Georgia is moving litigation finance into a licensed, trackable framework through the Nationwide Multistate Licensing System (NMLS) — the online platform states use to license and supervise non-bank financial services. The operational deadline is January 1, 2026. Whether you fund cases, run a PI practice, or provide care under liens, treat this as a preview of the baseline other states will adopt. The real work is getting your definitions, disclosures, and data organized so you can hand it to a regulator, a referring attorney, or a skeptical payor and feel confident.
I’ve long argued for self-regulation backed by market pricing. These transactions are non-recourse and should not be regulated as traditional lending. Years ago, when South Carolina explored new rules, we volunteered information by letter even though it wasn’t required. That kind of transparency is healthy. Where things go wrong is when policymakers treat non-recourse funding like a loan and impose rate caps that make longer, harder cases impossible to finance. We’ve already seen how blunt caps strain complex matters in places like California. When pricing is pushed below the risk, long-duration cases simply don’t get funded. The people who lose are patients who still need care and cannot wait years for resolution.
Operational readiness is now a competitive advantage. If you prepare properly, licensing becomes administrative rather than existential. If you don’t, you’ll struggle to answer basic questions about what you sell, what you disclose, and what your outcomes actually look like. Here’s what “ready” should mean.
• Get the Language Right
Start by mapping what you actually do. List each product you fund or accept in your practice: pre-settlement advances, medical lien financing, letter-of-protection arrangements, post-settlement funding. Label each one as recourse or non-recourse and make sure your contracts, website copy, intake scripts, and invoices match the label. Clean up anything that sounds like a loan or introduces collateral, wage assignment, or confession-of-judgment concepts. Non-recourse must mean non-recourse in plain English, not just in a footnote.
• Modernize the Disclosures
Hand a client or a referring attorney a single-page summary that makes the economics obvious. Show the funded amount, how fees accrue over time, and the total they might repay under a few realistic timelines. Skip the fine-print gotchas. If you serve non-English speakers, standardize high-quality translations. For attorneys, include a short acknowledgment section that confirms they’ll honor lien procedures and provide settlement statements that reconcile funding at the end.
• Build Regulator-Grade Data
You will need structured, exportable data that a third party can follow. At minimum, track deal ID, case type, origination date, funded amount, pricing method, expected duration, attorney of record, involved providers, and the state and county. On the outcome side, capture resolution date, gross recovery, net to client, amount repaid, and clear write-off reasons. Add an audit trail so you can see who changed what and when, and use role-based access to protect sensitive details. If your data lives in spreadsheets no one can reconcile; fix that now.
• Prepare For the NMLS Process
Assign a single owner for licensing. Collect corporate documents, financials, and background materials for key managers and owners who require disclosure. Write a concise description of your products and markets served and keep it consistent across filings. Centralize renewals and ongoing obligations in a dated tracker—owned, visible, and alert-driven. If you’re a PI firm or provider, you won’t be the NMLS filer, but you will be asked for cleaner paperwork and better case information by your funding partners; plan on it.
• Tighten Your Compliance Playbook
Create short, usable policies covering advertising, intake scripts, conflicts, data privacy, complaint handling, and adverse-event escalation. Train the intake and case-ops teams and keep a record of it. Run quarterly file reviews and document fixes. Compliance that only lives with the general counsel is compliance that fails the moment a client calls your front desk.
• Align With Attorneys and Providers
Most problems show up at intake and closing. Add a funding checkpoint at intake so clients understand terms before they sign. At closing, reconcile all liens in a standard way, and send updated payoff information early. Work with providers to standardize LOP templates, coding, and documentation so their charges stand in negotiations. Ask firms to use a simple checklist for lien notice, periodic case updates, and final distribution statements. Small but intentional process improvements here save months of friction later.
Transparency Without Killing Access
Registration, standardized disclosures, and outcome reporting are reasonable. They help weed out bad actors, give clients clearer expectations, and improve how cases are closed. But equating non-recourse funding with consumer lending is a category error. Non-recourse funding prices risk and time in a way loans do not. When rules cap returns below that risk, long cases vanish from the market. A better model is to enforce true non-recourse terms, penalize deceptive marketing, require clear disclosures, and publish aggregate outcomes. That combination protects consumers without shutting the door on people with serious injuries and long timelines.
A Simple Timeline to Hit January 1, 2026
- This quarter — Map products, scrub contract language, draft the one-page client disclosure, and define your core data fields. Assign a licensing owner and set up your renewal calendar.
- Next quarter — Finalize attorney acknowledgments and provider LOP templates, train intake and case-ops teams, and run a sample file audit to test your disclosures and data exports.
- Through 2026 — Keep quarterly reviews, update your outcomes dataset, and be ready to share high-level summaries that demonstrate responsible practices without exposing PII or trade secrets.
What Good Looks Like
If a regulator, lender, or large firm asked for a quick read on your business, you should be able to produce four things within a day:
- A clean description of your products with clear non-recourse language.
- A one-page disclosure clients actually understand.
- A data export that ties origination to outcomes without manual detective work.
- A short, current compliance packet that shows policies, training records, and findings from your last file review.
If you can’t do that, start now. Georgia’s license is not the end of the world; it’s a call to make your operations regulator-grade. Prepare once, use it everywhere, and you’ll be ready for Georgia and whatever comes next.
Informational only, not legal advice.