Under Texas HB 700, providers and brokers of sales-based financing must register with the Office of Consumer Credit Commissioner by 31 December 2026 and renew annually. The law itself took effect in September 2025, but the registration deadline is the part with a date attached — and it applies to brokers, not only funders.
Most of the regulatory coverage in this market is aimed at funders. This one is not. Texas HB 700 names brokers explicitly, and the deadline is four months out.
The word doing the work there is "brokers". A shop that never funds a deal itself, only places files with funders, is still in scope if it is brokering sales-based financing to Texas merchants.
Texas is not alone, and this is the shift worth understanding: disclosure obligations have started to come with registration obligations attached, and registration is the one a regulator can check with a database query.
| State | What it involves |
|---|---|
| Texas | OCCC registration, deadline 31 December 2026, annual renewal |
| New York | Broker registration alongside its disclosure regime |
| California | Registration, plus annual provider reporting due 15 March |
| Virginia | Registration alongside disclosure |
| Utah | Registration alongside disclosure |
| Georgia | Registration alongside disclosure |
| Florida | Registration alongside disclosure |
Requirements differ in scope and in who exactly is captured, so the table is a prompt to check rather than an answer. If you place files in any of these states, the question "am I registered there" now has a factual answer that somebody else can look up.
As of August 2026, ten states require commercial financing disclosures: California, Connecticut, Florida, Georgia, Kansas, Missouri, New York, Texas, Utah and Virginia.
California’s SB 362 took effect at the start of 2026 and tightened the rules noticeably for brokers who discuss pricing with merchants directly — which is most brokers.
Disclosure rules on their own move slowly. What moved the industry was the enforcement that arrived alongside them.
The Yellowstone action cancelled more than $534 million owed by over 18,000 small businesses and permanently barred the company from the industry. The state’s case was that the advances were disguised loans, with rates reaching as high as 820%.
Figures as reported by the New York Attorney General’s office.
The through-line in both actions is recharacterisation: courts and regulators treating an advance as a loan, which brings usury caps, licensing requirements and a very different set of consequences into play.
Effective 17 February 2026, New York extended its unfair-and-abusive-practices protections to small businesses and non-profits, not only individual consumers.
In practice that widens what the Attorney General can examine — collection conduct, demand letters, and UCC-1 filing practices among them. For a broker the relevant question is less about your own collections, which you probably do not run, and more about which funders you place files with and how they behave afterwards.
Yes. Under Texas HB 700, providers and brokers of sales-based financing must register with the Office of Consumer Credit Commissioner by 31 December 2026, with annual renewal thereafter. The requirement names brokers explicitly, so a shop that only places files rather than funding them is still in scope for Texas merchants.
As of August 2026, Texas, New York, California, Virginia, Utah, Georgia and Florida have broker or provider registration requirements attached to their commercial financing regimes. Scope and definitions differ by state, so confirm your own position for each state you place files in.
Ten as of August 2026: California, Connecticut, Florida, Georgia, Kansas, Missouri, New York, Texas, Utah and Virginia. Some industry sources say eleven and include New Jersey, but the New Jersey bill has not been enacted and remains proposed.
In 2025 the New York Attorney General announced a $1.065 billion judgment and settlement against Yellowstone Capital, on the basis that its advances were disguised loans carrying rates as high as 820%. It cancelled more than $534 million owed by over 18,000 small businesses and permanently barred the company from the industry.
Effective 17 February 2026, it extends New York’s unfair-and-abusive-practices protections to small businesses and non-profits rather than only individual consumers. It widens what the Attorney General can scrutinise, including collection conduct, demand letters and UCC-1 filing practices.
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