Texas HB 700 Compliance Automation — Before the Dec 31, 2026 Deadline.
Texas HB 700 is now in force, with implementing rules effective July 9, 2026, and a hard registration deadline: providers and brokers of commercial sales-based financing must register with the Texas OCCC through NMLS by December 31, 2026. It also voids confession-of-judgment provisions outright and restricts automatic ACH debits unless the provider holds a valid, perfected, first-priority security interest. This is a narrow, active compliance window, not a someday problem — and it applies to brokers, not just funders. We build the disclosure, registration-tracking, and payment-authorization workflow changes to get you compliant before the window closes.
HB 700's underlying statute took effect September 1, 2025; its implementing rules take effect July 9, 2026; and providers and brokers of commercial sales-based financing must register through NMLS by December 31, 2026 — a specific, dated compliance sequence, not an open-ended future obligation.
Texas HB 700 (89th Legislature) and OCCC implementing rules, as publicly enacted — not legal advice, and not a Scaler client result.
The registration deadline is fixed. Your process for meeting it isn't, yet.
- 01HB 700 requires both providers and brokers of commercial sales-based financing to register through NMLS by December 31, 2026 — broker registration is a distinct, easy-to-underestimate obligation, not something covered automatically by a funder's own registration.
- 02The implementing rules take effect July 9, 2026, adding a detailed compliance framework on top of the underlying statute, which means the specific operational requirements are new enough that most shops' current processes weren't built around them.
- 03Automatic ACH debits are now restricted unless the provider holds a valid, perfected, first-priority security interest — a payment-collection mechanism many shops currently rely on by default, without having confirmed their security-interest status meets the new bar.
- 04Confession-of-judgment provisions are void and unenforceable under the law — contracts and templates still relying on COJ language as a recovery mechanism in Texas transactions need to be updated, not just noted as a risk.
- 05Missing the registration deadline, continuing an ACH structure that no longer qualifies, or running Texas transactions on outdated contract language creates civil penalty exposure under a law that's specifically designed with enforcement teeth.
Live in days, not months.
Assess
We map your current Texas transaction volume, ACH/debit structure, and contract language against HB 700's actual requirements and the July 9, 2026 implementing rules.
Track
We build the registration-tracking workflow that keeps your NMLS filing status, renewal dates, and any broker-specific obligations visible and on schedule ahead of the December 31, 2026 deadline.
Update
We rebuild the disclosure and contract templates and payment-authorization logic for Texas transactions to reflect the ACH restriction and the confession-of-judgment prohibition.
Maintain
We keep the process current as the OCCC issues further guidance or amended rules, so a first-mover compliance posture doesn't quietly drift out of date.
Compliant in Texas before the deadline — and ahead of competitors still figuring this out.
- NMLS registration for both provider and broker roles tracked and on schedule, not discovered as a gap close to the deadline.
- ACH and payment-authorization structure reviewed against the new security-interest requirement, so collection mechanics don't quietly become non-compliant.
- Contract and disclosure templates updated to remove unenforceable confession-of-judgment language and reflect required disclosures.
- A documented compliance process ahead of a law most competitors are still reacting to reactively, which is itself a credibility advantage with Texas-facing funders and merchants.
- Ongoing monitoring so amended rules or OCCC guidance get incorporated as they come, instead of leaving you compliant on day one and exposed by month six.
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Book a free scoping call.
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