Cassidy Law
MONTH-IN-BRIEF (Sep 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.
