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+1 (844) 360-1818  |  info@conciergefunding.com  |  📅 Schedule a Call  |  Portal

Compliance

Attorney Compliance Center

New York’s Consumer Litigation Funding Act takes effect June 17, 2026. We help your firm stay compliant, protected, and informed.

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Effective June 17, 2026: New York’s Consumer Litigation Funding Act (A804-C/S1104-A) caps all funder charges at 25% of gross recovery. Attorneys who distribute settlement proceeds in excess of that cap are in violation of the CLFA and face direct civil liability to their own client. Two steps protect your firm: (1) ask every funder to confirm they will be DFS-registered by June 17, 2026 before referring any client, and (2) require a written CLFA compliance certification and indemnification agreement from every funding company before disbursing any settlement funds.

25%

The critical number every New York attorney must know

Total charges (interest + fees combined) are capped at 25% of the plaintiff’s gross recovery — the gross settlement or judgment before any deduction for legal fees or expenses. If a funder’s payoff exceeds this cap, the attorney who distributes those funds is in violation of the CLFA and faces direct civil liability to their client. Where a client has fundings with multiple companies, the 25% cap applies to the combined total charges from all funders — not each funder individually. See Multi-Funder Considerations below. Applies to all contracts signed on or after June 17, 2026.

New York State

Consumer Litigation Funding Act (CLFA)

Signed December 19, 2025, effective June 17, 2026. New York’s first comprehensive regulatory framework for non-recourse legal funding — and a new source of liability for personal injury firms.

What the law requires of funders

  • Register with the New York Department of Financial Services (DFS) — registration opens prior to June 17, 2026
  • Cap all charges at 25% of gross recovery — interest and fees combined, calculated before legal fee deductions
  • Contracts in bold, 14-point font disclosing funded amount, fees, repayment terms, and 5-day cancellation right
  • 5-day right of rescission for the plaintiff with no penalty
  • Prohibited from influencing litigation strategy, settlement decisions, or attorney-client relationships

What it means for your firm

  • Before any referral: confirm the funder intends to register with DFS and will be registered by June 17, 2026
  • At every payoff: confirm charges do not exceed 25% of gross recovery — calculated before your fee is deducted
  • Do not distribute settlement funds to a funder whose payoff exceeds the cap — this creates direct liability to your client
  • Cap applies only to contracts signed on or after June 17, 2026 — pre-existing agreements are unaffected but remain active on your files
  • If a client has multiple funders, obtain compliant indemnification from each, with all payoff amounts disclosed to every funder
  • Maintain clear records of gross settlement, all deductions, and all payments to funders for every file

The multi-funder problem

  • When two or more funders have liens on the same file, the 25% cap applies to combined total charges from all funders
  • Each funder’s indemnification must identify and acknowledge all other payoff amounts on the file
  • Provide each funder with every other funder’s payoff figures before seeking indemnification
  • Mixed-date file (one funding pre-6/17/26, one post) creates ambiguity — awaits DFS clarification

Effective date & enforcement

  • Signed: December 19, 2025 (Governor Hochul)
  • Effective: June 17, 2026 (180 days after signing)
  • Enforced by: New York Department of Financial Services
  • Cap applies to contracts signed on or after June 17, 2026
  • Violation: distributing funds to non-compliant funder = potential client claim against attorney

Attorney liability — the risk is real

  • If a funding company recovers more than 25% of gross recovery in charges, the plaintiff can potentially sue the attorney who distributed those proceeds
  • Distributing settlement funds to an unregistered funder creates potential liability to both the client and DFS
  • The safest protection: require a signed indemnification and certification from every funder at the payoff stage — not just at initial funding

Concierge Funding — registered & CLFA compliant

Concierge Funding will be registered with New York State under the CLFA prior to the June 17, 2026 effective date. Our contracts comply with the 25% cap, include all required bold 14-point disclosures, and include the 5-day right of rescission. We provide a Payoff Compliance Certificate at settlement confirming our charges comply with the statutory cap — and we execute a full indemnification agreement protecting your firm at the time of payoff.

Jurisdiction Guide

State-by-state compliance

Obligations and risks vary significantly by jurisdiction. Use the tabs to review requirements in each state where your firm handles cases.

Comprehensive law in effect — June 17, 2026

Funder requirements

  • DFS registration — mandatory before operating as of June 17, 2026
  • 25% gross recovery cap on all charges
  • Bold, 14-point font contract disclosures
  • 5-day rescission period for plaintiffs
  • Maximum payoff disclosed at contract signing

Attorney obligations

  • Confirm funder will be DFS-registered by June 17, 2026 — verify DFS certificate of registration number once registry opens
  • Confirm payoff does not exceed 25% of gross recovery before disbursing
  • Obtain signed indemnification at payoff — not just at initial funding
  • On multi-funder files: share all payoff figures with every funder
  • Do not accept referral fees or any compensation from funders

Risks if funder is non-compliant

  • Client may sue attorney for distributing excess proceeds to funder
  • Contract may be void or voidable — settlement dispute at closing
  • DFS investigation or enforcement action
  • Malpractice exposure for failure to verify compliance

How to verify compliance

  • Request written confirmation from funder that they will be DFS-registered by June 17, 2026 — and their DFS certificate of registration number once the registry opens
  • Check DFS public funder registry (available at effective date)
  • Review funder contract for CLFA disclosures
  • At payoff: confirm charges do not exceed 25% of gross recovery
  • Require signed Indemnification & Certification Agreement at payoff
Firm Protection

Forms & indemnification library

Every form your firm needs to document compliance, verify the 25% cap, and protect against liability — available as PDF downloads.

1

Funder Compliance Certification

The funding company certifies in writing that it will be DFS-registered by June 17, 2026, its contract will meet all CLFA requirements, and its charges will comply with the 25% gross recovery cap. Signed at time of initial funding.

Download PDF →

2

Indemnification & Certification at Payoff

Required at settlement disbursement. The funder certifies the payoff complies with the 25% cap and agrees to indemnify and hold harmless your firm. On multi-funder files, this form identifies all co-funder payoff amounts so each funder certifies with full knowledge of aggregate charges.

Download PDF →

3

Attorney Referral Acknowledgment

Documents that the attorney verified funder registration, remained neutral, did not accept referral fees, and confirmed the non-recourse nature of the funding. Creates a record that your firm met its professional obligations on every referral.

Download PDF →

4

Payoff Compliance Certificate

Issued by Concierge Funding with every payoff letter. Certifies the payoff amount, the gross recovery used to calculate the cap, and confirms charges do not exceed 25%. Signed by our compliance officer. Attach to your settlement file.

Download PDF →

Red flag checklist — before referring any client to any funder

Funder cannot confirm in writing they will be DFS-registered by June 17, 2026
Contract does not show maximum payoff at signing
Charges may exceed 25% of expected gross recovery
Funder offers or implies a referral fee to your firm
No 5-day rescission right offered to plaintiff
Funder refuses to sign indemnification at payoff
Contract not in bold 14-point with required disclosures
Funder asks about case strategy or settlement offers
Multi-funder file with no aggregate cap analysis provided
Updates & Resources

CLFA guidance & attorney memos

We publish updates here as DFS issues regulatory guidance and the June 17, 2026 effective date approaches.

Jan 22
2026

NY Consumer Litigation Funding Act — Key Implications & Potential Exposure

Overview for NY personal injury practitioners. Covers the 25% gross recovery cap, DFS registration requirement, multi-funder complexity, attorney liability exposure, and recommended next steps including indemnification agreements and record-keeping.

New YorkCLFAAttorney Liability

Download PDF

Q2
2026

DFS Regulatory Guidance — Mixed-Date Files & Multi-Funder Cap Calculation

Update forthcoming as DFS issues guidance on pre/post-effective-date files and aggregate cap methodology.

Coming Soon

Ready to get started?

Schedule a call with our team or reach us directly.

+1 (844) 360-1818

info@conciergefunding.com

100 Garden City Plaza, Suite 518
Garden City NY 11530