PART TEN: BUILDING AND SCALING A LICENSED MTO Chapter 33

The Business Model for a Licensed Money Transmitter


A money transmitter founder approaches me with a business plan. The plan projects that the business will process ten million dollars in monthly transaction volume within three years. The plan assumes a revenue margin of two percent on transaction volume, generating twenty thousand dollars in monthly revenue. The founder has calculated that this revenue is sufficient to sustain the business.

I ask a simple question: once the business is licensed and operational, what will your monthly operating costs be? The founder has not calculated this. Once we work through the numbers, we discover that monthly operating costs will be approximately thirty thousand dollars. The business will be running a monthly loss of ten thousand dollars.

This is the most common mistake in money transmitter business planning: confusing revenue with sustainable revenue, and failing to account for the actual cost structure of the business.

Revenue Models in Money Transmission

Money transmitters generate revenue through several mechanisms. The most common is a fee on transactions. A customer sends a remittance, and the money transmitter charges a fee—either a fixed amount (two dollars per transaction) or a percentage of the transaction amount (two percent of the transfer amount).

A second revenue mechanism is foreign exchange spread. When a customer sends dollars to Mexico and receives pesos, the money transmitter converts the dollars to pesos. The money transmitter can earn revenue by taking a spread on the exchange rate. If the wholesale FX rate is 17 pesos per dollar, the money transmitter might offer customers 16.8 pesos per dollar, retaining 0.2 pesos per dollar as revenue.

A third revenue mechanism is investment of float. While a customer's money is in transit before being paid out, the money transmitter has access to that money. The money transmitter can invest the float in overnight investments—money market accounts, reverse repurchase agreements, Treasury bills. The float generates interest income.

A fourth revenue mechanism is payout partnership arrangements. If the money transmitter owns the payout infrastructure, the money transmitter can earn revenue from fees paid by other money transmitters who use the payout infrastructure.

In the context of money transmitter operations, the fee mechanism and the FX spread mechanism are the primary revenue sources. Float investment and payout partnerships are secondary.

Cost Structure Breakdown

The cost structure of a money transmitter is more complex than most founders realize.

Regulatory compliance costs are substantial. To be licensed, the money transmitter must obtain a license in each state where it operates. Licensing costs vary, but for a money transmitter licensing in ten states, the annual licensing and examination costs might total fifty thousand to one hundred thousand dollars per year. Additionally, the money transmitter must maintain a compliance officer, which costs sixty thousand to one hundred twenty thousand dollars per year depending on the market and the experience level of the officer. The money transmitter must conduct due diligence and maintain customer files, which requires people and systems. The money transmitter must conduct suspicious activity monitoring and file SARs, which requires people and systems.

Banking costs are substantial. The money transmitter needs banking relationships to maintain customer deposits and to conduct settlement with payout partners. Banks that serve money transmitters charge higher fees than banks that serve traditional businesses. A money transmitter might pay monthly banking fees of one thousand to five thousand dollars, and these fees increase as transaction volume increases.

Technology costs are substantial. The money transmitter needs a transaction system to accept customer transactions, to calculate fees, to execute settlement with beneficiaries. The money transmitter needs a customer information system to maintain customer records. The money transmitter needs a compliance system for transaction monitoring and SAR filing. If the money transmitter operates a digital channel (mobile app, website), the money transmitter needs to maintain and update that application. These systems might be purchased from vendors, or the money transmitter might build systems internally. Either way, the cost is substantial. A licensed money transmitter might spend fifty thousand to two hundred fifty thousand dollars annually on technology, depending on the sophistication of the systems.

Payout costs are the largest cost in most money transmitter operations. To deliver money to beneficiaries, the money transmitter must either own payout infrastructure or must pay payout partners to deliver the money. If the money transmitter sends money through a correspondent bank, the correspondent bank charges fees. If the money transmitter works through independent agents in the destination country, the money transmitter pays the agents a portion of the revenue. These costs typically consume fifty to eighty percent of the transaction fee revenue.

Personnel costs are substantial. In addition to the compliance officer, the money transmitter needs customer service staff to handle customer inquiries, settlement staff to manage the settlement process with payout partners, and back-office staff to maintain records. A money transmitter with a modest operation might need five to ten staff members. The annual payroll for five staff members might be two hundred fifty thousand to four hundred thousand dollars.

Marketing and customer acquisition costs should be budgeted. A money transmitter cannot rely on customers finding the business organically. The money transmitter must engage in marketing—digital marketing, partnerships, referrals. These costs might be one to three percent of revenue.

Legal and consulting costs are substantial during the first few years of operation. The money transmitter will need to engage lawyers to interpret regulations, to manage regulatory relationships, and to handle any enforcement matters. The money transmitter might engage compliance consultants to design and implement the compliance program. These costs are highest in the first year and decline over time.

Margins by Corridor and Product Type

Margin economics vary substantially by corridor.

Remittances to countries with strong payout infrastructure and low political and AML risk—corridors like Mexico, the Philippines, India—have lower margins because competition is intense and payout costs are lower. A typical margin on a Mexico remittance might be one to two percent.

Remittances to countries with weaker payout infrastructure and higher AML risk—corridors like parts of Africa, the Middle East, South Asia—have higher margins because competition is lower and payout costs are higher. A typical margin might be five to ten percent.

Corridors that involve less common destination countries or complex payout arrangements—corridors involving multiple transfers, payment to non-bank entities, or delivery in countries with currency controls—have higher margins, sometimes ten to twenty percent or higher, because they require more expertise and because few money transmitters operate in those corridors.

These margin differences create an important strategic choice for a money transmitter: compete on volume in low-margin corridors, or compete on expertise and relationships in high-margin corridors.

Many money transmitter founders target high-margin corridors because the math appears better. If you can earn a ten percent margin on a thousand dollars in transactions, that is one hundred dollars of revenue. If you must earn a one percent margin on the same amount of transactions in a low-margin corridor, you earn only ten dollars. But high-margin corridors have problems: they typically have fewer customers, require deeper expertise, and involve higher compliance risk.

A money transmitter that can process ten million dollars per month in low-margin corridors will be more profitable than a money transmitter that can process one million dollars per month in high-margin corridors, because the volume advantage offset the margin disadvantage.

Volume Economics: When Does the Business Become Profitable?

A money transmitter becomes profitable when revenue exceeds total operating costs.

Let's work through a model. Assume a money transmitter is licensed in five states. Assume the licensing and compliance costs are seventy-five thousand dollars per year, or approximately six thousand dollars per month. Assume the banking fees are three thousand dollars per month. Assume the technology costs are ten thousand dollars per month. Assume the personnel costs are thirty thousand dollars per month. Assume the legal and consulting costs are five thousand dollars per month. Total monthly operating costs: fifty-four thousand dollars.

Now assume the money transmitter charges an average fee of one percent of transaction volume, but must pay fifty percent of that fee to payout partners and must budget five percent for marketing. Net margin available to cover operating costs: forty-five percent.

To break even, the money transmitter must generate monthly revenue of approximately one hundred twenty thousand dollars. At a one percent fee, this requires monthly transaction volume of twelve million dollars.

This is a substantial volume requirement. To put this in perspective, a money transmitter with fifty employees processing remittances might process this volume. A small money transmitter with five employees will not process this volume.

This is why many money transmitter startups fail. They underestimate the volume required to break even. They achieve profitability only when they reach significant scale. And many money transmitters do not reach that scale.

Capital Requirements for Sustained Operations

A money transmitter requires capital for several purposes. First, capital is required to fund the regulatory process. Obtaining licenses, conducting examinations, engaging lawyers and compliance consultants—these activities cost money before the business generates any revenue.

Second, capital is required to fund the float. Many money transmitters operate on a model in which customers deposit money before the money transmitter remits to the beneficiary. The money transmitter must maintain sufficient cash on hand to cover the deposits. If a money transmitter processes ten million dollars in monthly volume, and the typical customer deposits five hundred dollars, and the average transaction is outstanding for two days before being settled, the money transmitter must maintain approximately one hundred thousand dollars in float. The larger the operation, the larger the float requirement.

Third, capital is required to fund the operational loss before the business reaches profitability. If the money transmitter requires twelve million dollars in monthly transaction volume to break even, and the money transmitter is currently processing three million dollars per month, the business is running at a monthly loss. The business must have capital to fund this loss until it reaches profitability.

A money transmitter starting from scratch might require five hundred thousand to two million dollars in capital, depending on the scope of the initial operation, the speed of customer acquisition, and the time required to reach profitability.

This capital requirement is substantial, and it is one of the largest barriers to entry in the money transmitter industry. Many entrepreneurs have good ideas for money transmitter businesses but cannot raise the capital required to get the business off the ground.

The Difference Between Revenue and Sustainable Revenue

I noted at the beginning of this chapter that many founders confuse revenue with sustainable revenue. This confusion is dangerous because it can lead to a false sense that the business is viable when it is actually unsustainable.

Revenue is the money that flows through your business. If a customer sends a thousand dollars through your money transmitter, that is a thousand dollars of revenue in the sense that the money flows through your system. But your net revenue—the amount you retain—might only be ten dollars (one percent fee) or even five dollars if you must pay payout partners and marketing costs.

Sustainable revenue is the money you actually keep, after paying all of your costs. If your net revenue is five dollars per thousand dollars of transaction volume, then to sustain an operation with fifty thousand dollars in monthly costs, you must process ten million dollars in monthly transaction volume.

Many founders think about this incorrectly. They think: if we process one million dollars in the first month, we will earn ten thousand dollars in revenue. In reality, after paying payout partners and marketing costs, they might earn only three thousand dollars in net revenue, which is insufficient to cover fifty thousand dollars in operating costs.

Common Business Model Mistakes

The most common mistake is underestimating the cost of compliance. Founders often think that the cost of compliance is the cost of hiring a compliance officer. In reality, compliance is a cost that is embedded throughout the organization: due diligence activities, monitoring, internal audit, regulatory reporting, response to regulatory examinations.

A second common mistake is overestimating margins. Founders often assume they can achieve margins that are higher than market. If the market margin is one percent, overestimating that you will achieve two percent is a costly error.

A third common mistake is underestimating the cost of customer acquisition. Founders often assume that customers will be easy to find and that customer acquisition will be inexpensive. In reality, customer acquisition requires marketing investment, partnerships, and time.

A fourth common mistake is not accounting for the seasonal nature of remittance flows. Remittances are seasonal. Around holidays and harvest times, remittance volumes spike. Outside of these periods, volumes decline. Founders often plan their operations based on average volume and then discover that during low-volume periods, the business is unprofitable.

A fifth common mistake is overestimating the speed of achieving scale. Founders often assume that they will achieve profitability within one to two years. In reality, most money transmitters take three to five years to reach profitability, if they reach it at all.

Case Study: Building a Viable MTO from Scratch

A founder wants to build a licensed money transmitter focused on remittances from the United States to Latin America. The founder has identified an underserved corridor and believes he can differentiate based on service quality and customer service.

The founder begins by raising capital. He determines that he needs one million dollars to fund the business through profitability. He approaches family office investors and pitches the opportunity. After a year of pitching, he raises the million dollars.

The founder then incorporates a company and begins the licensing process. He files applications in Texas, California, and New York. The process takes approximately six months and costs one hundred thousand dollars. During this period, he is hiring staff: a compliance officer, a technology consultant, and a customer service representative.

Once licensed, the founder launches his service. He partners with a payout provider in Latin America who agrees to deliver remittances to beneficiaries. He sets up banking relationships with a bank that serves money transmitters. He develops a simple website where customers can send money.

In the first month of operation, he processes one hundred thousand dollars in transaction volume. In the second month, two hundred thousand dollars. In the third month, three hundred thousand dollars. He is acquiring customers through partnerships with community organizations and through word of mouth from early customers.

Six months into operation, he is processing five hundred thousand dollars per month. At this volume, with a one percent fee and a fifty percent payout cost, he is generating twenty-five hundred dollars per month in net revenue. His monthly operating costs are approximately forty thousand dollars. He is running a monthly loss of thirty-seven thousand five hundred dollars.

He realizes he has a problem. At this growth rate, it will take him years to reach the twelve million dollars in monthly volume required to break even. And his capital will run out in approximately two years. He will not reach profitability before his capital is exhausted.

The founder makes a strategic decision. He cannot compete in the Mexico corridor on service quality. He must find a higher-margin corridor. He identifies a corridor to a smaller country in Central America where existing competitors are limited. In this corridor, he can achieve a five percent margin instead of a one percent margin. The margin is higher but the market is smaller.

He reallocates his resources. He maintains his Mexico operation but does not aggressively market it. He focuses on building the Central America corridor. In the Central America corridor, he partners with local agents who agree to distribute his service. He travels to the destination country and builds relationships with agents.

After another six months, he is processing one hundred thousand dollars per month to Central America. At a five percent margin with a fifty percent payout cost, he is generating two thousand five hundred dollars per month in net revenue on this volume. Combined with his Mexico operation, his net revenue is approximately four thousand dollars per month, and his operating costs are now thirty-five thousand dollars per month (he has slowed hiring). He is still running a significant loss.

But his growth rate has changed. The Central America corridor is growing faster than the Mexico corridor. He projects that within two years, he will have ten million dollars in annual volume in the Central America corridor alone. At that volume, he projects profitability.

The founder makes another strategic decision. The business cannot be purely remittance-based. He is going to launch a service that allows businesses to make international payments. He partners with a payroll processor, and he offers the payroll processor's clients the ability to pay international workers through his platform. This service has a lower margin than remittances but higher volume potential.

With this business line added, his projections change. He projects that within three years, he will reach profitability. He goes back to his investors and explains the strategy. The investors agree that the strategy is sound, and they agree to provide an additional five hundred thousand dollars in funding to extend the runway until profitability.

The business eventually reaches profitability in year four. The founder has learned several important lessons: he underestimated the cost of compliance and the cost of customer acquisition; he had to shift strategy from high-volume low-margin business to lower-volume higher-margin business; he had to diversify revenue sources to achieve sufficient volume for profitability; he had to extend his fundraising timeline because his original assumptions about growth rate were too optimistic.

Practitioner's Bottom Line

Money transmitter business models require reaching substantial transaction volume to achieve profitability—typically ten million dollars per month or more for a basic operation. Sustainable revenue is the money you keep after paying payout partners and marketing costs, not the transaction volume flowing through your system. Most money transmitter businesses do not reach profitability in two years, requiring three to five years and significant capital investment before generating profit.


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