State disclosure laws —
the late-2024 landscape.

The state commercial financing disclosure landscape has changed faster than most merchants realize. In 2018, exactly zero states had a disclosure law on the books. In 2022, two became operative. By the end of 2024, seven states have live regimes, and a handful more have active pending legislation. The framework is not yet federal, but it is increasingly national in practical reach.

This guide is a state-by-state snapshot as of November 2024. It is not legal advice — these regimes evolve quickly and the specifics of any given transaction depend on facts beyond the scope of any general summary. But for an operator trying to understand which state laws apply to a financing offer, this is the lay of the land.

California — SB 1235 (effective December 9, 2022)

California was the first state to pass a commercial financing disclosure law, signed in September 2018, and the third to actually go operative — December 9, 2022, after a four-year rulemaking process by the Department of Financial Protection and Innovation (DFPI).

Threshold: $500,000 or less. Covered products: MCAs, factoring, asset-based lending, term loans, lines of credit. Disclosure depth: the most prescriptive, with product-specific form variants and a required APR-equivalent methodology. Broker rules: developing. Regulator: DFPI.

Virginia — HB 1027 / SB 1027 (effective July 1, 2022)

Virginia was the first state to put a commercial financing law fully into operation, going live July 1, 2022, months before California. The framework was unusually broker-focused from day one.

Threshold: $500,000 or less. Covered products: MCAs, factoring, term loans, lines of credit. Disclosure depth: moderate. Broker rules: robust — broker registration required. Regulator: Virginia State Corporation Commission's Bureau of Financial Institutions.

Utah — SB 183 (effective January 1, 2023)

Utah took the registration-first approach, signed in March 2022 and effective January 1, 2023. The Utah Department of Financial Institutions maintains a public registry of covered providers and brokers.

Threshold: $1,000,000 or less. Covered products: MCAs, factoring, term loans, lines of credit. Disclosure depth: lighter than CA/NY; core fields required. Broker rules: registration-based. Regulator: Utah DFI.

New York — CFDL / SB 5470-B (effective August 1, 2023)

Signed in December 2020, the New York Commercial Financing Disclosure Law went operative August 1, 2023 after multiple deferred effective dates and extensive NYDFS rulemaking.

Threshold: $2,500,000 or less — the highest among the active state regimes. Covered products: MCAs, factoring, term loans, lines of credit, accounts receivable financing. Disclosure depth: high, parallel to California with some methodology differences. Broker rules: developed. Regulator: New York Department of Financial Services (NYDFS).

Missouri — HB 1397 (effective August 28, 2023, with phased provisions)

Missouri's commercial financing law was enacted in 2023 with phased operative provisions beginning August 28, 2023. The Missouri framework is somewhat less developed than the California or New York regimes but applies the same core philosophy of standardized disclosure.

Threshold: generally $500,000 or less. Covered products: MCAs, factoring, term loans, lines of credit, similar to other state regimes. Disclosure depth: moderate. Broker rules: developing. Regulator: Missouri Division of Finance.

Georgia — SB 90 (effective January 1, 2024)

Georgia became the first major Southeastern state to adopt a disclosure regime, signed May 2023 and effective January 1, 2024.

Threshold: $500,000 or less. Covered products: MCAs, AR financing, factoring, term loans, lines of credit. Disclosure depth: closely tracks California. Broker rules: separate broker disclosure obligations. Regulator: Georgia Department of Banking and Finance.

Connecticut — SB 1032 / PA 23-201 (effective July 1, 2024)

Connecticut's framework went fully operative July 1, 2024, with the lowest dollar threshold among the active state regimes.

Threshold: $250,000 or less — the lowest in the country. Covered products: MCAs, factoring, term loans, lines of credit. Disclosure depth: moderate to high. Broker rules: separate broker registration with the Connecticut Department of Banking. Regulator: Connecticut Department of Banking.

Florida and the no-state-law jurisdictions

Florida — despite being one of the largest small-business markets in the country and a center of the MCA industry — currently does not have a state-level commercial financing disclosure law on the books. Florida operators rely on federal protections (FTC Act, UDAP statutes), the CFPB's Section 1071 rule, and whatever voluntary disclosures responsible funders provide. The same is true of most other states without listed regimes.

The practical implication for a Florida merchant is that disclosure is not guaranteed by state law. A serious funder will provide one anyway; less serious counterparties may not. Asking for a clear cost breakdown — amount financed, total cost, estimated APR, payment schedule, prepayment terms — before signing any contract is a basic precaution that costs nothing.

Pending legislation as of late 2024

Several states have active or recently-active bills that could expand the state disclosure framework further. Notable pending or recently-considered legislation includes:

Illinois — has considered commercial financing disclosure legislation in recent sessions; status varies by session.

Kansas — has had bills introduced; status pending.

North Carolina — legislative interest in commercial financing disclosure has been active; specific bill status varies.

Maryland — has had bills introduced covering commercial financing disclosure and broker registration.

The status of pending bills changes frequently. By the time you read this, some may have advanced, others may have died in committee, and new ones may have been introduced. For accurate current status, check the relevant state legislature's tracker or consult counsel.

Side-by-side comparison summary

The seven active state regimes, in a single mental table you can carry around:

Lowest threshold: Connecticut ($250K). Highest threshold: New York ($2.5M). Middle thresholds: California, Virginia, Georgia, Missouri at $500K, Utah at $1M.

Most disclosure-detailed: California, followed by New York and Georgia. Most registration-focused: Utah, Virginia, and Connecticut.

Strongest broker rules: Virginia, New York, Georgia, and Connecticut, in roughly that order of historical development.

For a multi-state operator or funder, the practical compliance lift is real: seven forms, seven methodologies, seven regulators. Funders doing this seriously have invested in automated disclosure pipelines that route each offer to the correct state-specific form based on the recipient's location.

Federal context: CFPB Section 1071

Operating alongside the state disclosure laws is the federal CFPB Section 1071 rule. Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act required the Consumer Financial Protection Bureau to collect and publish data on small business lending — specifically demographic information about applicants and businesses, to enforce fair lending laws and identify business and community development needs.

The CFPB issued its final Section 1071 rule in 2023, with phased compliance dates based on a covered financial institution's small-business loan volume. The largest covered institutions began compliance in 2024; smaller institutions phase in over subsequent years.

Section 1071 is fundamentally a data collection rule. It does not require merchant-facing disclosure. It does not set caps on rates or impose substantive conduct rules on small business lending. What it does do is build a federal dataset that, over time, allows regulators, researchers, and policymakers to see who is being offered credit, on what terms, and where the gaps are. For merchants, the practical impact in 2024 is limited — your funder will be collecting some additional demographic data at application — but the long-term effect of the dataset on policy is likely to be significant.

Where the framework is heading

Three patterns are visible in the trajectory. First, more states will adopt regimes. The early movers — California, Virginia, Utah — gave later states design templates to borrow from, and the bills coming through legislatures in 2024 and 2025 generally follow one of the existing models rather than inventing new ones.

Second, the designs are converging. The most recent regimes (Georgia, Connecticut) combine disclosure depth with broker rules and registration in ways that feel like a hybrid of the California and Utah models. Expect future state laws to land in roughly the same neighborhood rather than inventing fundamentally new approaches.

Third, federal pressure may eventually catch up. Section 1071 is the first major federal commercial-finance rule in this space; if the dataset reveals patterns of concern, federal disclosure rules may follow. Whether that happens in the next two years or the next ten is uncertain.

How Goliath approaches all of this

Goliath is a direct lender. We deliver transparent cost disclosures on every offer regardless of which state the recipient operates in. Where state law specifies a form, we deliver that form. Where state law requires registration, we maintain it. Where no state law exists, we still provide a clear cost breakdown — because a merchant making a six-figure financial decision deserves to see the numbers in plain English before signing, not after. The state laws raised the industry floor. Our internal standard already required it.

This article is general information, not legal advice. Commercial finance laws evolve quickly; consult licensed counsel in your jurisdiction before making decisions based on this content.