Licensing Insights: FL Money Transmitter License Updates & MD Payroll Licensure Law
Florida Money Transmitter License Updates
ICYMI: Florida has updated its Money Services Business License Reporting and Application
Florida Expands MSB Quarterly Report Effective Q2 2026
The Florida Office of Financial Regulation has revised Form OFR-560-04, the Money Services Business Quarterly Report, effective July 1, 2026, applicable to all Money Services Business licensees operating under Rule 69V-560.1012, F.A.C. Licensees must use the updated format for all quarterly reports filed on or after the effective date.
The revisions expand the report to capture virtual currency transmission activity and physical commodity assets, including gold and silver coins, reflecting the growing role of these asset classes in money services business operations.
Key Updates:
- Section II expanded: A new subsection (Section II(B)) requires foreign currency exchangers to separately report gold and silver coin exchange transactions, including transaction count, total face amount (in U.S. dollars), and service fees assessed.
- Section VI added: Money transmitters engaged in virtual currency activity must now report virtual currency transmissions quarterly, capturing transaction count, total U.S. dollar equivalent value, and fees assessed. The prior form included no virtual currency reporting requirement.
- Sections VII and VIII added: New reporting sections cover gold and silver coin transmissions (by coin type, with separate rows for gold and silver) and gold and silver coin held in custody, reported as the U.S. dollar equivalent value on the last day of each month.
In addition, the Office has updated Form OFR-560-01, the new application form for Money Transmitter Licensees, to input similar language related to gold and silver coin custody, as well as virtual currency transactions. These updates can be found in Section 5(E).
Form Note: Licensees should discard prior versions of Form OFR-560-04 (previously effective 02/2023) and use only the July 1, 2026 version going forward. Per Florida OFR, the updated form applies beginning with the Q2 2026 report, covering activity through June 30, 2026, due August 14, 2026.
FS Vector monitors ongoing state guidance for money services business licensing and reporting to help ensure compliance with the latest requirements. Contact FS Vector for assistance navigating Florida’s updated quarterly reporting obligations for virtual currency transmissions and expanded coin-related disclosures.
Maryland General Assembly Passes Legislation Related to Payroll Processor Licensure
During its 2026 session, Maryland’s General Assembly passed House Bill 118. The bill was signed into law by Governor Wes Moore and takes effect October 1, 2026.
The new law excludes payroll processors from the definition of money transmitter under Md. Code Ann., Financial Institutions Article §12-401 if certain conditions are met. Specifically:
- There must be a written agreement directing the payroll processor to provide services on behalf of the employer;
- The employer holds the processor out to employees as providing payroll services on the employer’s behalf; and
- The employer’s obligation to pay employees is not extinguished if the processor fails to deliver funds to employees.
If the above conditions are met, and the processor does not provide any other type of money transmission service, the payroll processor will be exempt from Maryland money transmitter licensing requirements. Processors who are currently licensed as money transmitters but will be exempt as of October 1 may surrender the license on or after October 1. Alternatively, they may allow the license to expire on December 31, 2026.
FS Vector Calendar
Events FS Vector Licensing Team is attending
- AARMR | August 11-13 | Bellevue, WA
- FS Vector <> Orrick Happy Hour - August 12, 6:30-8:30 PM
- RSVP Here
- MTRA | September 14-17 | Albuquerque, NM
- M20/20 | October 18-21 | Las Vegas, NV
- Chicagoland | October 30 | Chicago, IL
Upcoming FS Vector Webinars
- FS Vector Licensing Lunch & Learn: APPROVED - Jul 15, 2026
- The Rules are Changing. Make Sure You’re Keeping up. - August 5, 2026
- Our very own Tim Lange and Kristie Battershell will be joining MSBA’s upcoming webinar on state regulatory updates. Staying on top of state-level regulatory changes is one of the biggest challenges facing money services businesses today. This session breaks down the latest updates from across the country - licensing changes, compliance requirements, and enforcement trends - giving you the clarity you need to keep your operations running smoothly and your business in good standing.
- RSVP Here