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New York Commercial Financing Disclosure Law: What MCA Funders Must Disclose

New York's commercial financing disclosure law in plain English — what's required, who's covered, and the operational changes for ISOs.

Owner Leads Direct Editorial•February 28, 2026•9 min

New York's commercial financing disclosure law went into effect in 2024 with a multi-year ramp of regulatory clarifications. By 2026, it's the most consequential state-level regulation in MCA. Every funder doing business with NY merchants — and every ISO submitting NY paper — needs to understand the rules.

Who's covered

The law applies to commercial financing offers of $2.5 million or less extended to recipients located in New York. It covers MCA, factoring, sales-based financing, and traditional commercial loans. Banks and certain other lenders are exempt.

What must be disclosed

At the time a specific offer is extended, the provider must disclose, in a standardized format:

  • ▸Total amount of financing
  • ▸Disbursement amount (after fees)
  • ▸Finance charge
  • ▸Annual percentage rate (APR)
  • ▸Total repayment amount
  • ▸Term
  • ▸Payment amounts and frequency
  • ▸Description of any prepayment policies
  • ▸Description of collateral requirements

The APR question

MCA is structured as a purchase of future receivables, not a loan, and historically resisted APR disclosure. New York's rule requires APR calculation using a defined methodology. Many funders comply by disclosing an estimated APR with assumptions about the merchant's revenue pattern.

For brokers, this means the APR on a typical MCA — when calculated under the NY methodology — often appears in triple digits. Be ready for that conversation with the merchant.

ISO operational impact

  • ▸Use only funder-approved disclosure documents at offer time
  • ▸Don't quote rates verbally before disclosure has been delivered
  • ▸Document delivery timing — disclosure must precede the merchant's signing
  • ▸Train your team on the APR conversation — it will come up

Other states with similar laws

California (SB 1235), Virginia, Utah, Connecticut, Georgia, and Florida have all passed or proposed similar disclosure laws. The rules differ in specifics. If you're funding multi-state, you need to know each one.

// About this article
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Owner Leads Direct Editorial Team
Editorial & Research
Published February 28, 2026

The Owner Leads Direct Editorial & Research team writes, reviews and maintains every public page on this site. Drafts are produced collaboratively (including AI-assisted drafting) and reviewed by a human editor with relevant subject-matter experience in MCA, commercial lending, B2B data or compliance before publication. Every quantitative claim is cited to a primary source or labeled as internal Owner Leads Direct data. We publish corrections within 72 hours of a verified report.

Merchant cash advance underwriting and pricingB2B owner contact data sourcing and verificationTCPA, CCPA/CPRA and AI-agent disclosure rulesLead-buyer economics (CPL, CAC, LTV, factor rates, ACH holdback)
Reviewed byOwner Leads Direct Compliance Team — Compliance & Legal
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