Licensing Insights: MA MTL Guidance, Renewal Season, CT-DOB NMLS Update & More

MA Issues Detailed Transition Guidance for Money Transmitter License

Starting November 1, 2025, the Massachusetts Division of Banks will require companies holding a Check Seller License and/or Foreign Transmittal Agency License to submit a license transition request related to the new Money Transmitter License via NMLS. As previously mentioned, license approvals will not be processed until January 1, 2026.

During the week of September 15, licensees should have received a transition number via email sent to the Primary Company Contact on their NMLS record. Companies with existing NMLS records will not need to re-enter company information but must select the Massachusetts license, identify business activities, and complete state-specific fields. Amendments or surrenders must also be processed in NMLS, and the Division encourages licensees to make record updates by November 1, 2025, to avoid pending changes at transition.

FS Vector continuously monitors regulatory developments to keep clients informed of licensing updates across all states. For more information on how we can assist with this transition or any other upcoming licensing requirements, contact us.

Oklahoma MTL Update – Digital Asset Kiosks Reporting

The Oklahoma State Banking Department has issued guidance implementing Senate Bill 1083, which takes effect November 1, 2025, and introduces new compliance obligations for digital asset kiosk operators.

Under the new law, digital asset kiosks must now be licensed as money transmitters pursuant to the Oklahoma Financial Transaction Reporting Act (Title 6 O.S. § 1511 et seq.).

Key Updates:

• Quarterly Reporting: Kiosk operators must complete and submit a new Quarterly Digital Current Kiosk Report available at banking.ok.gov.
  
  • The completed report must be emailed in Excel format to DigitalKioskReport@banking.ok.gov
  • and uploaded to NMLS under “Additional Requirements” as a PDF named “OK-Kiosk-List.”
• Other new requirements include notice to the Department before kiosk placement, customer disclosure standards, fraud-prevention measures, transaction and fee limits, refund procedures, and live customer support.
• Kiosk operators must also maintain a $500,000 surety bond and pay a $50 per-location fee.

Renewal Note: The Department has also released an updated Renewal Report, older versions should be discarded. The new form is available on the Department’s website and can be uploaded through NMLS under “Additional Requirements.”

​FS Vector monitors ongoing state guidance for digital asset kiosk operators and money transmitter licensees to help ensure compliance with ​t​he latest requirements.​ Contact FS Vector for assistance navigating Oklahoma’s new quarterly reporting and licensing obligations.

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Renewal Season

The NMLS license renewal season (November 1 to December 31) is fast approaching, and timely renewal is essential to ensure your business operations continue without interruption in all your licensed jurisdictions. Below are some key considerations to help you prepare.

• License Priority and Determine Licenses Not Being Renewed: Evaluate which licenses are most critical to your business operations and prioritize their submission and approval to avoid potential disruptions. Additionally, identify any unneeded licenses and plan to surrender them proactively. This will help maintain a clean NMLS record and prevent unnecessary fees or compliance issues. Merely designating a license as "not being renewed" in NMLS is insufficient; state regulators require formal surrender and completion of all related requirements.
• Review License Eligibility and Identify Potential Submission Blockers: Review your current license status in NMLS to confirm that all licenses meet renewal criteria. Audit the associated NMLS records (company, branch, key individuals, etc.) to ensure all information is current and accurate.

Resolve any open license items that could potentially block renewal, such as a “prevent renewal flag” placed by a regulator, open license items or unpaid invoices.  Keep in mind that some states require all license items are cleared and all fees paid before renewal submissions via NMLS.  While the system may allow renewal submission if there isn't a "prevent renewal flag," individual state regulators may have different requirements. 

For mortgage related companies, ensure all associated Mortgage Loan Originators complete their annual Continuing Education and submit their individual license renewals.

• Be Aware of Early Deadlines: Some states may have earlier submission requirements. Confirm all state-specific deadlines to avoid last-minute surprises. For example, West Virginia has a November 1st deadline. For 2025, renewals will be accepted on Monday, November 3, 2025 since November 1 falls on a Saturday.
• Authority To Do Business After 12/31: Renewal submission via NMLS is only a request which each regulator must approve. The license will expire on December 31st unless the renewal is approved before that date. While some states permit companies to continue doing business in the new year as long as the renewal request was submitted by their deadline, other states require renewal approval before the December 31 license expiration. In these states, your company may not be authorized to conduct business after January 1, resulting in a gap in licensure. As mentioned, prioritize renewals for these states to prevent any disruption of business.

Prepare early to help minimize risks and ensure a smooth NMLS renewal process. Reach out to FS Vector for any assistance with your license renewals. 

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States Requiring SOC 2 or Other IT Audits Before MTL Issuance

While a number of states require audited financials, minimum net worth, surety bonds, and an AML/KYC program, only a few explicitly require a security audit, third-party systems review, or IT control attestation (e.g., something akin to a SOC 2 report) as part of the initial license application.

In most states, the term “audit” refers to financial audits, internal audits, or independent reviews of financial statements and compliance program effectiveness. Explicit requirements for security system audits or third-party security control attestations are less common in licensing statutes, though some states impose them through regulations or guidance.

For example, Texas requires applicants to submit an Information Technology Questionnaire detailing their internal and external audit programs, incident response, disaster recovery, and security controls covering application servers, web applications, and virtual currency wallet infrastructure. Texas also explicitly states that “the applicant must be prepared to provide a third-party assessment, audit, test, or combination of the applicant’s relevant computer systems.” Although not specified in the published checklist, the Texas Department of Banking has informally indicated a preference for a SOC 2 Type 2 audit. Similar requirements apply in Ohio, Hawaii, and Washington, which each call for a security audit as part of the initial application process (Ohio’s rule applying specifically to virtual currency companies).

New York, by contrast, mandates that covered entities maintain a robust cybersecurity program designed to protect the confidentiality, integrity, and availability of their information systems and nonpublic information. Under Part 500 of the Superintendent’s Regulations, applicants must provide evidence of a recent independent cybersecurity audit, as well as the results of their most recent penetration testing and vulnerability assessments of systems, networks, and applications.

Even where statutes do not explicitly require security audits at the application stage, licensees are typically subject to examinations post-licensure that evaluate internal controls, recordkeeping, system security, and incident response. Accordingly, maintaining a comprehensive, independently verified security program—such as a SOC 2 Type II attestation—can help expedite regulatory approval and address examiner expectations.

State of Connecticut Department of Banking Expanding Use of Electronic Surety Bonds through NMLS 

Starting Oct. 27, the State of Connecticut Department of Banking will begin receiving Electronic Surety Bonds (ESB) for their existing licensees and new applicants through NMLS for the following license type(s):

• Debt Negotiation License
• Exempt Mortgage Servicer Registrant

See the Electronic Surety Bonds section of the NMLS Resource Center for a list of state agencies who have also adopted ESB and their conversion plan. This is in addition to 9 other licenses that CT already accepts ESB etc and shows the valuable extension of this efficient solution.

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FS Vector Calendar

Events FS Vector Licensing Team is attending

• Money20/20 | Oct 26-29 | Las Vegas, NV
• 2025 NACARA Conference - Oct 28-30 - Boise, ID
• RegList on the Ocean | Nov 4-5 | Huntington Beach, CA - Contact us for a discount code to attend!
• FinTech NerdCon - Nov 19-20 -  Miami, FL

Upcoming FS Vector Webcasts

• FS Vector Licensing Lunch & Learn: Real Talk: Real Estate Licensing & More - November 5, 2025
  
  • Register Here

With increased focus on real estate licensing and an industry-wide push for greater transparency, understanding the complex world of broker licensing is even more critical. Join FS Vector, and Doug Gartley, State Broker with Rocket Homes/Redfin, for a webinar on the state licensing process where we'll break down:

• Broker License Process
• State reciprocity 
• Broker responsibility once licensed