Circular Payments

State Commercial Financing Disclosures

Last updated: May 2026

Circular Payments (a trade name of MFG Holdings, LLC) provides commercial financing in the form of merchant cash advances — the purchase of future receivables. These transactions are not loans. Several US states have enacted commercial financing disclosure laws that apply to our offers. This page summarizes those frameworks and describes how we comply.

How disclosures are provided

For every merchant cash advance offer we make in a state with an applicable commercial financing disclosure law, we provide a standardized written disclosure document before the merchant signs the Future Receivables Purchase Agreement (FRPA). The disclosure contains the items required by the state's law — including total funded amount, total cost of financing, term, payment amount and frequency, an estimated or stated annual percentage rate (where required), and a description of prepayment terms.

The disclosure is delivered together with the offer in the merchant's secure online portal, where it can be reviewed, saved, and printed prior to acceptance. Acceptance of the offer requires the merchant to acknowledge receipt of the disclosure.

States covered

We monitor and comply with the following state commercial financing disclosure regimes. We update this page as new state laws take effect.

California

SB 1235 — Commercial Financing Disclosures Law

Effective
December 9, 2022 (final regulations)
Threshold
Offers under $500,000

Requires providers of commercial financing offers of $500,000 or less to disclose, among other items, the total amount of funds provided, the total dollar cost of the financing, the term, the method/frequency/amount of payments, a description of prepayment policies, and an annualized rate calculated under the DFPI's prescribed formula.

New York

Commercial Finance Disclosure Law (CFDL)

Effective
August 1, 2023
Threshold
Offers under $2,500,000

Requires providers to give recipients a standardized disclosure before consummation of a commercial financing transaction. Disclosure includes the total amount of the financing, the disbursement amount, finance charge, an annual percentage rate computed under prescribed methodology, the total repayment amount, the term, payment amounts and frequency, and a description of prepayment policies.

Virginia

Sales-Based Financing Provider and Broker Registration

Effective
July 1, 2022
Threshold
Offers under $500,000

Requires sales-based financing providers (including merchant cash advance providers) and brokers to register with the State Corporation Commission and provide standardized disclosures to recipients prior to consummation of a sales-based financing transaction.

Utah

Commercial Financing Registration and Disclosure Act

Effective
January 1, 2023

Requires commercial financing providers (including sales-based and merchant cash advance providers) to register annually with the state and to provide disclosures of total dollar cost, annual percentage rate calculated under prescribed methodology, term, payment amount and frequency, and prepayment policies before consummation of a commercial financing transaction.

Connecticut

Commercial Financing Disclosure Statute (Public Act 23-201)

Effective
July 1, 2024 (registration since October 1, 2024)
Threshold
Offers under $250,000

Requires commercial financing providers and brokers to register with the Department of Banking and to provide standardized disclosures before consummation of a commercial financing transaction under $250,000. Disclosures include total amount funded, finance charge, term, an estimated annual percentage rate, and total repayment amount.

Florida

Commercial Financing Disclosure Law (SB 1380)

Effective
July 1, 2023

Requires providers of commercial financing transactions to provide disclosures before consummation, including total amount of funds provided, total dollar cost of the financing, total repayment amount, term, payment amount and frequency, and a description of prepayment policies.

Georgia

Commercial Financing Disclosure Act

Effective
January 1, 2024

Requires commercial financing providers and brokers to provide standardized written disclosures before consummation of a commercial financing transaction. Disclosures cover total amount of financing, total cost, term, payment terms, and prepayment policies.

Kansas

Commercial Financing Disclosure Law (HB 2247)

Effective
July 1, 2024

Requires providers of commercial financing transactions to make standardized disclosures before consummation. Disclosure items include total funded amount, total finance charge, term, payment amount and frequency, and prepayment terms.

Missouri

Commercial Financing Disclosure Law (SB 1359)

Effective
August 28, 2024

Requires providers of commercial financing transactions to deliver standardized written disclosures to recipients before consummation. Disclosure items mirror other state CFDL regimes (total amount, total cost, term, payment schedule, prepayment).

Other states

Several additional states are considering or have recently enacted commercial financing disclosure laws — including New Jersey, Texas, and others. We track those legislative developments and update our disclosure templates accordingly. Where a state law requires registration in addition to disclosure (Virginia, Utah, Connecticut), we maintain the required registrations.

Federal context

Commercial financing transactions in the United States are not subject to the federal Truth in Lending Act (TILA), which applies to consumer credit. State commercial financing disclosure laws are designed to provide functionally similar transparency for small business transactions. The Consumer Financial Protection Bureau (CFPB) has issued determinations that several state laws are consistent with TILA and therefore are not preempted.

Questions

If you have questions about the disclosures we provide, your specific offer, or our registration status in a particular state, please contact us:

This page is informational and is not legal advice. Specific disclosures applicable to any offer are provided with the offer itself, in writing, prior to acceptance.