The federal agency with rulemaking and enforcement authority over consumer financial products, and over small business lending data collection under Section 1071.
Its revised Section 1071 rule, issued in May 2026, excluded merchant cash advances from covered credit transactions on the reasoning that they are structured differently from traditional lending products.
Section 1071
The Dodd-Frank provision requiring lenders to collect and report demographic and pricing data on small business credit applications.
Recharacterisation
A court or regulator determining that a transaction structured as an advance was, in substance, a loan.
Commercial financing disclosure law
State legislation requiring standardised cost disclosures to a business before it signs a financing agreement.
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