Licensing Insights: Money20/20 Recap, NMLS Updates, NE MTL Changes & More
Money2020 Recap
Stablecoins continue to dominate the conversation. In particular, we had some great discussions with companies in the stablecoin space about their go-to-market and scaling strategies. The passage of the GENIUS Act and the growing focus on state/federal charter options mean that licensing scope and strategy have become significantly more complex and strategically consequential.
Our conversations with investors reflected a refined focus on AI. In particular, AI is quickly becoming a baseline expectation. In the state licensing context, this is relevant both to the products that companies are building as well as the licensing platforms that are supporting license acquisition and maintenance. We continue to advance our Approved licensing platform to meet this moment, building automation and intelligence into the licensing lifecycle.
CSBS to Implement Revised Individual Disclosure Questions in 2026
The Conference of State Bank Supervisors (CSBS) will introduce updated Individual Disclosure questions for NMLS MU2 and MU4 filings, with implementation expected in early 2026. Specific rollout details are planned to be announced by CSBS closer to the launch.
These changes are part of CSBS’s broader initiative to modernize and streamline disclosure reporting across license types. While the revised questions will initially apply only to Individual filings, corresponding updates to Company Disclosure questions are expected to be made at a later date.
What Companies Should Do Now
- Review CSBS’s Response to Public Comments document here, which summarizes key updates and clarifications.
- Begin internal discussions with legal and compliance teams to understand the impact of revised individual disclosures on company disclosures.
- Monitor the NMLS Resource Center and CSBS Newsroom for release timelines and implementation instructions.
FS Vector will continue to monitor and provide guidance as more information becomes available. For questions or assistance evaluating how these changes may impact your company, please contact our Licensing Team.
Nebraska updates MTL requirements - Effective Immediately
Nebraska recently updated its Money Transmitter License application requirements. The new requirements include:
- Criminal background check requirement for direct owners triggered when ownership equals or exceeds 25% (previously 10%).
- NMLS Credit Report now required for key individuals
- Removed personal financial statement
- Net worth requirement increased from $50K to $100K
- Added requirement to provide a certified copy of unaudited financial statements for the most recent fiscal quarter
- Adjusted max surety bond amount to $500,000
- Multiple amendments removed 30 day ACN requirement
Managing license amendments for ownership or officer changes
The key to successfully completing any amendment project is to follow the specific procedures outlined by the relevant regulatory authority and the same rule applies for ownership or officer change. Here are a few tips to get your project going:
- Review requirements.
- Create a checklist.
- Keep in mind that even though there are common requirements among regulatory authorities, there are some specific requirements as well, including some specific forms.
- Leverage information already available and previously provided to the regulatory authority.
- Some common requirements for this type of change: ACN (Advance Change of Notice), updated management chart, updated operating agreement, among others.
FS Vector LLC offers a great platform, APPROVED, that assists with amendment projects by providing requirements and tracking status of the process.
Service Spotlight - Government Relations
FS Vector’s government relations team helps businesses of all sizes engage in the federal rulemaking process with our regulatory comment letter services. We provide hands-on support to draft, refine, and submit comment letters that can shape how future regulations are written and enforced.
Participating in the federal notice-and-comment process is one of the most effective ways for organizations to influence policy outcomes. Submitting a thoughtfully developed comment letter provides direct policy influence, strategic insight, and visibility as a credible stakeholder. Our team works alongside clients to ensure their perspectives are clearly represented and contribute to well-informed, effective rulemaking.
Upcoming Comment Deadlines
Several important opportunities to provide input are now open:
- CFTC: Request for Comment on Digital Asset Recommendations and Tokenized Collateral in Derivatives Markets
- Deadline: November 28, 2025
- FinCEN: Request for Comment on Proposed Survey of the Costs of AML/CFT Compliance
- Deadline: December 1, 2025
- OCC & FDIC: Proposals on Material Risks and removal of Reputation Risk from Supervisory Frameworks
- Due 60 days after pending Federal Register publication
- NMLS Proposals for Comment include:
- Request for comments on the proposed business activities and definitions for Issuing Stablecoin and Virtual Currency Kiosk Operation. Comments are due by November 13, 2025.
- A response summary for comments submitted on Proposal 2024-3 proposed changes to the Mortgage Call Report Form Version 7.
FS Vector had a busy and energizing few days at Money20/20 in Las Vegas. We came home inspired by the conversations and momentum across the fintech ecosystem.
- The Treasury Department’s comment period on its Advance Notice of Proposed Rulemaking (ANPRM) to implement the GENIUS Act closed on November 4. This marks an early step in developing a regulatory framework for payment stablecoins, with additional opportunities for public input expected as implementation continues.
- The CFPB is reassessing its approach to open banking by revisiting the final rule to implement Section 1033 of the Dodd-Frank Act. The comment period on the ANPRM closed on October 21, and further opportunities for feedback are expected as the rulemaking process progresses.
To learn more about the federal rulemaking process and explore how we can support your engagement, please contact commentletters@fsvector.com.
FS Vector Calendar
Events FS Vector Licensing Team is attending
- RegList on the Ocean | Nov 4-5 | Huntington Beach, CA - Contact us for a discount code to attend! Tim Lange will be presenting on NMLS changes - the mortgage call report, upcoming disclosure questions, continued phasing of NMLS modernization and more.
- FinTech NerdCon - Nov 19-20 - Miami, FL`
Upcoming FS Vector Webcasts
- FS Vector Licensing Lunch & Learn: Real Talk: Periodic Reporting & CFL - January 28, 2026