Money Transmission Modernization Act

Key points

  • CSBS reports 31 states have enacted the Money Transmission Modernization Act in full or in part, as of September 2026.
  • Licensees in adopting states account for 99% of reported US money transmission activity.
  • Permissible investments must at least equal outstanding money transmission obligations at all times, which makes it a daily control.
  • Change of control requires prior approval, and CSBS now issues unified guidance on contested points such as virtual currency in net worth.
  • Each state's enactment should be checked, because effective dates and figures differ.
On this page

The Money Transmission Modernization Act (MTMA) is the Conference of State Bank Supervisors' model law for money transmission. As of September 2026, CSBS reports that 31 states have enacted it in full or in part, and that money transmitters licensed in at least one adopting state account for 99% of reported money transmission activity. For licensees, the MTMA turns the most variable state requirements, net worth, surety bonds and permissible investments, into common standards, adds a consistent approach to change of control and supports coordinated examinations.

This article covers the compliance side: the requirements licensees must meet in adopting states and the controls that show they are met.

What the MTMA standardises

AreaMTMA requirementControl needed
Tangible net worthTiered by total assets, with floor and capMonthly calculation and buffer monitoring
Surety bondScaled to state transmission volume, with minimum and maximumAnnual review and adjustment
Permissible investmentsAt least equal to outstanding obligations at all timesDaily reconciliation
Change of controlPrior approval of acquisitions of controlShareholder monitoring and deal procedure
Authorised delegatesLicensee responsible for delegates' conductDelegate due diligence and oversight
ReportingCall reports and notices through NMLSCalendar and data quality checks
ExaminationsMultistate coordinationExamination readiness file

Permissible investments: a daily control

The MTMA requires a licensee to hold permissible investments with a market value at least equal to its outstanding money transmission obligations at all times. These investments are held in trust for customers if the licensee becomes insolvent. Eligible assets include cash, certificates of deposit, certain receivables from authorised delegates, US government securities and some money market funds, some subject to limits.

The words at all times mean this is a daily test. A licensee whose outstanding obligations spike on a high-volume day, for example before a holiday, can fall short even if month-end figures look healthy. The control set should include:

  • a daily calculation of outstanding obligations, by state where the law requires;
  • a daily valuation of permissible investments, applying any concentration limits;
  • an automated alert where the margin falls below an internal buffer;
  • a funding procedure to restore the position the same day;
  • records retained for examination.

For virtual currency businesses, outstanding obligations may include virtual currency owed to customers. State laws and CSBS guidance address whether like-kind assets are required, so check each state's position.

Net worth and bonds

Tangible net worth under the MTMA rises with the licensee's total assets between a floor and a cap. Intangible assets, such as goodwill and capitalised software, are excluded. For fintechs whose balance sheets are largely intangible, this is often the binding constraint. CSBS guidance published in 2026 addresses the treatment of virtual currency in tangible net worth and of right-of-use lease assets, and should be reflected in the calculation.

Surety bonds scale with the licensee's money transmission volume in each state, between a minimum and a maximum. Review bond amounts after each annual report of volume and adjust before the state asks.

Licensees growing quickly should model net worth and bond requirements forward, using projected assets and volumes for the next 12 to 24 months. A funding round or a large new client can move a licensee into a higher tier, and capital should be in place before the requirement applies, not after an examiner notices. Record the projection and the board's decision on the buffer to hold above the requirement.

Change of control

Acquiring control of a licensee requires prior approval in MTMA states. Control is presumed above a common shareholding threshold, and the acquirer files through NMLS with information on the people and entities involved. Licensees should:

  • monitor the cap table and know which investors approach the threshold;
  • build the approval timetable into fundraising and M&A documents;
  • prepare the filing package in advance, including biographical and financial information on controllers;
  • notify states of changes in key individuals as each state requires.

A transaction that closes before approval puts the licence at risk in every state that has not approved it.

Authorised delegates

Many money transmitters operate through authorised delegates, the agents that accept funds from customers. Under the MTMA the licensee is responsible for its delegates' conduct of money transmission. A delegate program needs written contracts, due diligence before appointment, AML training, monitoring of activity, remittance of funds within set periods, and termination where needed. Receivables from delegates can count as permissible investments within limits, so delegate remittance timing also affects the daily calculation.

Review each delegate at least annually, and more often for high-volume or higher-risk delegates. Track remittance timeliness, transaction patterns, complaints and training completion. Delegates that remit late, show unusual activity or resist monitoring should be placed on a remediation plan or terminated. Keep the delegate list current in NMLS where states require it, and make sure the list held for FinCEN purposes matches.

Reporting and examinations

Licensees file call reports through NMLS, including the money services businesses call report, and annual reports with financial statements. Our MSB call report guide covers the content and our article on NMLS renewal for money transmitters covers the year-end cycle.

The MTMA supports multistate examinations coordinated through CSBS, including the One Company, One Exam approach. Keep an examination readiness file with the latest permissible investments and net worth calculations, bond schedule, delegate list, BSA/AML risk assessment and independent test, complaints log and board minutes.

Findings that recur in examinations

State examinations of money transmitters regularly identify the same weaknesses:

  • permissible investments calculated monthly rather than daily, with shortfalls on high-volume days;
  • outstanding obligations understated by excluding funds held by delegates or in transit;
  • intangible assets counted towards net worth;
  • change of control filings made after a transaction closed;
  • delegate oversight that consists of contracts without monitoring;
  • call report data that does not reconcile to financial statements;
  • BSA/AML risk assessments not updated for new products or corridors.

Each of these can be addressed with a control and evidence. An internal review against this list before the next examination is an efficient use of compliance time.

A compliance calendar for MTMA licensees

FrequencyTask
DailyPermissible investments against outstanding obligations
MonthlyTangible net worth calculation and buffer review
QuarterlyMSB call report through NMLS; delegate monitoring review
AnnuallyRenewal through NMLS, annual report and audited financial statements, bond review, independent AML test
Event drivenChange of control, key individual changes, new products, material incidents

Where states differ

PointWhy it matters
Effective datesSome states phase in provisions over time
FiguresSome states changed net worth or bond figures
Partial adoptionSome states adopted only parts of the model law
Virtual currencyTreatment of crypto in obligations and net worth varies
Non-adopting statesNew York and others apply their own regimes

Keep a state matrix that records, for each state, whether the MTMA applies, the effective date, the figures and any local variations. Review it when states legislate, usually after each legislative session. Assign an owner for the matrix and record the source for each entry, such as the statute, regulation or state guidance, so that changes can be traced and examiners can see the basis for the firm's approach.

Using CSBS guidance

CSBS runs a formal process for requests for unified MTMA implementation guidance. Topics published so far include virtual currency in tangible net worth, right-of-use leases and stablecoin tangibility. Licensees should monitor new guidance, apply it to their calculations and record which guidance they rely on. Where a state takes a different view, record the state's position.

Our guide to US money transmitter compliance requirements covers the wider obligations, and our US money transmitter licence page covers applications.

For licensees planning expansion into further states, the MTMA reduces the work of adapting the compliance framework state by state, but each new licence still brings its own application, bond, reporting and examination. Build the state matrix, the daily permissible investments control and the change of control procedure once, at group level, and extend them as each state is added. That approach keeps the framework consistent and makes the next examination, in whichever state leads it, easier to manage.

References

This article is general information as at 8 November 2026 and is not legal advice.

Frequently asked questions

How many states have adopted the MTMA?

31 states had enacted it in full or in part as of CSBS's September 2026 update.

How often must permissible investments be tested?

The MTMA requires them to at least equal outstanding obligations at all times, so licensees should test daily.

Do intangible assets count towards net worth?

No. The MTMA uses tangible net worth, which excludes intangible assets such as goodwill.

Is prior approval needed for a change of control?

Yes, in MTMA states, for acquisitions above the control threshold, filed through NMLS.

Is the licensee responsible for its agents?

Yes. Under the MTMA the licensee is responsible for its authorised delegates' money transmission activity.

Does CSBS issue MTMA guidance?

Yes, through a formal request process. Published topics include virtual currency in net worth and stablecoin tangibility.

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