Legal
Licensing & Disclosures
What Provenance Capital is, what it isn't, and how it gets paid. Last updated: July 22, 2026.
Not yet reviewed by counsel. This page was drafted to describe how Provenance Capital actually operates, but it is not legal advice and has not been reviewed by a New York attorney. Have counsel review this page, the terms of use, and the disclosures before launch — particularly the licensing analysis and TCPA/consent language.
Provenance Capital is not a lender, a mortgage broker, or a real estate broker. We publish an informational directory of commercial mortgage lenders, and we separately introduce prospective borrowers to the capital partner covering their area. We do not originate, underwrite, fund, service, or negotiate loans, and we are not a party to any loan you obtain.
Scope of service
Provenance Capital operates an informational directory of commercial real estate capital providers serving New York City, and a separate introduction service that routes a prospective borrower's stated financing request to the one capital partner whose territory — borough, loan program, and deal size — the request fits. The partner who receives your request is not necessarily one of the lenders profiled in the directory.
Our role begins and ends with the introduction. Specifically, we do not:
- make, fund, or originate loans;
- negotiate, offer to negotiate, or attempt to negotiate the terms of any loan, on behalf of a borrower or a lender;
- solicit, process, place, or negotiate a residential mortgage loan;
- take, receive, or process a loan application, or collect application-level financial information such as Social Security numbers, credit reports, tax returns, or bank statements;
- advise you on which loan or lender to choose, or on the terms you are offered;
- hold, escrow, or handle borrower funds;
- represent any lender as its agent, or bind any lender to any rate, term, or approval.
Rates, terms, fees, and approval decisions come from the lender. Any figures shown on this site are indicative illustrations, not offers, quotes, or commitments, and are subject to change, verification, and credit approval.
Directory listings vs. capital partners
These are two different things, and we keep them separate on purpose.
Directory listings are informational
The lender profiles in our directory are editorial reference content, compiled from public and lender-published sources. A listing is nota paid advertisement, and it does not mean the lender pays us, has any relationship with us, or is the lender you'll be introduced to. We are not affiliated with, do not represent, and are not endorsed by the lenders we list unless we say so explicitly. Figures shown are indicative — confirm them directly with the lender.
Capital partners are who you're introduced to
Separately, we run a partner program. A capital partner pays a flat, recurring fee to receive borrower introductions in a territory. When you submit a request, it goes to the partner holding that territory — who may or may not appear in the directory. If we ever accept payment for a directory listing itself, we will label that listing as sponsored.
Business-purpose financing only
We accept requests for business, commercial, and investment-purpose financing only. Every borrower must affirm, before submitting a request, that the financing is not for personal, family, or household use and that the property is not and will not be their primary residence.
We do not handle owner-occupied residential mortgages, home equity lending, or any consumer-purpose mortgage. If your request is for a home you live in or intend to live in, we cannot help, and you should contact a licensed residential mortgage broker or lender.
Licensing position
New York regulates mortgage activity through two separate regimes, and our scope of service is designed to sit outside both:
Banking Law Article 12-D (NYS Department of Financial Services)
DFS registers mortgage brokers who solicit, process, place, or negotiate residential mortgage loans. Banking Law §590 defines those as loans to a natural person made primarily for personal, family, or household use, secured by one-to-four family residential real property used as a home. We accept business-purpose commercial requests only and collect an express attestation to that effect, so we do not engage in activity covered by Article 12-D.
Real Property Law Article 12-A, §440 (NYS Department of State)
New York's real estate broker definition reaches a person who, for a fee, negotiates or offers or attempts to negotiate a loan secured by a mortgage other than a residential mortgage loan — the provision that covers commercial mortgage brokerage. We do not negotiate, offer to negotiate, or attempt to negotiate any loan. We publish advertising and make introductions, we are not compensated by borrowers, and our compensation is a fixed advertising fee that varies with neither the number of introductions nor whether any loan closes.
If our activities change — if we begin negotiating terms, taking applications, or accepting compensation tied to closed loans — this analysis no longer holds and licensure would be required before doing so.
How we are compensated
Borrowers never pay us. There is no cost to submit a request, no success fee, and nothing deducted from your loan proceeds.
We are paid by our capital partners for advertising placement. A partner pays a flat, recurring fee to hold exclusive placement in a territory — a combination of borough, loan program, and deal-size band. The fee is set in advance for a fixed period.
That fee does not vary with results. Specifically, it is:
- not per-introduction — the price is the same whether we pass along two requests in a month or two hundred;
- not contingent on closing — we are paid the same whether every introduction funds or none of them do;
- not a commission — no share of points, interest, origination fees, or loan proceeds, and no payment tied to the size or terms of any loan.
We hold no interest in whether you accept any particular offer, or whether you borrow at all.
We have a financial relationship with our capital partners. When you submit a request, you are introduced to the partner holding the relevant territory — who may not be a lender shown in the directory, and is not every lender in the market. Our introduction is not a recommendation, an endorsement, or a determination that a partner offers you the best available terms. You should compare offers independently before committing.
How we contact you
Email is our default and only channel unless you say otherwise. The phone field on our form is optional. We ask separately, in an unchecked box, whether you consent to calls or texts, and that consent is never a condition of getting matched or of obtaining financing from anyone.
If you don't give that consent, we don't keep your phone number at all — it is discarded before your request is stored, so neither we nor the capital partner ever receives it. If you do consent, we record the exact wording you agreed to, and you can withdraw consent at any time by replying STOP to a text, telling the partner directly, or emailing us.
We share your request with one capital partner. That partner contacts you under its own policies, and is separately responsible for its own compliance with the Telephone Consumer Protection Act and applicable state telemarketing law.
Capital partner responsibilities
Each capital partner is an independent third party, responsible for its own licensing, registration, and regulatory compliance — including any license required to lend or broker in New York, and its own compliance with telemarketing and privacy law. We do not supervise partners' lending practices, verify their rates, or guarantee their performance. A capital partner's territory placement is paid advertising; ordinary directory listings are informational and unpaid.
No professional advice
Nothing on this site — including the loan calculators, articles, directory content, and any communication from us — is legal, tax, accounting, investment, or financial advice, and none of it should be relied on as such. The calculators are estimation tools using assumptions you supply; their output is illustrative only. Consult your own attorney, accountant, and advisors before entering into any financing.
Equal opportunity
We support the principles of the federal Fair Housing Act and the Equal Credit Opportunity Act. We do not match, route, or decline requests on the basis of race, color, religion, national origin, sex, familial status, disability, age, marital status, sexual orientation, gender identity, or any other characteristic protected by federal, New York State, or New York City law.
Operating entity
Provenance Capital is a brand operated by KUROGIRI LLC, a New York limited liability company. KUROGIRI LLCis registered with the New York Department of State (DOS ID 7648243). “Provenance Capital” is a brand and trade name; it is not a separate legal entity, and it is not a registered or licensed financial institution.
Contact
Questions about this statement? Email legal@provenancecapital.nyc. See also our terms of use and privacy policy.