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Money Transmission Licensing

The Money Transmission Modernization Act

The Model Money Transmission Modernization Act is the CSBS model law rewriting how states license money transmitters: shared definitions, shared prudential standards, and coordinated multistate exams. Here is what it changes, and what it deliberately does not.

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Reviewed by Cornerstone Staff28 years of financial services state licensing experienceLast verified August 6, 2026

Money Transmission Licensing

What is the Money Transmission Modernization Act?

The Money Transmission Modernization Act, formally the Model Money Transmission Modernization Act (MTMA) and sometimes called the Money Transmitter Model Law, is model legislation finalized by the Conference of State Bank Supervisors in 2021 that states enact to standardize money transmitter licensing. It replaces each state's homegrown statute with common definitions of money transmission, common exemptions, uniform net worth, surety bond, and permissible investments standards, and a framework for coordinated multistate licensing and examination through NMLS. It is not federal law: each state enacts it on its own, states adopt it in whole or in part, and a transmitter still generally needs a separate license in every state where its customers live.

Is the Money Transmission Modernization Act a Federal Law?
No. It is model legislation drafted by the Conference of State Bank Supervisors that individual state legislatures choose to enact. There is still no federal money transmitter license: the license remains state-by-state, and the model law standardizes the state statutes rather than replacing them.
What Is the Difference Between the MTMA and the MMLA?
Nothing substantive: both abbreviations refer to the CSBS Model Money Transmission Modernization Act, which is also called the Money Transmitter Model Law. Different states, firms, and articles abbreviate it differently. What matters legally is the version a particular state enacted, since states adopt the model in whole or in part.

Money transmitter licensing by the numbers

US jurisdictions require a money transmitter license
51 of 52 US jurisdictions require a money transmitter license Source: state regulator statutes compiled in our state-law index, verified August 2026. Money transmitter license state laws
statutory surety bond range across licensing states
$10,000 to $1,000,000 statutory surety bond range across licensing states Source: state regulator statutes compiled in our state-law index, verified August 2026. Money transmitter license state laws

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One Model Law, State-by-State Adoption

For decades, every state wrote its own money transmission statute, and the differences, not the requirements themselves, were the expensive part of nationwide licensing. The Model Money Transmission Modernization Act, drafted by the Conference of State Bank Supervisors (CSBS) with state regulators and industry and finalized in 2021, gives legislatures a common statute to enact: one set of definitions and exemptions, one net worth and permissible investments framework, and common standards for control, reporting, and examination. States have been enacting it in whole or in part since 2021, and a substantial share of states now operate under it. It is a model, though, so what is actually law in any state is that state's enacted version.

What the Model Law Standardizes

The MTMA's core bet is that most of the cost in multistate licensing came from inconsistency, so it standardizes the parts of the statute that used to vary state by state.

Definitions and exemptions

A common definition of money transmission, payroll processing, and stored value, and a common exemption list, including an agent-of-payee exemption, so the same business model gets classified the same way across adopting states.

Prudential standards

A uniform tangible net worth formula tied to total assets, standardized surety bond provisions, and a common permissible investments regime held against outstanding transmission obligations.

Control and change-of-control

Common definitions of who counts as a person in control and uniform procedures for approving acquisitions and new control persons, one of the most friction-heavy events for a licensed transmitter.

Coordinated supervision

Express authority for multistate licensing processes and joint examinations through NMLS, so one coordinated exam can stand in for many separate state exams.

Virtual currency coverage

An optional virtual currency article that adopting states can include, bringing digital asset transmission under the same framework instead of a separate regime.

What MMLA Adoption Changes for a Licensee

The same model law travels under several names: the Model Money Transmission Modernization Act, the MTMA, the MMLA, and the Money Transmitter Model Law all refer to the CSBS model. Whatever a state calls its bill, adoption changes practical things for companies licensed there.

Classification gets more predictable: a flow of funds analyzed under MTMA definitions in one adopting state lands the same way in the next, which shrinks the legal work of entering additional states. Prudential compliance gets simpler to manage: one net worth calculation and one permissible investments methodology replace a spreadsheet of state variants. Exams consolidate: adopting states can join coordinated multistate examinations, so a well-run licensee faces one deep exam cycle instead of dozens of shallow ones. And change-of-control transactions, raising money, adding a control-person investor, or being acquired, follow a common playbook across adopting states.

What adoption does not change: the license count. The MTMA harmonizes the rules; it does not create a single national license. A transmitter serving customers nationwide still files, bonds, and renews in each state, adopting or not, which is why the program management covered at /money-transmitter-license remains the real work.

Where the Model Law Stands, and How to Track Your States

Adoption runs through each state legislature, so the map is always moving: some states enacted the model essentially whole, others took select articles or modified provisions, and the rest still operate legacy statutes. That unevenness is the practical trap. A company that assumes MTMA rules apply everywhere will misread the non-adopting states, and a company that assumes nothing changed will miss real differences, like a new net worth formula or a new exemption, in the states that did enact it.

The working method is to check the actual statute in each state you are licensed in or entering. Our state-by-state money transmitter law pages at /mtl-state-laws track each state's current statute, regulator, bond, and net worth requirement, and we fold legislative changes into client filing calendars as states enact them. CSBS publishes the model text and tracks enactment status, which is the authoritative source for where the model stands.

For companies planning a multistate program, the model law is genuinely good news: the direction of travel is toward common standards and coordinated exams. It just has not repealed the state-by-state nature of the license itself.

FAQ

Frequently Asked Questions

Related Pages

Money Transmitter License Money Transmitter State Laws Money Transmitter License Cost Who Needs a Money Transmitter License

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Money transmitter regulations by state

Money transmitter regulations by state

We are refreshing our state-by-state summaries for money transmitter. Browse the states we have published below.

  • Alabama
    Regulator: Alabama Securities Commission
    License: yes
    Bond: Not less than $100,000, or the average daily outstanding money-received-for-transmission obligations in Alabama plus 50% of average daily outstanding payment-instrument and stored-value obligations in Alabama, whichever is greater; commission may raise to a maximum of $5,000,000
    Open Alabama guide Official regulator site
  • Alaska
    Regulator: Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities
    License: yes
    Bond: $25,000 plus $5,000 for each location, not exceeding a total addition of $125,000 (base + additions); department may raise to a maximum of $500,000 based on financial condition
    Open Alaska guide Official regulator site
  • Arizona
    Regulator: Arizona Department of Insurance and Financial Institutions
    License: yes
    Bond: Greater of $25,000 or 100% of the licensee's average daily money transmission liability in Arizona (most recent three-month period), up to a maximum of $500,000; $25,000 if tangible net worth exceeds 10% of total assets
    Open Arizona guide Official regulator site
  • Arkansas
    Regulator: Arkansas Securities Department
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Arkansas (most recent three-month period), up to a maximum of $500,000; $100,000 if tangible net worth exceeds 10% of total assets
    Open Arkansas guide Official regulator site
  • California
    Regulator: California Department of Financial Protection and Innovation (DFPI)
    License: yes
    Bond: $250,000 to $7,000,000 for receiving money for transmission; selling or issuing payment instruments or stored value carries a separate $500,000 to $2,000,000 bond, and the two are cumulative
    Open California guide Official regulator site
  • Colorado
    Regulator: Colorado Department of Regulatory Agencies, Division of Banking
    License: yes
    Bond: Greater of $250,000 or 100% of the licensee's average daily money transmission liability in Colorado (most recent three-month period), up to a maximum of $1,000,000
    Open Colorado guide Official regulator site
  • Connecticut
    Regulator: Connecticut Department of Banking
    License: yes
    Bond: Non-virtual-currency transmitters: not less than $300,000 (avg weekly transmissions < $300,000), $500,000 ($300,000-$500,000), or $1,000,000 (> $500,000); virtual-currency transmitters: amount set by the commissioner
    Open Connecticut guide Official regulator site
  • Delaware
    Regulator: Delaware Office of the State Bank Commissioner
    License: yes
    Bond: $25,000, plus $5,000 for each location in excess of one, not to exceed $250,000 total
    Open Delaware guide Official regulator site
  • District of Columbia
    Regulator: District of Columbia Department of Insurance, Securities and Banking
    License: yes
    Bond: $50,000, increased by $10,000 per additional location, not to exceed $250,000 total
    Open District of Columbia guide Official regulator site
  • Florida
    Regulator: Florida Office of Financial Regulation
    License: yes
    Bond: Amount specified by rule, but not less than $50,000 and not exceeding $2,000,000 (rule allows for financial condition, number of locations, and anticipated volume)
    Open Florida guide Official regulator site
  • Georgia
    Regulator: Georgia Department of Banking and Finance
    License: yes
    Bond: $250,000 minimum; the Department may require additional coverage, capped at $2,000,000
    Open Georgia guide Official regulator site
  • Hawaii
    Regulator: Department of Commerce and Consumer Affairs, Division of Financial Institutions
    License: yes
    Bond: $100,000 for the initial 12 months of licensure; commissioner may increase up to a maximum of $500,000 based on impaired financial condition
    Open Hawaii guide Official regulator site
  • Idaho
    Regulator: Idaho Department of Finance
    License: yes
    Bond: $10,000, increased by $5,000 per additional location/authorized representative, up to a maximum of $500,000
    Open Idaho guide Official regulator site
  • Illinois
    Regulator: Illinois Department of Financial and Professional Regulation, Division of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Illinois for the most recently completed quarter, capped at $2,000,000
    Open Illinois guide Official regulator site
  • Indiana
    Regulator: Indiana Department of Financial Institutions
    License: yes
    Bond: Greater of $300,000 or the licensee's average daily money transmission liability in Indiana for the most recent calendar quarter, capped at $500,000
    Open Indiana guide Official regulator site
  • Iowa
    Regulator: Iowa Division of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Iowa for the most recent 3-month period, capped at $500,000
    Open Iowa guide Official regulator site
  • Kansas
    Regulator: Office of the State Bank Commissioner
    License: yes
    Bond: Greater of $200,000 or 100% of the licensee's average daily money transmission liability in Kansas for the most recent 3-month period, capped at $1,000,000 (or $200,000 if tangible net worth exceeds 10% of total assets)
    Open Kansas guide Official regulator site
  • Kentucky
    Regulator: Kentucky Department of Financial Institutions
    License: yes
    Bond: At least $500,000; commissioner may increase up to a maximum of $5,000,000 based on financial condition, net worth, or transaction volume
    Open Kentucky guide Official regulator site
  • Louisiana
    Regulator: Louisiana Office of Financial Institutions
    License: yes
    Bond: Minimum $100,000, up to a maximum of $500,000, or a higher amount deemed appropriate by the Commissioner up to a maximum of $1,000,000
    Open Louisiana guide Official regulator site
  • Maine
    Regulator: Bureau of Consumer Credit Protection
    License: yes
    Bond: $100,000
    Open Maine guide Official regulator site
  • Maryland
    Regulator: Office of the Commissioner of Financial Regulation
    License: yes
    Bond: Greater of $150,000 or 100% of the applicant's average daily money transmission liability in the State for the most recent quarter, capped at $2,000,000
    Open Maryland guide Official regulator site
  • Massachusetts
    Regulator: Massachusetts Division of Banks
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Massachusetts over the most recently completed three months, capped at $500,000
    Open Massachusetts guide Official regulator site
  • Michigan
    Regulator: Department of Insurance and Financial Services (DIFS)
    License: yes
    Bond: $500,000 for the first location, plus $10,000 for each additional location and authorized delegate, up to a maximum of $1,500,000
    Open Michigan guide Official regulator site
  • Minnesota
    Regulator: Minnesota Department of Commerce
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Minnesota (most recent 3-month period), capped at $500,000
    Open Minnesota guide Official regulator site
  • Mississippi
    Regulator: Mississippi Department of Banking and Consumer Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Mississippi (most recent 3-month period), capped at $500,000 (commissioner may raise up to $1,000,000)
    Open Mississippi guide Official regulator site
  • Missouri
    Regulator: Missouri Division of Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Missouri (most recent 3-month period), capped at $500,000
    Open Missouri guide Official regulator site
  • Montana
    Regulator: Montana Division of Banking
    License: no
    Bond: Not required (no state license needed)
    Open Montana guide Official regulator site
  • Nebraska
    Regulator: Nebraska Department of Banking and Finance
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in Nebraska (most recent 3-month period), capped at $500,000
    Open Nebraska guide Official regulator site
  • Nevada
    Regulator: State of Nevada Department of Business and Industry, Financial Institutions Division
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Nevada (most recently completed quarter), capped at $500,000
    Open Nevada guide Official regulator site
  • New Hampshire
    Regulator: New Hampshire Banking Department
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in New Hampshire (most recent 3-month period), capped at $500,000
    Open New Hampshire guide Official regulator site
  • New Jersey
    Regulator: New Jersey Department of Banking and Insurance
    License: yes
    Bond: Amount set by the Commissioner by regulation, not less than $100,000 and not more than $1,000,000 (money transmitter). Foreign money transmitters use a volume-based schedule starting at $25,000.
    Open New Jersey guide Official regulator site
  • New Mexico
    Regulator: New Mexico Regulation and Licensing Department, Financial Institutions Division
    License: yes
    Bond: Greater of $300,000 or 1% of the licensee's total yearly dollar volume of money transmission business in New Mexico (or projected first-year volume), up to a maximum of $2,000,000
    Open New Mexico guide Official regulator site
  • New York
    Regulator: New York State Department of Financial Services
    License: yes
    Bond: Set by the Superintendent of Financial Services for each licensee; New York Banking Law Article 13-B fixes no dollar amount, so confirm the required bond with DFS before relying on a figure
    Open New York guide Official regulator site
  • North Carolina
    Regulator: North Carolina Office of the Commissioner of Banks
    License: yes
    Bond: $150,000 base (transmission volume in NC up to $1,000,000); increases with NC transmission volume (e.g., $175,000, $200,000, and higher tiers)
    Open North Carolina guide Official regulator site
  • North Dakota
    Regulator: North Dakota Department of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of the licensee's average daily money transmission liability in North Dakota (most recent 3-month period), capped at $500,000
    Open North Dakota guide Official regulator site
  • Ohio
    Regulator: Ohio Department of Commerce, Division of Financial Institutions
    License: yes
    Bond: Security device (surety bond or permitted alternative) of not less than $300,000, up to a maximum of $2,000,000 as the Superintendent finds appropriate
    Open Ohio guide Official regulator site
  • Oklahoma
    Regulator: Oklahoma State Banking Department
    License: yes
    Bond: $50,000 plus $10,000 per authorized-delegate location, not exceeding a total of $500,000
    Open Oklahoma guide Official regulator site
  • Oregon
    Regulator: Oregon Department of Consumer and Business Services, Division of Financial Regulation
    License: yes
    Bond: $25,000, increased by $5,000 per additional location/authorized delegate (amount otherwise set by rule/Director)
    Open Oregon guide Official regulator site
  • Pennsylvania
    Regulator: Pennsylvania Department of Banking and Securities
    License: yes
    Bond: Bond in the penal sum of $1,000,000 (department may require additional bond based on average daily outstanding transmission balance)
    Open Pennsylvania guide Official regulator site
  • Puerto Rico
    Regulator: Puerto Rico Office of the Commissioner of Financial Institutions (OCIF)
    License: yes
    Bond: $500,000 for a single office, increased by $10,000 per additional office or authorized agent (Commissioner may require a higher bond based on business volume/financial condition)
    Open Puerto Rico guide Official regulator site
  • Rhode Island
    Regulator: Rhode Island Department of Business Regulation, Division of Banking
    License: yes
    Bond: $50,000 (currency transmission licensees); department may accept an alternative security form if a surety bond is not commercially available at reasonable cost
    Open Rhode Island guide Official regulator site
  • South Carolina
    Regulator: South Carolina Attorney General (Commissioner under the South Carolina Uniform Money Services Act)
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in South Carolina (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open South Carolina guide Official regulator site
  • South Dakota
    Regulator: South Dakota Division of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in South Dakota (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open South Dakota guide Official regulator site
  • Tennessee
    Regulator: Tennessee Department of Financial Institutions
    License: yes
    Bond: Greater of $50,000 or 100% of average daily money transmission liability in Tennessee (most recent calendar quarter), capped at $800,000
    Open Tennessee guide Official regulator site
  • Texas
    Regulator: Texas Department of Banking
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Texas (most recent 3 months), capped at $500,000; alternatively $100,000 if tangible net worth exceeds 10% of total assets
    Open Texas guide Official regulator site
  • Utah
    Regulator: Utah Department of Financial Institutions
    License: yes
    Bond: Flat minimum surety bond of $50,000
    Open Utah guide Official regulator site
  • Vermont
    Regulator: Vermont Department of Financial Regulation
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Vermont (most recent 3 months), capped at $2,000,000
    Open Vermont guide Official regulator site
  • Virginia
    Regulator: Virginia State Corporation Commission, Bureau of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Virginia for the most recent quarter, capped at $1,000,000; a flat $100,000 where tangible net worth exceeds 10% of total assets
    Open Virginia guide Official regulator site
  • Washington
    Regulator: Washington State Department of Financial Institutions
    License: yes
    Bond: Surety bond based on prior year's money transmission and payment instrument dollar volume; minimum $10,000, not to exceed $550,000
    Open Washington guide Official regulator site
  • West Virginia
    Regulator: West Virginia Division of Financial Institutions
    License: yes
    Bond: $300,000 for money transmission; $100,000 for check or money-order sale or currency exchange; increased by 1% of annual West Virginia volume over $10 million, capped at $1,000,000
    Open West Virginia guide Official regulator site
  • Wisconsin
    Regulator: Wisconsin Department of Financial Institutions
    License: yes
    Bond: Greater of $100,000 or 100% of average daily money transmission liability in Wisconsin (most recent 3 months), capped at $500,000
    Open Wisconsin guide Official regulator site
  • Wyoming
    Regulator: Wyoming Division of Banking
    License: yes
    Bond: $10,000 or 2.5 times outstanding payment instruments, whichever is greater, not to exceed $500,000
    Open Wyoming guide Official regulator site

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