Womble Perspectives
Welcome to Womble Perspectives, where we explore a wide range of topics from the latest legal updates to industry trends to the business of law. Our team of lawyers, professionals and occasional outside guests will take you through the most pressing issues facing businesses today and provide practical and actionable advice to help you navigate the ever-changing legal landscape. With a focus on innovation, collaboration and client service, we are committed to delivering exceptional value to our clients and to the communities we serve.
Womble Perspectives
Regulatory Clarity in Missouri: Premium Finance Loans and the CFDL
Last year, Missouri joined a growing number of states introducing CFDL legislation. These laws aim to bring consumer-style transparency to certain commercial loans, requiring lenders to disclose terms like APR, fees, and repayment schedules. But there was a wrinkle—insurance premium finance loans were left in a gray area.
Although the Senate version of the bill proposed a specific exemption for these loans, that language didn’t make it into the final omnibus bill signed into law. The result? Ambiguity for lenders and borrowers alike.
Read the full article: Insurance Premium Finance Exemption Enacted — Missouri Commercial Finance Disclosure Law
About the authors
Welcome to Womble Perspectives, where we explore a wide range of topics, from the latest legal updates to industry trends to the business of law. Our team of lawyers, professionals and occasional outside guests will take you through the most pressing issues facing businesses today and provide practical and actionable advice to help you navigate the ever changing legal landscape.
With a focus on innovation, collaboration and client service. We are committed to delivering exceptional value to our clients and to the communities we serve. And now our latest episode.
Welcome to Womble Perspectives, where today, we’re revisiting a topic that’s been evolving over the past year—Missouri’s Commercial Finance Disclosure Law, or CFDL—and a key exemption that just became law.
Let’s rewind for a moment.
Last year, Missouri joined a growing number of states introducing CFDL legislation. These laws aim to bring consumer-style transparency to certain commercial loans, requiring lenders to disclose terms like APR, fees, and repayment schedules. But there was a wrinkle—insurance premium finance loans were left in a gray area.
Although the Senate version of the bill proposed a specific exemption for these loans, that language didn’t make it into the final omnibus bill signed into law. The result? Ambiguity for lenders and borrowers alike.
Fast forward to this legislative session—and we’ve got clarity.
On July 11, 2025, Missouri Governor Mike Parson signed Senate Bill 98 and House Bill 754 into law. Both bills explicitly exempt insurance premium finance loans from the CFDL. This is a big deal for the insurance and finance industries.
So, what exactly are insurance premium finance loans?
They’re short-term, secured loans that help businesses pay for insurance coverage—whether it’s commercial, property, casualty, or liability insurance. Instead of paying the full premium upfront, businesses can finance the cost over time, freeing up capital for other needs.
These transactions are already heavily regulated in Missouri under a law that requires detailed disclosures—many of which mirror what the CFDL demands. So, applying CFDL standards on top of existing rules would have been redundant, and potentially confusing for borrowers.
The new exemption does more than just simplify compliance. It levels the playing field.
Previously, only a subset of premium finance lenders—those classified as depository institutions—were exempt from the CFDL. Now, the exemption applies across the board, ensuring consistency and fairness within the industry.
It also helps avoid conflicting regulatory obligations and inconsistent disclosures that could arise if two overlapping laws applied to the same transaction.
So, what’s the takeaway?
Missouri’s move to exempt insurance premium finance loans from the CFDL is a smart, targeted fix. It acknowledges that these loans are already well-regulated and ensures that businesses can continue to access insurance financing without unnecessary regulatory friction.
At Womble Bond Dickinson, we’re keeping a close eye on developments like this—and we’re here to help clients navigate the evolving patchwork of state-level commercial finance laws.
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