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MCA Disclosure Laws

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Notes & caveats

  • **Business vs. consumer**: Several federal regimes (e.g., E-SIGN, TCPA/TSR, CAN-SPAM, GLBA) do not hinge on consumer status alone; your marketing channels, data handling, and payment rails can bring you within scope even for **small-business** products. [fcc.gov](http://fcc.gov)
  • **1071 timing:** The CFPB **finalized** the extension of compliance dates on **October 2, 2025**; follow the Bureau’s 1071 page and compliance resources for the new tiered schedules (Tier 1 compliance begins July 1, 2026). [consumerfinance.gov-](https://www.consumerfinance.gov/compliance/compliance-resources/small-business-lending-resources/small-business-lending-collection-and-reporting-requirements/?utm_source=chatgpt.com)
  • **ACH specifics**: When you accept ACH from business customers, some Nacha obligations (e.g., encryption, secure channels for exception handling) still apply to **non-consumer** originators and their processors. [nacha.org](http://nacha.org)

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