Licensing
Licensing Insights: State Exam Updates, Insights from AARMR, Talent Resourcing Spotlight
August 13, 2025
The MTMA and It's Impact on Examinations
The Model Money Transmission Modernization Act (MTMA) is reshaping how regulatory examinations are conducted for licensed money transmitters and fintech companies across the U.S. Developed by the Conference of State Bank Supervisors (CSBS), the MTMA aims to standardize licensing and supervision, making it easier for companies to operate across multiple states with consistent regulatory expectations. To date, more than 30 states have adopted or are in the process of adopting the MTMA.
As part of this effort, states are increasingly coordinating examinations—especially for companies licensed in multiple jurisdictions. This leads to more unified exam standards, reduced regulatory duplication, and greater information sharing between state regulators. Examiners now have a clearer view of a licensee’s internal controls, transaction monitoring, and overall compliance framework, often flagging areas for follow-up across all participating states. For companies, this presents an opportunity to standardize compliance programs, streamline exam preparation, and align more closely with evolving expectations around vendor oversight, recordkeeping, and financial reporting.
Regulatory exams are only becoming more comprehensive. Drawing on decades of experience, FS Vector helps clients prepare for both single-state and multi-state exams—providing the structure, confidence, and insight needed to navigate them successfully.
Insights from AARMR
The 2025 American Association of Residential Mortgage Regulators (AARMR) Conference attendance was the most attended conference in the past 5 years. There was a recurring theme of modernization, the use of artificial intelligence, and collaboration between industry, regulators and CSBS.
Tuesday morning began with the NMLS Ombudsman Meeting where the upcoming NMLS changes were highlighted and discussed. Topics included improvements to the individual application process, a redesigned NMLS Resource Center, and system updates related to disclosure questions and definitions, remote work, unsubmitted filings, and Mortgage Call Report Form Version 7. These system enhancements have been previously covered in the NMLS Modernization Town Halls presented by CSBS. A copy of the July 15 Town Hall recording can be found here.
Overall, company and individual mortgage license applications have been increasing in recent years. That said, staffing continues to be an ongoing issue but state processing timelines have shown improvement. One state shared their success with having examiners handle the initial licensing application review so that feedback is consistent from the beginning.
The remote work section of an individual’s NMLS profile will be added with the September 2025 NMLS release. The state regulators confirmed this new section is not required to be completed for the upcoming license renewal season in fall 2025. Companies will have time in calendar year 2026 to ensure all relevant information is input in this new section. Additional guidance and definitions from NMLS will be forthcoming.
In Quarter 1 of 2026, the NMLS individual (MU2 and MU4) disclosure questions will be updated. Individuals and companies will need to review and update all responses accordingly. As with the other upcoming system updates, NMLS intends to provide additional guidance and definitions, including a cross-reference to the existing disclosure questions.
Several mortgage regulators, including Massachusetts, emphasized a company’s financials and cybersecurity policies are being closely reviewed in the examinations. Additionally, as indicated above, they are leveraging the CSBS’ Baseline Nonbank Cybersecurity Exam Program as a baseline as well as reviewing against their state specific requirements.
Other Licensing News
The Connecticut Department of Banking will be adding two new registrations to the NMLS system effective October 1, 2025. These are the Exempt Mortgage Servicer Registrant (Company) and Exempt Mortgage Servicer Registrant Branch licenses. New applications for these licenses will be accepted through NMLS starting on October 1st.
Service Spotlight: Talent Resourcing
FS Vector serves as a trusted advisor to fintechs and financial services firms looking to innovate and scale. Our close relationship with clients enables us to deeply understand their products, offerings, business objectives, and subsequent staffing needs. From C-suite executives to operations professionals, we connect our clients with highly qualified candidates who seamlessly integrate into their teams on a full-time, interim, or project-based basis. These roles include, but are not limited to:
- Board Members
- Chief Compliance Officers
- Chief Risk Officers
- Chief Technology Officers and CISOs
- GCs and other in-house counsels
- BSA/AML Officers
- AML and KYC Analysts and Investigators
- Complaints Handling Personnel
- Business Development Representatives
- Marketing Managers
- Senior Software Engineers
- UI/UX Designers
- Product Leaders and Managers
Explore more about our Talent Resourcing Services on our website or reach out to us at info@fsvector.com.
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
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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.
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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.