New York MCA Final Disclosure Laws
Still in comparison to other States that enacted similar laws such as Virginia, California and Utah, the New York law goes a little further.
https://grantphillipslaw.com/n....ew-york-mca-final-di
New York MCA Final Disclosure Laws
Still in comparison to other States that enacted similar laws such as Virginia, California and Utah, the New York law goes a little further.
https://grantphillipslaw.com/n....ew-york-mca-final-di
New York Enacts APR Disclosure Laws
The new TILA-like Disclosure requirements were signed into law on December 23rd of 2020 with an original commencement date of June 21, 2021. However, since passing S.B. 5470 the New York Senate has provided additional guidance and updates (In March 2021), and included in this update is a new date for commencement of the law to begin January 1st, 2022.
https://grantphillipslaw.com/n....ew-york-enacts-apr-d
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New York Enacts APR Disclosure Laws
S.B. 5470 is a New York law requiring non-bank lenders to provide corporate borrowers specific disclosures in the loan paperwork and prior to formal consummation of the loan. The law was enacted in order to create more transparency for small business borrowers surrounding their application for credit from non-conventional banking institutes.
https://grantphillipslaw.com/n....ew-york-enacts-apr-d
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New York MCA Final Disclosure Laws
The final rules are a good start, but fall short in several areas. For example an MCA Funder is exempt from full disclosure if they are “partnered” with FDIC insured banks. Another shortfall is the inclusion of a $2,500,000 cap. Thus, commercial financing in excess of $2.5M is exempt from the CFDL. Hardly ideal.
https://grantphillipslaw.com/n....ew-york-mca-final-di
New York MCA Final Disclosure Laws
The final rules are a good start, but fall short in several areas. For example an MCA Funder is exempt from full disclosure if they are “partnered” with FDIC insured banks. Another shortfall is the inclusion of a $2,500,000 cap. Thus, commercial financing in excess of $2.5M is exempt from the CFDL. Hardly ideal.
https://grantphillipslaw.com/n....ew-york-mca-final-di
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