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Money Transmission Act Money Transmitter

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

Troutman Pepper

Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros...

Troutman Pepper on

In this episode of Payments Pros, Keith Barnett is joined by Eli Polanco, founder and CEO of Nivelo, to discuss critical issues in payroll processing. They highlight the significant impact that the Money Transmitter...more

Ballard Spahr LLP

Wisconsin and Maine enact Model Money Transmission Modernization Law

Ballard Spahr LLP on

In April 2024, Wisconsin and Maine enacted the Model Money Transmission Modernization Law (“MTML”) to implement the Conference of State Bank Supervisors’ Model Money Transmission Modernization Act.  As of April 22, 2024,...more

McGlinchey Stafford

Podcast: Deep Dive Into Payments: Impacts of Money Transmission Laws [More with McGlinchey, Ep. 59]

McGlinchey Stafford on

The next item in McGlinchey's Deep Dive into Payments Series is a podcast on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money...more

McGlinchey Stafford

Deep Dive Into Payments: Impacts of Money Transmission Laws

McGlinchey Stafford on

The next item in McGlinchey’s Deep Dive into Payments Series is on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money transmission...more

Orrick, Herrington & Sutcliffe LLP

DFPI concludes MTA licensure not required for data processor

On July 25, the California Department of Financial Protection and Innovation (DFPI) released a new opinion letter concluding that a company that merely receives payment instructions, orders, or directions to transmit money or...more

Orrick, Herrington & Sutcliffe LLP

DFPI says escrow trust accounts are not stored value under MTA

The California Department of Financial Protection and Innovation recently released a new opinion letter covering aspects of the California Money Transmission Act (MTA) and the Escrow Act related to persons engaging in...more

Shipkevich PLLC

Michigan Suspends FTX Lend Money Transmitter License and Orders FTX US License as Expired

Shipkevich PLLC on

On January 10, 2023 by the Michigan Department of Insurance and Financial Services (DIFS), issued an order regarding two companies, West Realm Shires Services, Inc. dba FTX US (“FTX US”) and FTX Lend Inc. Both companies are...more

Ballard Spahr LLP

D.C. Department of Insurance, Securities and Banking issues bulletin on money transmission

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On August 8, 2022, the District of Columbia Department of Insurance, Securities and Banking (the Department”) issued a Bulletin on money transmission (the “Bulletin”). The Department issued the Bulletin to ensure that...more

Sheppard Mullin Richter & Hampton LLP

DFPI: Virtual Currency Platform is not Money Transmitter

On March 23, the California Department of Financial Protection and Innovation (DFPI) responded to a request for an interpretative legal opinion as to whether the virtual currency services offered by a company require it to...more

Cooley LLP

Alert: California Finalizes Rulemaking for Agent-of-a-Payee Exemption in Money Transmission Licensing

Cooley LLP on

The California Department of Financial Protection and Innovation (DFPI) has finally adopted final rules relating to the scope of the agent-of-a-payee exemption under the California Money Transmission Act (MTA), Cal. Fin. Code...more

Carlton Fields

State Regulations on Virtual Currency and Blockchain Technologies (Updated March 2021)

Carlton Fields on

Introduction: There exists no uniformity with respect to how businesses that deal in virtual currencies (also known as "cryptocurrencies") such as Bitcoin are treated among the states. For these proprietors, often the first...more

Cooley LLP

Alert: Who is an Agent of a Payee in California? With Rulemaking Pending, Possible Scope Suggested by Opinion Letters

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Any company that intermediates payments for other parties ─ such as a marketplace platform, a billing service, a payment facilitator or a B2B platform provider ─ must take into consideration the applicability of money...more

Morrison & Foerster LLP

Bitcoin Is “Money” For Purposes Of D.C. Money Transmission Law, Says Federal Court

A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license—even if the state’s...more

Allen Matkins

Will California License Virtual Currency Issuers?

Allen Matkins on

The California Department of Business Oversight regulates the money transmission business pursuant to the Money Transmission Act, Cal. Fin. Code § 2000 et seq. The Act currently defines "money transmission" as any of the...more

Ballard Spahr LLP

PA Department of Banking and Securities: Virtual Currency is not “Money”

Ballard Spahr LLP on

Typical Virtual Currency Exchanges Do Not Require PA Money Transmitter Licenses - The Pennsylvania Department of Banking and Securities (“DoBS”) just released Guidance declaring that virtual currency, “including Bitcoin,”...more

Goodwin

Financial Services Weekly News - September 2015

Goodwin on

Regulatory Developments - California Department of Business Oversight Permits Money Transmitter to Treat Customer Funds in Designated Custodial Account as “Eligible Securities” - The California Department of...more

Shumaker, Loop & Kendrick, LLP

Internet Startups: Beware of Being a Money Transmitter

So, you’ve got a great idea. Social media platforms are all about finding new solutions for old inefficiencies. And what’s more efficient than serving as a platform for an account holder to obtain a single cash payment in...more

Davis Wright Tremaine LLP

California Adds Limited Agent of A Payee Exemption to Its Money Transmitter Licensing Requirement; Relaxes “Right To Refund”...

Following an extended period of public comment and modifications to the bill beginning in March of 2013, the California legislature recently amended its Money Transmission Act to exempt from licensure companies that process...more

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