On October 20, 2021, the New York Department of Financial Services (NYDFS) issued proposed rules under New York’s Commercial Financing Disclosure Law (CFDL). The CFDL will be effective January 1, 2022 and mandates consumer type disclosures for certain types of commercial financings up to $2.5M, as follows: (i) sales-based financing; (ii) closed-end financing; (iii) open-end financing; (iv) factoring transaction financing; (v) lease financing; and (vi) general asset-based financing. The comment period for the proposed regulations will end on December 19, 2021.