[Jason Sterling]

We are still funding MCA credit card split deals in California. We remit via Lockbox or direct split relationship with several credit card processors.
The disclosure provision which is a huge element of the law is unenforceable when it comes to the product we sell because of variations in sales patterns creating variations in payment thus you can’t disclose what you don’t know in terms of how many payments, the amount of payments or the payment term. MCA ACH deals would have more of an issue with the law due to fixed payment arrangements. This is another advantage of using our credit card sales based product.

[abfunders]

We are still funding MCA credit card split deals in California. We remit via Lockbox or direct split relationship with several credit card processors.
The disclosure provision which is a huge element of the law is unenforceable when it comes to the product we sell because of variations in sales patterns creating variations in payment thus you can’t disclose what you don’t know in terms of how many payments, the amount of payments or the payment term. MCA ACH deals would have more of an issue with the law due to fixed payment arrangements. This is another advantage of using our credit card sales based product.

Jason, that's awesome news! Is anyone over at Fundkite be able to tell us what they think with regards to their ACH split program?

[Sean Cash]

This is not true. The whole point of the the disclosure law is your specific product to begin with, to create and disclose APRs for unknowable things. Your business model is a textbook case of what the law covers. You have 2 days now to be ready for compliance.

We are still funding MCA credit card split deals in California. We remit via Lockbox or direct split relationship with several credit card processors.
The disclosure provision which is a huge element of the law is unenforceable when it comes to the product we sell because of variations in sales patterns creating variations in payment thus you can’t disclose what you don’t know in terms of how many payments, the amount of payments or the payment term. MCA ACH deals would have more of an issue with the law due to fixed payment arrangements. This is another advantage of using our credit card sales based product.