MCA Enforcement Tracker: FTC, State AG, and TCPA Actions (2026)

Why This Tracker Exists

Every state-disclosure-law and enforcement resource found in this research is written for one of two audiences: law firms advising their own clients, or merchants who already lost money and are looking for recourse. None of it is written for the ISO, broker, or funder who is trying to stay compliant while buying leads and appointments, and protecting their own pipeline's reputation in the process. Given the FTC, state AG, and TCPA enforcement pattern documented below, that gap is a real, current risk, not a hypothetical one. This page tracks it plainly, dated and sourced, for that specific audience.

Federal Trade Commission Actions

The FTC has brought at least four dated actions against MCA operators since January 2022. In January 2022, the agency settled with two RCG Advances defendants, permanently banning them from the MCA and debt-collection industries and ordering redress to small businesses. In January 2024, a separate settlement addressed FTC Act, ROSCA, and ECOA violations tied to deceptive marketing and discriminatory lending practices. In February 2024, the agency secured a $20.3 million judgment against Jonathan Braun of RCG Advances, along with a permanent ban from the MCA industry, the largest individual FTC judgment in this record. In March 2025, a separate online cash-advance company settled for $17 million over deceptive marketing practices. Four actions in roughly three years is an active enforcement cadence, not a single historical incident.

The Yellowstone Capital Case: The Largest MCA Action on Record

The New York Attorney General sued Yellowstone Capital and its subsidiaries, filed in March 2024, alleging illegal high-interest loans disguised as merchant cash advances, with interest rates exceeding state limits and fraudulent collection practices including improper court judgments and UCC liens. The settlement scope is the largest documented in this research: approximately $1 billion in total debt relief, with $534 million in merchant debt automatically canceled. The settlement fund was reported insufficient to fully compensate every affected merchant. The claim deadline was January 9, 2026, with payments mailed by April 3, 2026.

State Disclosure Laws: The Moving Target

Eleven states now have commercial financing disclosure laws on the books: California, Connecticut, Florida, Georgia, Kansas, Louisiana, Missouri, New York, Texas, Utah, and Virginia. Two changes matter most for anyone marketing or brokering MCA right now. California's SB 362, effective January 1, 2026, adds an APR-equivalent disclosure mandate and restricts the use of "rate" and "interest" language in commercial financing offers of $500,000 or less. Texas's HB 700, effective September 1, 2025, has no de minimis exemption, and broker and provider registration is due by December 31, 2026, with OCCC enforcement of up to $10,000 per violation. Most other states carve out a five-transactions-per-12-months exemption; Louisiana and Texas do not, which is itself a shift worth tracking rather than assuming stays constant.

TCPA: The Fastest-Growing Exposure for Cold-Calling and Cold-Texting Shops

TCPA class-action litigation is not MCA-specific, but MCA cold-calling and cold-texting operations sit squarely inside its blast radius. Q1 2025 saw 507 TCPA class-action filings, up 112% year over year. By September 2025, year-to-date filings had reached 2,128, with September alone accounting for 224 filings, a 283% spike versus September 2024. Nearly 80% of all TCPA suits filed today are class actions, and the average class settlement exceeds $6.6 million. For any operation still built around volume cold-calling or cold-texting, that trend line is the single fastest-growing line item on this tracker.

The Numbers

Sources

The external data in this article draws on the sources below. Figures described in the text as estimates or industry triangulations are directional and are not attributed to a single dataset.

• FTC, press release on RCG Advances settlement (January 2022)
• Consumer Finance Insights, FTC settlement with cash-advance company (January 2024)
• FTC, press release on the Jonathan Braun judgment (February 2024)
• New York Attorney General, Yellowstone Capital settlement page
• Consumer Finance Insights, FTC $17 million settlement (March 2025)
• Alston Consumer Finance, commercial financing disclosure requirements and exemptions
• Buchalter, California SB 362 explainer
• Venable, state commercial financing disclosure laws (March 2026)
• Lexology, TCPA class actions continue to skyrocket
• Lexology, TCPA class actions spiked 283%
• ActiveProspect, TCPA lawsuits explode in 2025

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