so the ILPA that claims it shaped this law in NY , are formed by companies mainly offering business loans through chartered banks. the agreements come with language of who the bank is. the PG is also a personal guarantee not a performance guarantee. Did NYC group MCA's into loans? If it's a true split repayment from cc sales with ebb and flow repayments, this may be tough for those companies. For the ILPA, they had no choice but to follow compliance since B of I, Finwise, Web Bank etc all require this