Tier 3 States: Smaller Markets, Still Required
Below the Tier 2 states sits a large cohort of states with smaller populations, less intense financial markets, and less demanding regulatory requirements. These Tier 3 states still require money transmitter licensing, but the application process is typically more straightforward, the timeline is shorter, and the regulatory burden is less intensive. However, the basic requirements remain: you'll file through NMLS, you'll provide financial statements, you'll undergo background investigation, and you'll comply with the state's operating requirements.
7.1 Nevada
Nevada regulates money transmitters through the Department of Financial Institutions under the Money Transmitters Law, found in the Nevada Revised Statutes (N.R.S.) Chapter 643. Nevada is unique because it positions itself as a financial innovation hub and has taken deliberate steps to make its regulatory regime efficient.
Nevada's definition of money transmission is functional. Nevada provides exemptions for licensed banks, for persons acting as agents of a specific payee, and for certain other specific situations.
Nevada's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Nevada accepts reviewed or compiled financial statements, which is less demanding than many states. Nevada has a minimum net worth requirement of twenty-five thousand dollars, one of the lowest in the country.
Nevada's surety bond requirement is also modest, typically fifty thousand dollars or less for smaller operators. Nevada allows the regulator to adjust the requirement based on your business model.
Nevada is known for relatively swift processing. Applications are typically approved within two to three months, assuming the application is complete. Nevada is considered one of the most business-friendly states for money transmitter licensing.
Nevada also allows for a specific type of money transmitter license called a "limited license" for operators with very limited transaction volumes or very specific business models. The limited license has even lower requirements than the standard license.
7.2 Utah
Utah regulates money transmitters through the Department of Financial Institutions under the Money Transmitter Law, found in the Utah Code (U.C.A.) Section 70C-6-101 and following. Utah is home to a growing technology and financial services sector and has a balanced approach to money transmitter regulation.
Utah's definition of money transmission is functional. Utah provides exemptions for licensed banks, for persons acting as agents of a specific payee, and for certain other situations.
Utah's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Utah requires audited or reviewed financial statements. Utah has a minimum net worth requirement of fifty thousand dollars.
Utah's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars depending on your business model.
Utah is known for relatively efficient processing. Applications are typically approved within three to four months. Utah is considered business-friendly for money transmitter licensing.
Utah also has a strong reputation for reasoned regulation and for working collaboratively with licensees on compliance matters.
7.3 Oregon
Oregon regulates money transmitters through the Department of Consumer and Business Services' Division of Finance and Corporate Securities under the Oregon Money Transmitter Law, found in the Oregon Revised Statutes (O.R.S.) Chapter 717.141 and following. Oregon is a growing state with a technology sector and a reasonable regulatory approach.
Oregon's definition of money transmission is functional. Oregon provides exemptions for licensed banks, for persons acting as agents of a specific payee, and for certain other situations.
Oregon's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Oregon accepts audited or reviewed financial statements. Oregon has a minimum net worth requirement of fifty thousand dollars.
Oregon's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars depending on your business model and transaction volume.
Oregon processes applications at a moderate pace, typically within four to six months. Oregon is considered moderately business-friendly.
7.4 Minnesota
Minnesota regulates money transmitters through the Department of Commerce, Division of Banks under the Transmitter Law, found in the Minnesota Statutes (Minn. Stat.) Chapter 45C. Minnesota is a major financial services hub (home to significant banking institutions) and an important market for money transmission.
Minnesota's definition of money transmission is functional. Minnesota provides exemptions for licensed banks and for certain other situations.
Minnesota's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Minnesota requires audited or reviewed financial statements. Minnesota has a minimum net worth requirement of fifty thousand dollars.
Minnesota's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars depending on your business model.
Minnesota processes applications at a reasonable pace, typically within three to five months. Minnesota is considered moderately business-friendly.
7.5 Wisconsin
Wisconsin regulates money transmitters through the Department of Financial Institutions under the Money Transmitter Law, found in the Wisconsin Statutes Chapter 217. Wisconsin is a significant financial services hub and an important market.
Wisconsin's definition of money transmission is functional. Wisconsin provides exemptions for licensed banks and for persons acting as agents of a specific payee.
Wisconsin's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Wisconsin accepts audited or reviewed financial statements. Wisconsin has a minimum net worth requirement of fifty thousand dollars.
Wisconsin's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars.
Wisconsin processes applications at a reasonable pace, typically within four to six months. Wisconsin is considered moderately business-friendly.
7.6 Indiana
Indiana regulates money transmitters through the Financial Institutions Division of the Department of Financial Institutions under the Transmitter of Money Law, found in the Indiana Code (Ind. Code) Section 28-8-1-1 and following. Indiana is a moderate-size financial services market.
Indiana's definition of money transmission is functional. Indiana provides exemptions for licensed banks and for persons acting as agents of a specific payee.
Indiana's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Indiana requires audited or reviewed financial statements. Indiana has a minimum net worth requirement of fifty thousand dollars.
Indiana's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars.
Indiana processes applications at a moderate pace, typically within four to six months.
7.7 Missouri
Missouri regulates money transmitters through the Department of Financial Institutions under the Money Transmitter Law, found in the Missouri Revised Statutes (Mo. Rev. Stat.) Chapter 361. Missouri is a significant financial services hub.
Missouri's definition of money transmission is functional. Missouri provides exemptions for licensed banks and for persons acting as agents of a specific payee.
Missouri's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Missouri accepts audited or reviewed financial statements. Missouri has a minimum net worth requirement of fifty thousand dollars for money transmitters.
Missouri's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars.
Missouri processes applications at a reasonable pace, typically within three to five months.
7.8 Tennessee
Tennessee regulates money transmitters through the Department of Financial Institutions under the Money Transmitter Law, found in the Tennessee Code Annotated (Tenn. Code Ann.) Section 45-7-101 and following. Tennessee is a growing state with an expanding financial services sector.
Tennessee's definition of money transmission is functional. Tennessee provides exemptions for licensed banks and for persons acting as agents of a specific payee.
Tennessee's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Tennessee requires audited or reviewed financial statements. Tennessee has a minimum net worth requirement of fifty thousand dollars.
Tennessee's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars.
Tennessee processes applications at a reasonable pace, typically within four to six months.
7.9 Maryland
Maryland regulates money transmitters through the Department of Financial Regulation under the Money Transmitter Law, found in the Maryland Code, Business Regulation Article Section 12-401 and following. Maryland is a significant financial services hub.
Maryland's definition of money transmission is functional. Maryland provides exemptions for licensed banks and for persons acting as agents of a specific payee.
Maryland's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Maryland requires audited or reviewed financial statements. Maryland has a minimum net worth requirement of fifty thousand dollars for money transmitters.
Maryland's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars.
Maryland processes applications at a reasonable pace, typically within four to six months.
7.10 Connecticut
Connecticut regulates money transmitters through the Department of Banking under the Money Transmitter Licensing Law, found in the Connecticut General Statutes (Conn. Gen. Stat.) Chapter 36a, Section 36a-607 and following. Connecticut is a significant financial services hub.
Connecticut's definition of money transmission is functional. Connecticut provides exemptions for licensed banks and for persons acting as agents of a specific payee.
Connecticut's application process follows the NMLS pathway. You'll submit MU forms, financial statements, and a business plan. Connecticut requires audited or reviewed financial statements. Connecticut has a minimum net worth requirement of fifty thousand dollars.
Connecticut's surety bond requirement typically ranges from fifty thousand dollars to two hundred fifty thousand dollars.
Connecticut processes applications at a reasonable pace, typically within four to six months.