finance Disclosure Laws

Paul Hastings LLP on

While consumer lenders have long been attuned to disclosure requirements under the Truth in Lending Act, many commercial financiers are or soon will be subject to similar state-level obligations. On June 23, 2023, Florida...more

Troutman Pepper

Connecticut Becomes Latest State to Enact a Commercial Financing Disclosure and Registration Law

Troutman Pepper on

On June 28, Connecticut Governor Ned Lamont signed into law Senate Bill 1032 entitled An Act Requiring Certain Financing Disclosures, which requires certain providers of commercial financing to make various disclosures and...more

Troutman Pepper

Florida Enacts Commercial Financing Disclosure Law

Troutman Pepper on

On June 26, Florida Governor Ron DeSantis signed the Florida Commercial Financing Disclosure Law (FCFDL). As discussed here, the FCFDL mandates that covered commercial financing companies provide consumer-like disclosures for...more

Manatt, Phelps & Phillips, LLP

Commercial Financing Disclosure Laws Continue to Spread

U.S. states continue to consider and adopt statutes requiring TILA-like disclosures in connection with various types of commercial financing transactions. Most recently, Georgia passed a law, effective January 1, 2024,...more

Troutman Pepper

Georgia Legislature Passes Commercial Disclosure Legislation

Troutman Pepper on

On April 5, the Georgia legislature sent SB 90 (Act) to Governor Kemp for signature. The Act aims to amend Chapter 1 of Title 10 of the Georgia Code to require commercial financing disclosures....more

Troutman Pepper

Missouri State Senator Reintroduces Commercial Financing Disclosure Bill

Troutman Pepper on

Last year, Missouri State Senator Justin Brown (R) introduced a bill that would have imposed certain mandatory disclosure requirements for commercial financing transactions. Ultimately, the bill failed to advance. On December...more

Cadwalader, Wickersham & Taft LLP

New York Department of Financial Services Issues Regulations Regarding Commercial Finance Disclosures

The State of New York passed a law in December 2020 – the Commercial Finance Disclosure Law (“CFDL”), with an effective date of June 2021 – that prescribed required disclosures for commercial finance transactions that are...more

Bowditch & Dewey

[Webinar] Full Disclosure – Tips, Tricks and Traps for the Unwary in Navigating Public Finance Disclosure Obligations: Part II –...

Bowditch & Dewey on

The newly-enacted Financial Data Transparency Act (FDTA) has the potential to significantly change the format currently used by issuers and conduit borrowers in submitting financial information to the Municipal Securities...more

Mayer Brown

The Suspense Is Over – NYDFS Adopts Final Commercial Financing Disclosure Rules, Announces Effective Date, and Provides New...

Mayer Brown on

Small business financers and brokers (“providers”) active in New York are officially on notice to finalize their preparations to comply with New York’s Commercial Finance Disclosure Law (“CFDL”) by August 1, 2023, the new...more

Pillsbury Winthrop Shaw Pittman LLP

California Finalizes Disclosure Requirements for Commercial Financing Transactions

The trend toward increased regulation of commercial lending continues with California’s approval of regulations requiring consumer-style disclosures for broad categories of commercial financing transactions. On June 9,...more

Locke Lord LLP

Russia-Related Sanctions Update: SEC ‎Disclosures and New U.S. Measures

Locke Lord LLP on

On May 3, 2022, the U.S. Securities and Exchange Commission (“SEC”) staff issued a sample comment letter to alert public companies to potential disclosure obligations relating to the impact of Russia’s invasion of Ukraine and...more

Keating Muething & Klekamp PLL

SEC Provides Sample Guidance on Disclosure of Russia-Ukraine Invasion

On May 2, 2022 the SEC’s Division of Corporation Finance issued a sample comment letter addressing disclosures companies should consider regarding Russia’s invasion of Ukraine. The SEC Staff believes companies should provide...more

Stikeman Elliott LLP

Disclosure Obligations Under Canadian Economic Sanctions and Anti-Terrorism Laws: A Primer

Stikeman Elliott LLP on

In this post we discuss disclosure obligations under Canadian economic sanctions and anti-terrorism laws, including in respect of financial services providers. As discussed below: There are disclosure obligations...more

Manatt, Phelps & Phillips, LLP

Utah Enacts Commercial Finance Disclosure and Registration Law

Merchant Cash Advance providers, commercial litigation funders, online SMB lending platforms and other nonbank small-business lenders, take note: Following the lead of California and New York, Utah is now the third state to...more

Manatt, Phelps & Phillips, LLP

Crypto Reporting Rules in the Biden Infrastructure Deal

The Infrastructure Investment and Jobs Act (the Act), H.R. 3684, commonly referred to as the infrastructure bill, was signed into law by President Biden on November 15, 2021. ...more

Perkins Coie

The Anti-Money Laundering Act of 2020: A Survey of Key Provisions and Practice Takeaways

Perkins Coie on

On New Year’s Day 2021, Congress overrode a presidential veto to pass the Anti-Money Laundering Act of 2020 (AMLA 2020), which amends and modernizes the Bank Secrecy Act (BSA). The AMLA 2020 includes sweeping reforms updating...more

Mayer Brown

NY Expands Coverage of Recently Enacted Commercial Financing Disclosure Law

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As expected, New York has broadened the reach of its new commercial financing disclosure law less than two months after its enactment. S.B. 5470, as previously reported by Mayer Brown, imposed a range of Truth in Lending-like...more

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