CA Consumer Financial Protection Law Mandates Annual Report

On March 15, 2026, certain providers of commercial financing must submit an annual Commercial Financing Annual Report to the California Department of Financial Protection and Innovation pursuant to the California Consumer Financial Protection Law. The reporting requirement applies to entities engaged in offering or providing commercial financing or other financial products or services to small businesses, nonprofits, or family farms whose activities are principally directed or managed from California.

The reporting obligation arises from DFPI regulations that became effective October 1, 2023. The rules apply broadly to “covered providers,” which include persons offering commercial financing or other financial products or services to covered entities, subject to limited exclusions.

The regulations specify that the annual report must include the following information for activity during the preceding calendar year:

• Provider identifying information. Name, entity type, any fictitious business names, mailing address, contact details, website, and designated contact person.
• Transaction volume and dollar amounts. Total number and total dollar amount of commercial financing transactions with covered entities, reported by type of commercial financing.
• Transaction size breakdowns. Number of transactions by specified “amount financed” ranges, reported separately for each type of commercial financing.
• Pricing metrics. Minimum, maximum, average, and median annual percentage rates disclosed for each financing type and transaction size range, where disclosures were required.

Putting It Into Practice: California’s commercial financing reporting regime underscores the state’s increasing emphasis on regulating commercial products like consumer ones (previously discussed here and here). Providers should confirm whether they qualify as covered providers or fall within an exemption, ensure internal systems can generate the required transaction and pricing data by product type, and verify DFPI portal access and internal sign-off well in advance of the March 15, 2026 deadline.