On September 15, the Conference of State Bank Supervisors (CSBS)
announced that money transmitters operating in 40 or more states
will be able to take advantage of a new, comprehensive exam
designed to satisfy all state money transmitter examination
requirements in 2021. Per the CSBS, this "one company, one
exam" program, known formally as "MSB Networked
Supervision," applies to "78 of the nation's largest
payments and cryptocurrency companies that currently meet the
40-state threshold."
Through this program, the CSBS, an organization composed of
regulators from all 50 U.S. states, Washington D.C., Guam, Puerto
Rico, American Samoa, and the U.S. Virgin Islands, allows money
transmitters who reach the 40-state threshold to replace
state-by-state examinations with a single exam that will satisfy
all state requirements. Under the program, a single state will lead
the exam and, in doing so, will use a group of examiners selected
from around the country.