MCA Broker Compliance Calendar: Monthly and Annual Tasks to Stay Audit-Ready

Regulatory scrutiny of the MCA industry has never been higher. California's SB 362, New York's commercial financing disclosure law, Texas HB 700, Illinois's disclosure requirements, and Vermont HB 648 have all added real compliance obligations for anyone placing MCA deals. Most brokers know the rules exist - but knowing is different from having a system.

This guide gives you a practical, month-by-month compliance calendar you can implement immediately. Whether you run a solo operation or manage a team of ISOs, these tasks will keep you audit-ready, protect your commissions, and let you spend your time closing deals instead of scrambling when a funder or regulator comes knocking.

Why MCA Brokers Need a Compliance Calendar Now

For most of the industry's history, MCA compliance was light: keep decent records, don't make fraudulent representations, and you were largely fine. That's no longer the case.

The regulatory picture in 2026 looks meaningfully different:

• Multi-state disclosure laws require specific disclosures - including APR equivalents - before a deal closes in California, New York, Utah, Virginia, and other states, with more on the way.
• TCPA and state consumer contact laws have made cold outreach to merchants legally complex, with class-action exposure for non-compliant lead generation.
• UCC filing disputes have triggered regulatory attention in several states, with brokers sometimes drawn into funder-merchant disputes they didn't expect.
• Funder ISO audits have become more rigorous, with some funders now requiring written compliance programs before issuing preferred ISO status.

A compliance calendar isn't about fear - it's about running a professional operation that funders want to work with and that can weather regulatory changes without disrupting your pipeline. For a deeper look at how disclosure requirements work across states, see our multi-state MCA disclosure laws guide.

Monthly Compliance Tasks

These tasks should happen every month, without exception. Set a calendar reminder for the first business day of each month.

1. Review and File All Deal Documentation

Every closed deal should have a complete file that includes:

• Signed Merchant Agreement or ISO submission confirmation
• All bank statements submitted for underwriting
• Any verbal or written pre-qualification notes
• Disclosure forms provided to the merchant (required in CA, NY, TX, IL, UT, VA)
• Copy of the executed Purchase and Sale Agreement (PSA)
• Commission confirmation from the funder

Missing documentation is the most common compliance failure found in funder audits. Your goal is to be able to pull up a complete file for any deal within five minutes.

2. Reconcile Commission Statements

Verify that every commission payment matches what your ISO agreement specifies. Chargebacks and clawbacks happen - but underpayments also happen, and they're rarely corrected unless you catch them. Flag any discrepancies immediately and document your follow-up in writing.

3. Check for New or Updated Funder Programs

Funder programs change. ISO agreements get updated, buy rate tiers shift, and new stipulations get added without formal notice. Log in to each funder portal or touch base with your ISO rep to confirm nothing has changed that affects your current submissions. When adding funders to your panel, search our funder directory to compare current program terms across verified funders.

4. Review Active Merchant Accounts for ACH Issues

If you receive notifications about NSF events, ACH returns, or payment disputes on active deals, review them promptly. Merchants who reach out about payment problems need to be redirected to the funder's servicing team - but document your response to show you acted professionally and didn't ignore the issue.

Quarterly Compliance Tasks

Do these four times a year: January, April, July, and October.

1. Audit Your ISO Agreements

Pull out every active ISO agreement and review the key terms:

• Are commission rates still accurate and current?
• Have any clawback windows or conditions changed?
• Are there new prohibited conduct clauses?
• Is your contact at the funder still the ISO rep named in the agreement?

An ISO agreement you haven't read in 12 months may contain terms that no longer reflect your understanding of the relationship. See our ISO agreement key clauses guide for what to look for in these reviews.

2. Update Your Merchant Intake Forms and Disclosures

If you're placing deals in states with disclosure requirements, your intake forms need to match current law. California's SB 362 requirements include specific APR disclosure formats - you can use our MCA underwriting calculator to compute factor rate-to-APR equivalents when preparing disclosures. New York's law requires specific timing before contract signing. Check that your templates are still compliant with current state requirements, since regulations continue to be refined through rulemaking even after legislation passes.

3. Check License and Registration Status

Some states require commercial loan brokers or sales finance company brokers to register or hold a license. Confirm your business entity registration is current in every state where you actively broker deals. This matters especially if you've recently started placing deals in a new state. Our broker licensing by state guide covers requirements state by state.

4. Review Lead Generation Compliance

If you're running Google Ads, Facebook or Meta Ads, cold calling, or email campaigns, review your practices against current TCPA guidance. Consent documentation for phone and text outreach needs to be current - prior express written consent obtained under older standards may not meet 2026 requirements. See our TCPA compliance guide for MCA brokers for the specifics.

Annual Compliance Tasks

Do these once a year, ideally in January or when your fiscal year turns.

1. Review and Renew Errors and Omissions Insurance

E&O insurance isn't just optional - some funders now require it before granting preferred ISO status, and it protects you personally against claims that you misrepresented a product to a merchant. Review your coverage limits annually. If your deal volume has grown significantly, your coverage should have grown with it. Our E&O insurance guide for MCA brokers walks through what to look for in a policy.

2. Complete a Full ISO Relationship Audit

List every funder you placed business with in the past 12 months. For each one:

• Is the ISO agreement current and signed?
• Are commission rates documented in writing?
• Do you have a named ISO rep contact?
• Is the funder actively funding and in good standing?

Drop any funder you haven't used in 12 months unless you have a specific reason to maintain the relationship. Stale ISO agreements clutter your compliance picture and create confusion if an audit occurs. To discover funders worth adding to your active panel, browse our funder directory.

3. Update Your Business Entity Documents

File your annual report with your state if required. Confirm your registered agent information is current. Review your operating agreement or bylaws if you're an LLC or corporation - business relationships and ownership structures change over time and need to be reflected in governing documents.

4. Tax Compliance Review

Work with your accountant to review 1099s issued and received. Commission income, override payments, and desk fee reimbursements all have specific tax treatment. Brokers who don't track these carefully end up with their own audit exposure. Our broker tax strategy guide covers key deduction categories and year-end planning considerations.

State-Specific Disclosure Compliance: A Quick Reference

If you're placing MCA deals in any of these states, you have active disclosure obligations. This isn't a comprehensive legal guide - work with a compliance attorney for your specific situation - but here are the key deadlines and requirements to track.

California (SB 362)

Disclosures required before any commercial financing offer above $5,000. Must include an APR equivalent calculated using a specific state-prescribed formula. Failure to provide the correct disclosure before closing creates real legal exposure. Our detailed California SB 362 compliance guide covers the exact format and timing requirements.

New York

Requires disclosure of the total repayment amount, total cost of financing, and equivalent APR. Timing matters: the disclosure must be provided before the merchant is required to complete the transaction, not after. See our New York commercial financing disclosure guide for details.

Texas (HB 700)

Disclosure requirements with specific formatting standards apply to commercial financing transactions in Texas. Learn what's required in our Texas HB 700 compliance guide.

Illinois

Illinois's commercial finance disclosure law covers transactions above $500,000, making it relevant for larger deals. Details and broker obligations are covered in our Illinois disclosure law guide.

Vermont (HB 648)

Vermont's disclosure requirements apply to commercial financing of $10,000 or less - the lowest threshold of any state, which means even small deals may trigger obligations. See our Vermont HB 648 guide for what applies to brokers.

What Funders Actually Review During ISO Audits

Funder ISO audits have become more common as funders themselves face increased regulatory scrutiny. When an audit request arrives, here's what they typically review:

• Deal files: Do you have complete records for every funded deal, including the merchant's bank statements and signed agreements?
• Disclosure compliance: Were required state disclosures provided before closing, and do you have documentation to prove it?
• Merchant representation: Are your marketing materials and merchant-facing communications accurate, with no guarantees of terms you can't actually deliver?
• Lead generation practices: How are you sourcing merchants? Funders are increasingly cautious about ISO partners using non-compliant lead generation methods.
• Consent documentation: Do you have records of merchant consent for data submission and contact?

The funders running the most rigorous audits tend to be the ones offering the best programs - preferred status, lower buy rates, higher advance limits. Building a compliance program now is how you position for those relationships. Use our funder directory to identify which verified funders offer preferred ISO programs worth qualifying for.

Building Your Compliance System: Simple Tools That Work

Compliance doesn't require enterprise software. Here's what solo and small-team brokers are using effectively in 2026:

• Cloud storage (Google Drive or Dropbox): Create a folder for each deal, named with the merchant name, amount, and closing date. Store every document immediately at closing - not later.
• State disclosure checklists: For each state where you regularly close deals, maintain a one-page checklist of required disclosures and their timing requirements. Review it quarterly.
• Calendar reminders: Monthly, quarterly, and annual compliance tasks belong in your calendar as recurring events - not in a to-do list you check irregularly.
• ISO agreement tracker: A simple spreadsheet listing each funder, the signed date of your ISO agreement, your commission rates, and your primary contact name. Review it quarterly.
• E&O certificate on file: Keep a current copy of your E&O certificate in a shared folder accessible to your ISO reps. Several funders will request it when you apply for preferred status.

For MCA Brokers: The 15-Minute Weekly Compliance Check

You don't need to spend hours on compliance every week. Here's a 15-minute Friday routine that keeps you current without becoming a burden:

1. File any deals that closed this week (5 minutes): Move all documents to the appropriate deal folder. Don't let documentation pile up - it gets harder to reconstruct later.
2. Check commission payments received (3 minutes): Compare against your ISO agreement rates for any deals that funded this week. Flag discrepancies the same day.
3. Review any merchant outreach you received (2 minutes): Document any calls or emails from active merchants and redirect to funder servicing as appropriate.
4. Scan for regulatory news (5 minutes): A quick review of MCA industry sources for compliance updates. Familiarizing yourself with key terms in our MCA glossary helps you follow regulatory developments accurately.

This 15-minute habit, compounded over 52 weeks, is the difference between a broker who passes a funder audit without stress and one who scrambles when the request arrives.

When to Get a Compliance Attorney Involved

Some situations call for professional legal review, not just a checklist:

• You're expanding into a new state and aren't certain about licensing or disclosure requirements
• You receive a formal complaint from a merchant through a state agency
• A funder asks you to sign a new ISO agreement with significantly different terms or new liability provisions
• You're considering hiring W-2 employees or 1099 contractors and need employment or contractor agreements
• A merchant dispute involves legal threats or attorney letters

The cost of a compliance attorney reviewing a standard ISO agreement or disclosure template is almost always less than the cost of a compliance failure. Many attorneys who specialize in commercial finance offer flat-fee reviews for common documents.

Practical Takeaway

The MCA industry's regulatory environment has changed permanently. The brokers who thrive over the next five years will be the ones who run professional operations - clean records, current disclosures, compliant lead generation, and documented ISO relationships.

Use this compliance calendar as your starting point. Adapt it to your specific situation, the states you work in, and the funders you partner with. If you're building or expanding your funder panel, create your free broker account on MCA Directory to access verified funders with transparent program terms - the foundation for funder relationships that hold up under any audit.

Compliance isn't the interesting part of the business. But it's the part that protects everything else you've built.