The Georgia MALPB: A Strategic Alternative to Traditional Sponsor Banks for Merchant Card Processing Services

Eversheds Sutherland (US) LLP
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The Georgia Merchant Acquirer Limited Purpose Bank (MALPB) offers a compelling alternative to traditional sponsor bank models by enabling payment processors to directly access card networks like Visa and Mastercard without relying on third-party financial institutions. This structure provides significant advantages, including operational simplicity, faster speed to market, and greater policy independence—allowing processors to streamline compliance and reduce friction in launching new services or adapting to network changes.

MALPBs are more narrowly scoped than traditional banks and do not engage in deposit-taking, lending, or consumer banking. This helps the parent company avoid classification as a bank holding company for purposes of the Bank Holding Company Act, which carries additional regulatory burdens and restrictions on commercial activities. The model also offers resilience -- processors can maintain continuity even if a thirdparty sponsor exits the market or shifts priorities. With Georgia’s Department of Banking and Finance providing a robust regulatory framework, and Fiserv already operational as the first MALPB in the U.S., this charter structure is poised to reshape how merchant acquirers engage with the payments ecosystem.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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