Score your sponsor bank exposure
Work through the five exposures one by one: termination notice period, open bank findings and remediation deadlines, single or dual bank concentration, upcoming economic reopeners, and product plans waiting on bank approval. Write down your position on each with dates.
Build the evidence room
Gather the material every path forward will ask for: audited financials, control person files, a current flow-of-funds diagram, your written BSA/AML program, and reconciliation documentation. A replacement bank's diligence and a state money transmitter application draw on the same packet.
Sequence your first filing wave
Rank your states by volume, note each state's fees, bond amounts, and typical processing time, and pick the wave that covers the most business the fastest. FinCEN MSB registration comes first because it is federal and quick relative to state licensing.
Set the parallel-run plan
Decide which functions stay with the bank during the transition, which volume migrates as each approval lands, and what the trigger points are for renegotiating or retiring the sponsor agreement.
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