CSBS Issues MTMA Guidance on Stablecoins and ROU Leases
CSBS Issues MTMA Guidance on Stablecoins and ROU Leases
CSBS Issues MTMA Guidance on Stablecoins and ROU Leases
The Conference of State Bank Supervisors (CSBS) issued two new Money Transmission Modernization Act (MTMA) implementation guidance documents, effective upon issuance, addressing the treatment of stablecoins and right-of-use (ROU) leases under Section 2.01(bb) of the MTMA, which governs tangible net worth calculations. The guidance applies to money transmitters licensed in any state that has adopted the MTMA in full or in part.
Money transmitters must apply consistent standards when accounting for stablecoins and ROU lease obligations as part of enterprise-level MTMA compliance, including across all operations in adopting states.
Key Updates:
- Stablecoin treatment: Guidance clarifies how stablecoins are classified under MTMA tangible net worth calculations, building on a 2025 clarification addressing virtual currency treatment more broadly.
- ROU lease accounting: Separate guidance addresses how right-of-use leases factor into tangible net worth, a core MTMA capital requirement.
- Enterprise-level applicability: Firms licensed in any MTMA-adopting state must comply at the enterprise level, extending requirements across all operations.
- Pending adoption: Legislation is currently pending in Alaska, Louisiana, Maryland, Michigan, and Oklahoma; multistate transmitters should monitor adoption status closely.
- Oversight process: Guidance was developed under the CSBS Non-Depository Supervisory Committee in consultation with the Money Transmitter Regulators Association; review the full CSBS blog post for additional detail.
FS Vector monitors ongoing state guidance for money transmission licensing and compliance to help ensure alignment with the latest requirements. Contact FS Vector for assistance navigating MTMA implementation requirements, including stablecoin classification and tangible net worth calculations.