News & Analysis as of

Banking Sector Money Transmitter

Wilson Sonsini Goodrich & Rosati

Association of State Financial Regulators Issues Guidance on Virtual Currency for Licensed Money Transmitters

Recognizing the evolving landscape of digital finance, the Conference of State Bank Supervisors (CSBS), an association of state financial regulators, issued advisory guidance on the treatment of virtual currency held on a...more

Troutman Pepper Locke

CSBS Issues Guidance on Virtual Currency and Tangible Net Worth

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On June 26, the Conference of State Bank Supervisors (CSBS) released new guidance regarding the treatment of virtual currency in the calculation of a licensee’s tangible net worth under the Money Transmission Modernization...more

Orrick, Herrington & Sutcliffe LLP

State bank supervision group releases money transmission guidance

Recently, an association of state bank supervisors issued new guidance to clarify how money transmitters must calculate tangible net worth under the model legislation known as the Money Transmission Modernization Act (MTMA),...more

Sheppard Mullin Richter & Hampton LLP

Colorado Overhauls Money Transmission Law to Align with Multistate Licensing Standards 

On April 16, the Colorado General Assembly enacted House Bill 25-1201, replacing the state’s prior money transmitter law with the Money Transmission Modernization Act (the “Act”). Modeled on the multistate framework developed...more

Paul Hastings LLP

State-Level Developments: The Regulatory Landscape for Digital Assets

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As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more

Orrick, Herrington & Sutcliffe LLP

Connecticut Banking Commissioner suspends bitcoin-ATM operator’s money transmitter license

On October 25, the Connecticut Banking Commissioner has suspended a money transmitter’s license, citing several issues: inadequate KYC policies, multiple consumer complaints about fraudulent activity, and insufficient capital...more

McGlinchey Stafford

Podcast: Deep Dive into Understanding Bank Partnerships in Payment Programs [More with McGlinchey, Ep. 73]

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In this latest installment of McGlinchey’s Deep Dive into Bank Partnerships Series, attorneys Amy Greenwood-Field, Aaron Kouhoupt, and David Tallman explore the complexities of payment programs involving partnerships between...more

Troutman Pepper Locke

2024 State Legislative Review: Key Payment Laws and Their Impacts — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, host Keith Barnett reviews state legislative actions in 2024 related to payments, focusing on the Money Transmission Modernization Act (MTMA), earned wage access (EWA), and peer-to-peer...more

Cooley LLP

US States Adopt Model Money Transmission Act, but Harmonization Remains Elusive

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So far in 2024, nine states1 – Maryland, South Dakota, Wisconsin, Kansas, Maine, Vermont, South Carolina, Missouri and Connecticut – have passed legislation or enacted regulations based, to varying degrees, on the Model Money...more

Orrick, Herrington & Sutcliffe LLP

MSB Call Report updates effective for Q3 reporting

Recently, NMLS announced updates to the Money Services Business (MSB) Call Report effective in the third quarter for filings due November 14. These updates aim to align the report with the Model Money Transmission...more

Orrick, Herrington & Sutcliffe LLP

Missouri updates its money transmission statute in new act

On July 11, the Governor of Missouri signed into law SB 1359 (the “Act”) to modify provisions relating to financial institutions. The Act included the Money Transmission Modernization Act of 2024, which was intended to help...more

Hudson Cook, LLP

"OVER THE LINE!"  Where Banking and Gaming Intersect, the CFPB Has Something to Say.

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The line between virtual and reality is getting thinner. Gamers pay gaming companies real currency for virtual in-game currency to buy skins, create the world they want to live in (virtually), or purchase loot that aid in...more

Orrick, Herrington & Sutcliffe LLP

Iowa enacts new money transmission provisions

On April 10, Iowa’s governor signed into law HF 2262 (the “Act”) relating to money transmission services. The Act will exempt a person appointed as an agent of a payor for purposes of providing payroll processing services...more

Stinson LLP

Wisconsin Adopts Model Money Transmission Modernization Act, Joining 19 Other States

Stinson LLP on

On April 4, 2024, the State of Wisconsin enacted S.B. 668 (the Act), repealing the state’s existing Seller of Checks Act, which solely regulated money transmitters with a physical presence in Wisconsin, and replacing the...more

American Conference Institute (ACI)

[Event] 8th Forum on FinTech & Emerging Payment Systems - April 9th - 10th, New York, NY

ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more

Alston & Bird

New Indiana Money Transmission License Requirements Impact Business Purpose Activities

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A&B Abstract: On May 4, 2023, Governor Holcomb signed SEA 458, the Model Money Transmission Modernization Act (the “MTMA”), into law in Indiana. The MTMA repeals and replaces Indiana’s existing law on money transmitters and,...more

McGlinchey Stafford

Video: Introduction: A Deep Dive into Payments

McGlinchey Stafford on

The world of payments has grown exponentially in recent years. The Consumer Financial Protection Bureau (CFPB) has continued its activity around Unfair or Deceptive Acts or Practices (UDAP), fees, and what the CFPB calls dark...more

Orrick, Herrington & Sutcliffe LLP

Indiana enacts Money Transmission Modernization Act

On May 4, the Indiana governor signed SB 458, which repeals current Indiana code governing the licensing and regulation of money transmitters by the Department of Financial Institutions. The bill adds a new chapter codifying...more

Orrick, Herrington & Sutcliffe LLP

Tennessee enacts Money Transmission Modernization Act

On April 4, the Tennessee governor signed HB 316 / SB 268 to enact the Money Transmission Modernization Act, the money transmitter model law created by industry and state experts. Provisions under the Act amend Tennessee Code...more

McDermott Will & Emery

Montana Pump Fakes a Requirement for Money Transmitters

Against a backdrop of near-daily enforcement actions and constant regulatory changes, Montana inched into the fray by publishing a letter calling on money transmitters to make a submission to the Montana Department of Banking...more

Venable LLP

FBO Accounts: What Banks and Fintechs Need to Know

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One of the biggest challenges for fintechs is ensuring that their services comply with federal and state money transmission laws. For example, a fintech operating as a payment facilitator faces significant money transmission...more

Troutman Pepper Locke

A Conversation with Third Party Payment Processors Association President Marsha Jones - The Crypto Exchange Podcast

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In this episode of The Crypto Exchange, Troutman Pepper attorneys Keith Barnett and Carlin McCrory welcome Marsha Jones from the Third Party Payment Processors Association to discuss a portion the ENABLERS Act, which proposes...more

Ballard Spahr LLP

Connecticut Department of Banking Issues Advisory on Money Transmission

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On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. ...more

Ballard Spahr LLP

Connecticut Department of Banking issues consumer and industry advisory on money transmission

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On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. ...more

Cooley LLP

Arizona Embraces CSBS Model Money Transmission Law; West Virginia Incorporates Some Key Provisions

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On May 20, 2022, Arizona Gov. Doug Ducey signed Senate Bill 1580, which effectively replaces Arizona’s current money transmission law with the Model Money Transmission Modernization Act (the Model Act) announced by the...more

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