On February 6, the Conference of State Bank Supervisors
("CSBS") announced that seven states have entered into a
compact that should streamline the process of applying for state
money transmitter licenses.
Moving forward, the participating states– Georgia,
Illinois, Kansas, Massachusetts, Tennessee, Texas, and Washington
– will accept each other's findings regarding certain
"key elements of state licensing." The "key
elements" include IT, cybersecurity, business plan, background
check, and compliance with the federal Bank Secrecy Act.
If the compact works as planned, a company that has obtained a
money transmitter license from one of the compact states will be
able to obtain a license from any other compact state without the
delay and expense of duplicative review and approval requirements,
at least as to the "key elements" outlined above.
