Guide

What the FTC's cases against cash advance companies tell you

They tell you exactly which practices regulators treat as unlawful, which makes them a checklist. In February 2024 a federal court ordered merchant cash advance operator Jonathan Braun to pay $20.3 million after the FTC's first-ever jury trial. The conduct at issue is a useful description of what a bad funder looks like.

What actually happened

The FTC sued Braun and four other defendants in June 2020 over the conduct of RCG Advances, which formerly traded as Richmond Capital Group.

The allegations were that the defendants misrepresented the terms of the advances they provided, made unauthorised withdrawals from customers' accounts, and required businesses and their owners to sign confessions of judgment — then used those to obtain uncontested judgments and seize personal and business assets in circumstances customers did not expect and the contracts did not permit. The FTC also alleged unfair collection practices including threats.

In June 2022 Richmond Capital and its owner were banned from the merchant cash advance and debt collection industries, ordered to return more than $2.7 million, and ordered to vacate judgments against former customers and release liens on their property.

In October 2023 Braun was permanently banned. In February 2024, following a jury trial, the court entered judgment of $20.3 million — $3,421,067 in redress and $16,956,000 in civil penalties, the court noting the contempt he had shown to the small business owners involved.

The checklist it produces

Withdrawals you did not authorise, or amounts that do not match the agreement. Reconcile the debits against the contract in the first fortnight, not the third month.

A confession of judgment in the paperwork. It lets a funder obtain judgment without you being heard, and it is the term most associated with the conduct in these cases. Ask for it to be removed; plenty of funders will write the deal without one.

Terms described one way in the sales call and another in the agreement — particularly the amount you will actually receive against the amount financed.

Any pressure, abuse or threat in a collections conversation. It is not normal, it is not a negotiating style, and it is reportable.

What to do about it

Read the agreement before the wire, not after. The pressure to sign quickly is itself worth noticing.

Ask directly whether the agreement contains a confession of judgment and what the governing law is. Both answers are one sentence, and hesitation on either is information.

Keep every version of every document, including the offer sheet. Discrepancies between what you were shown and what you signed are the whole basis of cases like these.

If it has already happened to you, report it to the FTC. That is genuinely how these cases begin — the enforcement above came from complaints by the businesses affected.

The honest caveat

These were the worst actors, and most funders in this market are not them. Citing enforcement is not a claim that the industry is a scam; if it were, we would not be in it.

But the market is far less regulated than consumer lending, the disclosure rules are recent and patchy by state, and the difference between a reasonable funder and one of these is not visible from the advertising. It is visible in the paperwork.

That is the argument for reading the agreement and for asking who is paid what. It works on us as well as on anyone else you talk to.

Sources

Related questions.

Are merchant cash advances legal?
Yes. These cases were about how specific companies behaved — misrepresentation, unauthorised withdrawals, abusive collection — not about the product being unlawful.
Is a confession of judgment always a red flag?
Not automatically unlawful, but it is the term that features most in these cases, and New York restricted its use against out-of-state debtors in 2019. Ask for it to be removed and see what happens.
How do I report a funder?
Through reportfraud.ftc.gov, and to your state regulator. Complaints from affected businesses are what produced the enforcement described above.
How do I check a funder before signing?
Search the company name against the FTC's legal library and your state regulator, look for the legal entity name and address on the site, and ask directly who pays whom in the transaction.

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