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Money Transmission Modernization Act: An Update on its adoption across the U.S.

Anicia De Pina

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June 19, 2024

The Model Money Transmission Modernization Act (MTMA) is a transformative piece of state-level legislation for money transmitters that will be prevalent for the foreseeable future. Through its alignment of prudential standards and the introduction of a multistate supervisory system, the MTMA will decrease the regulatory burden felt within the industry by providing a uniformity across requirements - and allow license holders to operate in multiple states with ease, and significantly cut down the fragmentation felt across state lines.

What is the Money Transmission Modernization Act?

The MTMA is a set of nationwide standards and requirements that were approved by the Conference of State Bank Supervisors (CSBS) in August 2021. The MTMA has been developed by industry and state experts with the aim of being implemented uniformly at the state level. Furthermore, the MTMA institutes a process for licensing money transmitters, which includes a thorough screening of owners, officers, and directors. The legislation also lists exemptions from money transmitter licensing requirements, outlines safety and soundness prerequisites (such as surety bonds, permissible investments, and net worth), mandates customer disclosures, and regulates recordkeeping and reporting.

State-by-State Adoption

Several states have adopted all or certain provisions of the MTMA and countless other states have introduced legislation that, if passed, would adopt the MTMA and implement it into the state's money transmission legislation. At the time of writing, 13 states have adopted the MTMA in its entirety, although only Maine, Minnesota, and Vermont have included the provisions regarding virtual currency; 9 states have partially adopted the MTMA; and 8 states have legislation pending.

Hover over the map below to see state-level adoption of the MTMA. This map was designed by 蹤獲鱉鱉 analysts to behave as a live tracker which updates as more states adopt the MTMA or make progress towards adoption.

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Adopted: The state has adopted the MTMA in its entirety.

Partially Adopted: The state has adopted portions of the MTMA.

Legislation Pending: Legislation regarding full or partial adoption of the MTMA is currently pending in the state legislature.

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