The Conference of State Bank Supervisors (“CSBS”) announced on June 24 that 23 states have joined a multistate agreement to standardize their licensing process for money services businesses (“MSBs”), such as money transmitters. The agreement centralizes the review of common licensing requirements, such as a MSBs’ “business plan; direct and indirect owners, including background checks; [and] financial information and compliance with the anti-money laundering provisions of the federal Bank Secrecy Act.” As the common items compose a “large part of an application review workload,” the agreement should reduce the existing licensing review burden on state regulators and promote the ease with which MSBs can receive licenses in multiple states.

The standardized process begins with one state regulatory department conducting a review of the common items and then issuing a “certification” that other states participating in the agreement will accept. Participating states will then review any state-specific requirements prior to issuing a state license. As of the time the agreement was announced, 15 MSBs are participating in a licensing review pilot under the agreement and have received a total of 72 licenses.

This represents growth from the original seven-state agreement announced in February 2018 and progress towards achieving the CSBS’ Vision 2020 goal of “harmoniz[ing] the multistate licensing and supervisory experience for nonbank financial services providers, including fintechs.” The 23 states that have joined the agreement include California, Connecticut, Georgia, Iowa, Idaho, Illinois, Kansas, Kentucky, Louisiana, Massachusetts, Mississippi, North Carolina, North Dakota, Nebraska, Ohio, Rhode Island, South Dakota, Texas, Tennessee, Utah, Vermont, Washington, and Wyoming.

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Photo of Paul Boller Paul Boller

Paul Boller is an Attorney in the Financial Services Litigation section of Troutman Sanders. Paul assists clients with navigating a variety of federal and state statutory and regulatory requirements in consumer financial services.

Photo of David M. Gettings David M. Gettings

Dave Gettings is a partner who focuses on defending his clients in consumer class actions and complex commercial litigation nationwide.  He specializes in class actions and consumer litigation involving a variety of federal and state laws and regulations, including the Fair Credit Reporting Act (FCRA), the Telephone Consumer Protection Act (TCPA) and associated FCC regulations, the Fair Debt Collection Practice Act (FDCPA), the Truth-in-Lending Act (TILA), the Electronic Fund Transfer Act (EFTA), and many similar state consumer protection statutes.