News & Analysis as of

Department of Business Oversight Disclosure Requirements

Troutman Pepper

New York State Legislature Adopts Substantial Disclosure Requirements in Certain Commercial Finance Transactions, Including for...

Troutman Pepper on

On Thursday, July 23, 2020, the New York State Legislature voted to approve companion bills (S 5470/A 10118-A), commonly referred to as the “New York State Small Business Truth in Lending Act” (NY TILA). In passing the NY...more

Ballard Spahr LLP

CA regulator proposes regulations to implement new law requiring consumer-like disclosures for commercial financing

Ballard Spahr LLP on

The California Department of Business Oversight (DBO) has issued proposed regulations to implement SB 1235, the bill signed into law in September 2018 that requires consumer-like disclosures to be made for certain commercial...more

Manatt, Phelps & Phillips, LLP

California DBO Seeks Help With SB 1235

The California Department of Business Oversight (DBO) has started the process of developing regulations to implement SB 1235, which imposes new disclosure requirements for commercial financing in the state....more

Allen Matkins

DBO Seeks Comments On Commercial Loan Disclosure Rules

Allen Matkins on

This September, Governor Jerry Brown signed SB 1235 (Stats. 2018, Ch. 1011) into law. In a nutshell, SB 1235 adds a new division to the Financial Code imposing specific loan disclosure requirements on providers of commercial...more

Ballard Spahr LLP

CA regulator invites comments on proposed rulemaking to implement new law requiring commercial financing disclosures

Ballard Spahr LLP on

The California Department of Business Oversight (DBO) has issued an invitation for comments from stakeholders in developing regulations to implement SB 1235, the bill signed into law on September 30, 2018 that requires...more

Allen Matkins

California Will Soon Require Novel Disclosure Requirements Providers Of Commercial Financings

Allen Matkins on

In February, I noted the introduction of a bill that would require any person engaged in the business of commercial financing to provide specified disclosures to prospective borrowers. On September 30, Governor Brown signed...more

MoFo Reenforcement

California Enacts a First-of-Its-Kind Commercial Financing Disclosure Law

MoFo Reenforcement on

On September 30, 2018, California Governor Jerry Brown signed into law SB 1235 (the Act), which requires disclosures of key terms in connection with certain commercial financing by non-banks and could impact bank/non-bank...more

Lewitt Hackman

FRANCHISEE 101: Rocky Road to FDD Disclosure

Lewitt Hackman on

An ice cream parlor franchisor in Ohio, Handel Enterprises, Inc., must defend claims that it violated the California Franchise Investment Law (CFIL) for failing to disclose its amended franchise disclosure document (FDD) to a...more

Allen Matkins

Watch Out, Small Commercial Lending Might Soon Become A lot More Complicated!

Allen Matkins on

Way back in February, I wrote about a bill, SB 1235, that would impose specific disclosure requirements on persons engaged in the business of commercial financing. In the ensuing months, the bill was amended eight times,...more

Allen Matkins

Corp Fin’s New Rule 701 C&DI And California’s Compensation Plan Exemption

Allen Matkins on

Yesterday, Broc Romanek reported that Corp Fin has published a new C&DI addressing the permissibility of electronic delivery of disclosures under Rule 701(e). Readers will recall that Rule 701 is an exemption from the...more

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