[fundingsmbs]

We have the members of the ILPA, https://innovativelending.org/, for lobbying this into existence. They have forced us all to use the same disclosure yardstick for loans and MCA's, even though it apples and oranges and likely to create more confusion than clarity.

But the NY law is very similar to California's upcoming disclosures regs. Starting this summer all CA & NY contracts will have a new disclosure page added. But it's a need driven product, so we can live with disclosure, as opposed to Maryland's proposed prohibition.

The more interesting question is how these disclosures are going to impact professional services fees? Will funders be forced to disclose separate PSF charged by ISO's? What if a ISO doesn't disclose a PSF?

call up finwise bank, web bank, bank of the internet, Green Dot Bank, etc etc. All the funders did was partner with these banks, accept their fee agreement, and, compliance, as well as contractually, these companies are no longer "the lender" in the language of the loan agreements. The bank is. They become servicing agents for these banks. Read the PGs on those contracts as well. They will come after all your assets if you default. It steers completely opposite of what an MCA stood for.