Key Regulatory Contacts by State

This appendix provides guidance on how to identify and contact money transmitter regulators in each state. Regulatory agencies change names, reorganize, and move offices periodically. Rather than providing specific contact names (which become outdated), this appendix explains how to find current contacts.

How to Find Your State Regulator

1. Go to your state's official website (secretary of state, attorney general, or banking/financial department).
2. Search for "money transmitter" or "money services business."
3. Look for a section on financial regulation or consumer protection.
4. The agency responsible for money transmitter licensing is usually one of:
5. Secretary of State (many states)
6. Department of Banking or Financial Institutions
7. Department of Commerce
8. Department of Financial Regulation or Financial Services

9. Consumer Affairs Department

10. Contact the relevant agency's licensing or registration department directly.

General Regulatory Structure by State

States where the Secretary of State regulates money transmitters: Alabama, Arkansas, Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Michigan, Mississippi, Missouri, Montana, North Carolina, North Dakota, Ohio, Oklahoma, Tennessee, West Virginia, Wyoming.

States where a dedicated banking department regulates: Arizona, California, Colorado, Connecticut, Delaware, Florida, Hawaii, Idaho, Maine, Maryland, Massachusetts, Minnesota, Missouri, Nevada, New Hampshire, New Jersey, New Mexico, New York, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Texas, Utah, Vermont, Virginia, Washington.

States with Department of Financial Institutions or similar: Alabama, Alaska, Arizona, Arkansas, Colorado, Florida, Georgia, Hawaii, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Montana, Nevada, New Mexico, North Dakota, South Carolina, South Dakota, Tennessee, Utah, Vermont, West Virginia, Wyoming.

States with combined consumer protection and banking functions: Connecticut, Maine, Massachusetts, Minnesota, New Jersey, New York, Oregon, Pennsylvania, Rhode Island, Texas, Washington.

Key Information to Provide When Contacting a Regulator

When you contact your state regulator, be prepared to provide: - Your business legal name - Your MSB registration number with FinCEN - Your principal place of business address - The types of money services you will provide - States where you will operate (if applicable) - Whether you will use agents - Your compliance contact information (compliance officer or attorney)

What to Ask the Regulator

1. Do I need a license to operate in this state? (The answer is almost certainly yes if you're transmitting money.)
2. What are the current application requirements and forms?
3. What is the current application fee?
4. What is the renewal fee and renewal timeline?
5. What bonding requirements exist?
6. What net worth or capital requirements exist?
7. How long is the typical licensing timeline?
8. What compliance documentation must I submit?
9. Are there any recent guidance documents or FAQs I should review?
10. Who is my assigned examiner or contact person for licensing questions?

Timeline for Getting Answers

Most state regulators will respond to inquiries within 5-10 business days. Some have dedicated licensing staff who can answer questions quickly. Others may route you through a general inquiry line and take longer.

Cost-Effective Approach

Do not contact all 50 state regulators individually if you're just starting. Focus on: 1. The state where your principal place of business is located (required) 2. States with high population or high transaction volume for your business 3. States that are geographically strategic for your operations

Once you have 5-10 states licensed, you'll have a better sense of what regulators are looking for across different states.

Regulatory Associations and Resources

Several organizations track money transmitter regulation and can provide guidance: - Money Transmitter Regulators Association (MRTA): An association of state and federal regulators. Their meetings are sometimes open to industry. Members' contact information is public. - Conference of State Banking Supervisors (CSBS): Represents state banking regulators. Publishes guidance on interstate financial services. - FinCEN: Provides general guidance but does not regulate states. FinCEN's website has links to state regulators. - American Bankers Association (ABA): Publishes regulatory updates and compliance guidance. - Independent Community Bankers of America (ICBA): Represents smaller financial institutions and provides regulatory resources.

Dealing with Unresponsive Regulators

Some state regulators are more responsive than others. If a state is unresponsive: - Contact the state's licensing board secretary or administrative office - Escalate to the agency director's office - File a FOIA request for public records on licensing procedures - Consult with a state-licensed attorney in that state - Consider engaging a regulatory consultant who has relationships with the regulator

Federal Regulatory Contacts

For federal matters: - FinCEN: fincen.gov, (800) 949-2732 - Office of the Comptroller of the Currency (OCC): occ.gov - Federal Reserve: federalreserve.gov - FDIC: fdic.gov - Commodity Futures Trading Commission (CFTC): cftc.gov (for crypto derivatives) - Securities and Exchange Commission (SEC): sec.gov (for securities-like products)

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