Licensing
Licensing Insights: State MTL Updates, Join us at AARMR Reception & Headmaster™ Spotlight
July 30, 2025
State Money Transmission Regulatory Updates
Georgia Final Rule Making Money Transmission Effective July 7, 2025
The Georgia Department of Banking and Finance recently provided clarity related to the definition of service providers as well as restrictions related to sanctioned activities. It is highly likely other states will adopt Georgia-style definitions or closely aligned language around service providers in money transmission regulation, especially under the broader push for uniformity and modernization through the Model Money Transmission Modernization Act (MTMA).Per Georgia’s June 18, 2025 release: for avoidance of doubt, material services include any services that: (1) require access to consumer funds, consumer account data, or personally identifiable information of consumers; or (2) grant the service provider rights, abilities, or other access to modify, create, delete, or otherwise alter such data or information, regardless whether such rights are limited, restricted, monitored, or otherwise controlled by the licensed money transmitter.
The final rule also provides language regarding restrictions around what a service provider can and cannot do (i.e., service providers cannot conduct money transmission on behalf of the licensee or present themselves in that way unless licensed or exempt under Georgia law). Georgia also set forth oversight expectations that a licensee is responsible for providing such evidence during a routine examination (e.g., contracts, fees, reports, financials, and more)
FS Vector can assist clients to ensure overall ‘exam readiness’ in this regard by conducting a mock examination and/or gap assessments to proactively identify compliance risks and ensure companies are well-positioned to demonstrate full compliance with Georgia’s new standards and any similar regulations adopted in other states.
Link to GA DBF - click here
Nebraska Implements MTMA Effective October 1, 2025
Nebraska Governor Jim Pillen signed Legislative Bill 474 (LB 474) into law on May 20, 2025, updating the Nebraska Money Transmitters Act. The legislation takes effect on October 1, 2025, and introduces key changes designed to align Nebraska’s framework with national standards, incorporating model language from the Conference of State Bank Supervisors (CSBS).
Key changes include:
- Updated Definitions: Clarifies terms such as “in this state,” “multi-state licensing process,” and “average daily money transmission liability.”
- Exemptions: Codifies exemptions for registered futures commission merchants, broker-dealers, and certain third-party service providers.
- Permissible Investments: Expands investment options with limits based on risk profile.
- Financial Requirements:
- Raises minimum net worth to the greater of $100,000 or a tiered percentage of assets.
- Increases surety bond cap from $250,000 to $500,000.
- Fee Increases: Application fee raised to $1,500; renewal fee increased to $750; a $1,500 change-of-control fee added.
The full text of LB 474 is available here.
FS Vector can assist clients in reviewing these updates and assessing licensing, compliance, and operational impacts. Please contact us for support in addressing the updated requirements.
Connecticut Updates Money Transmission Law to Cover Digital Wallets and Virtual Currency Effective October 1, 2025
Revisions to Connecticut’s money transmission statutes impacting digital asset activities were enacted on June 30, 2025. The new law, effective October 1, 2025, updates definitions, expands consumer protections for virtual currency users, and imposes new restrictions on the state’s ability to use digital assets. The new law modernizes Connecticut’s money transmission law to address digital asset activity and licensing.
Key provisions impacting the digital asset space are:
- Expansion of covered activities to digital wallets and mobile apps.
- One-to-one reserve and custody requirement for virtual currency. Licensees must hold the same type and amount of virtual currency as owed to customers and treat those assets as trust property shielded from creditor claims.
- Disclosure and receipt obligations for virtual-currency transactions
- Restriction on unapproved third-party custodians
- Prohibition on state acceptance or investment of virtual currency.
The full text of House Bill 7082 is here.
Service Spotlight: Headmaster
Headmaster™️ is FS Vector’s proprietary training platform designed specifically for fintechs. Compliance and risk management training doesn’t need to be a thing that employees detest. With Headmaster, we’ve made trainings relevant, accurate, and role-specific while keeping it simple to use.
The platform offers all core functionality needed for companies to develop and administer their compliance training program:
- Courses/content on key compliance concepts ranging from risk management, information security, and business continuity to courses on specific regulatory requirements (e.g., UDAAP, EFTA/Reg E, TILA, TISA, etc.)
- Tracking ability to pull reports on training assignments and completion to document compliance with your company’s established training program
Banking partners, regulators, and examiners expect any institution offering a financial product to offer a robust training program tailored to the institution's funds flows and regulatory obligations. The Headmaster team will work with your company to ensure you meet all your training program obligations:
- Assist in developing your training plan
- Provide an easy-to-use platform for assigning, completing, and tracking completion of training courses
Explore more about Headmaster on our website or reach out to us at headmaster@fsvector.com.
FS Vector Calendar
Events FS Vector Licensing Team is attending
- American Association of Residential Mortgage Regulators | August 5-7 | Fort Worth, TX
- You're invited! Join us during AARMR’s 35th Annual Conference for a reception at Tannahill’s Tavern & Music Hall! Enjoy an evening of live music, craft cocktails & mocktails, delectable bites and great conversation in Fort Worth’s Stockyards Historic District.
- RSVP now - Space is limited!
- 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: Real Estate Licensing in 2025 - What's New and What You Need to Know | August 13, 2025
- FS Vector Licensing Lunch & Learn: Approved System Overview | September 17, 2025