Current Month (September 2026)
CSBS Launches and Formalizes Money Transmission Modernization Act Guidance Request Intake Process
By Rachael Aspery and Amy Greenwood-Field, Womble Bond Dickinson (US) LLP
On September 3, 2026, the Conference of State Bank Supervisors (“CSBS”) introduced a formal guidance request process creating a centralized mechanism for industry participants to seek clarification on Money Transmission Modernization Act (“MTMA”) requirements and implementation. The new formal process is intended to address inconsistencies arising from varying state adoption and interpretation of the MTMA and to promote more uniform application of the law across adopting jurisdictions.
What Is New
CSBS announced that stakeholders may now submit requests for MTMA implementation guidance through a dedicated online intake form. CSBS explained that while more than half of the states have adopted the MTMA in full or in part, differences in implementation and interpretation have emerged as states operationalize the law. To encourage consistency, CSBS, working with member regulators and oversight committees, established an intake and deliberation process for MTMA-related guidance requests with the goal to provide unified, consistent MTMA implementation guidance.
The new submission portal effectively functions as a public “intake button,” providing money transmitters, industry participants, and other stakeholders with a formal channel to raise interpretive questions and identify areas where greater regulatory clarity regarding state MTMA adoption may be needed. CSBS notes that not every request will result in published guidance, although staff intends to respond to submissions and communicate next steps.
Why It Matters
The MTMA was designed to establish a more uniform framework for state money transmission regulation, including standards relating to net worth, surety bonds, and permissible investments. Currently, CSBS reports that as of August 2026, thirty-five states have enacted the law in full or in part and that licensed entities operating in at least one state that has adopted the MTMA account for approximately 99% of reported money transmission activity.
Despite this progress, implementation questions continue to arise as states adopt and apply the model law. The new formal guidance request process is noteworthy because it provides an avenue for industry participants to proactively seek clarification before differing state interpretations become entrenched. If used regularly by regulators and the industry, the process could help reduce compliance uncertainty and improve consistency across MTMA jurisdictions.
Potential Areas for Guidance Requests
The new formal intake process should prove to be particularly useful where the MTMA’s provisions intersect with evolving business models or emerging products. CSBS previously published uniform guidance with respect to MTMA implementation surrounding calculation of the net worth of a money transmitter, specifically the topics of: (1) Tangible Net Worth and Virtual Currency, (2) Right of Use Leases, and (3) Stablecoin Tangibility, but additional implementation pain points remain. Companies may consider submitting requests involving:
- permissible investment requirements;
- net worth and financial condition standards;
- treatment of novel payment products;
- application of MTMA provisions to digital asset activities;
- examination expectations and supervisory processes; and
- questions where multiple adopting states have taken differing compliance approaches.
Because guidance issued through this formal process could influence supervisory expectations across multiple jurisdictions, industry participants should closely monitor published MTMA implementation guidance that results from review of submitted topics.
