Licensing
Licensing Insights: Phased Licensing Rollout, MA MTL Transition, ME MTL Transition to ESB, Webcasts & Calendar
September 10, 2025
How to Structure a Phased Licensing Rollout (and Avoid Costly Mistakes)
When managing a licensing project involving 10 or more applications, it is often best to use a phased approach. This method streamlines the process, which is especially useful because license applications often require input and documentation from multiple departments. A phased rollout helps set clear expectations for submission timelines and reduces the risk of submitting incomplete applications.
Submitting incomplete applications can cause major setbacks. Regulators vary in how they handle deficiencies, but if key requirements are missing and cannot be provided within the required timeframe, the application may be withdrawn. In that case, the company must restart the process and pay all associated application fees again.
When prioritizing licenses in a phased rollout, consider two key questions:
1. Which licenses are most critical to the business?
2. How quickly can the required documentation be provided for each license?
If high-priority licenses also have simple documentation requirements, begin the rollout there. However, if they involve complex or time-consuming documentation, it may be more effective to begin with licenses that have fewer or simpler requirements. These early wins lay the groundwork for future applications—including high-priority ones—and help keep the overall project moving efficiently, while avoiding the costly setbacks of incomplete submissions.
MA Money Transmitter License (MTL) Transition to NMLS Begins Nov. 1, 2025; Requirements effective January 1, 2026
The Massachusetts Division of Banks will begin licensing and regulating money transmitters under MGL c. 169B on January 1, 2026.
As part of the money transmitter statutory framework adjustments made in 2024, Massachusetts will convert existing Foreign Transmittal Agency and Check Seller licensees to a new Money Transmitter license type during the 2025 renewal cycle.
Any licensee in good standing will be required to submit a license transition request through the Nationwide Multistate Licensing System (NMLS) beginning November 1, 2025. The transition will align license holders under the newly created Money Transmitter License.
Importantly, the NMLS transition checklist will differ from prior renewal requirements, reflecting the updated standards under the Money Transmitter framework. Additional details on the process are expected to be made available in mid-September. For more information, view the Massachusetts FAQ document.
Domestic entities not currently licensed under the Foreign Transmittal Agency and/or a Check Seller will be required to file an application for a money transmitter license on or before July 1, 2026. Failure to do so will result in an interruption to business activity unless and until the MTL is granted.
FS Vector helps financial services companies navigate licensing, compliance, and regulatory changes. For more information on how we can assist, contact us here.
Maine Money Transmitter License - Transition to Electronic Surety Bonds; must be complete before 1/31/2026
Maine is transitioning to the Electronic Surety Bond (ESB). Entities licensed in ME must transition from a paper bond to the ESB as a condition of renewal. ESB conversion is suggested before 11/1/2025 to expedite the renewal process, but must be complete before 1/31/2026. Any company requesting renewal that has not transitioned/converted to the ESB before 12/31/2025 will be placed "on hold" and will only be renewed once the conversion to the ESB is complete.
The ESB covers all locations, but may need to be increased from the base coverage amount depending on whether or not the company has multiple locations. Please refer to the Licensing Requirements and Fees Chart and the specific license type checklist for details. Please contact your insurance carrier to start the transition from the paper bond to the ESB. More information on the ESB is also available on the NMLS Resource Center.
FS Vector Calendar
Events FS Vector Licensing Team is attending
- MTRA | Sep 8-11 | Louisville, KY
- Tim Lange (Drawing the Line Between Innovation and Regulation) and Emily Goodman (Shifting Gears: As Federal Regulators Take a Back Seat, State Regulators are the Stars of the Regulatory Show: What impact will these changes have on MSBs?) will be featured panelists at this year’s conference.
- Money20/20 | Oct 26-29 | Las Vegas, NV
- RegList on the Ocean | Nov 4-5 | Huntington Beach, CA
Upcoming FS Vector Webinars
- FS Vector Licensing Lunch & Learn: Approved System Overview - September 17, 2025
APPROVED™: License Management Made Simple
Join FS Vector for an inside look at APPROVED™, our end-to-end automated licensing technology platform built by licensing pros for licensing pros. Discover how APPROVED™ simplifies license management across all jurisdictions, from application reporting, to renewal, while providing real-time visibility into regulatory obligations.
In this webinar, you’ll learn how our platform:
- Tracks more than 40,000 license requirements (NMLS and non-NMLS) from over 500 agencies nationwide.
- Automates updates and reminders to keep your team ahead of deadlines.
- Integrates with NMLS for seamless data flow.
- Enhances collaboration with task management, document storage, and reporting tools, all in a secure cloud environment.
Whether you’re a fintech startup or an established nationwide licensee, see how APPROVED™ can reduce manual work, cut costs, and help you stay compliant with confidence.
- FS Vector Licensing Lunch & Learn: 2026 NMLS Renewals Prep for Success - October 8, 2025
2026 NMLS Renewals Prep for Success
With autumn approaching, it's time to start preparing for the NMLS renewal season.
To help you navigate the NMLS Renewal Season with confidence, we invite you to join our upcoming session. We'll discuss essential strategies and practical tips to ensure you're fully prepared for a smooth and successful renewal.
- FS Vector Licensing Lunch & Learn: Real Talk: Real Estate Licensing & More - November 15, 2025
- Overview and registration link coming soon!