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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
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
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
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
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
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
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
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
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
On September 15, the Conference of State Bank Supervisors (CSBS) announced that money transmitters operating in 40 or more states will be able to take advantage of a new, comprehensive exam designed to satisfy all state money...more
The Conference of State Bank Supervisors (CSBS) recently announced plans to establish a program under which money transmitters licensed in multiple states will undergo a single comprehensive exam that seeks to satisfy all...more
As we reported, Acting Comptroller of the Currency Brian Brooks has previewed the OCC’s plans to introduce another special purpose national bank charter that would give payment companies a nationwide servicing platform and...more
A new Payments Charter could enable entities to engage in payments-related activities on a nationwide basis, rather than by state. The US Office of the Comptroller of the Currency’s (OCC) newly appointed Acting...more
The New York Department of Financial Services (DFS) has filed its opening brief with the Second Circuit in the OCC’s appeal from the district court’s final judgment in DFS’s lawsuit challenging the OCC’s issuance of special...more
Last year, we noted that the Banking Department of the Vermont Department of Financial Regulation had taken the position that its money transmission law “does not exempt a payment processor or an agent of a payee from [money...more
In this episode, Jennifer Crowder discusses the State Money Transmitter Licensing (“MTL”) Regime and the impacts of payment innovation. The episode also addresses MTL licensing exemptions, agent and authorized delegates, the...more
The FinTech and payments industries are facing unprecedented growth, rapid technological advancements, and a flood of new entrants into the market. As the FinTech landscape continues to evolve with some uncertainty,...more
The payments and money transmission regulatory landscape continues to evolve. A key new development is that Michigan has affirmed by legislation that “agent of a payee” transactions meeting certain criteria are not subject...more
As we have noted on multiple occasions, one of the most important questions in the non-bank payments revolution — at least from a regulatory perspective — is whether a particular payments service is subject to regulation as...more
Earlier this week, the Conference of State Bank Supervisors (CSBS) announced that seven states have agreed to a multi-state compact that standardizes key elements of the licensing process for money services businesses (MSB). ...more
The Conference of State Bank Supervisors issued a press release this week in which it announced the April 1 release of a new tool within the Nationwide Multistate Licensing System (NMLS) to streamline reporting by money...more
The SEC’s been floating an idea that would require mutual funds “to increase their liquidity cushions to accommodate investors looking to leave in a hurry,” but the industry’s pushing back—hard—despite the recent Third Avenue...more