Commercial Finance Disclosures

In 2018, California became the first state to pass a commercial finance disclosure law (CDL) requiring certain commercial finance companies, including factoring companies, to make consumer-style disclosures to financing recipients. After years of regulatory delay, revisions, and comment periods, the California Department of Financial Protection and Innovation released its final regulations implementing the CDL in June 2022. This short timeline, paired with a specific and complex set of regulatory requirements under the new regulation, means that compliance will require a substantial amount of time, effort, and resources for anyone entering factoring agreements with California businesses. These difficulties are compounded for factoring companies, who have to comply with additional requirements in order to determine the “APR.” Join Bradley attorneys Alex McFall and Christopher Friedman as they provide practical advice to factors about how to come into compliance with these new requirements and how other states are following California.

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