What is the Money Transmission Modernization Act (MTMA), and which states have adopted it?

The Money Transmission Modernization Act (MTMA) is a model state law, written by the Conference of State Bank Supervisors (CSBS), that gives US money transmitters a single set of standards for net worth, surety bonds, permissible investments and supervision. It does not create a federal license: a company still needs a license in each state where it transmits money, but states that adopt the MTMA ask for the same things in the same way. CSBS reported in September 2026 that 31 states had enacted it in full or in part. CSBS: Money Transmission Modernization Act

For a payments product team, the MTMA matters because it turns licensing from fifty different negotiations into one set of financial and operating requirements, applied state by state.

Why does the US need a model money transmission law?

Money transmission is licensed at state level. A company that moves money for US customers usually also registers with FinCEN as a money services business, but FinCEN is clear that federal registration does not satisfy any state licensing requirement. FinCEN: MSB registration Before the MTMA, each state set its own capital, bonding and investment rules, so a nationwide provider had to meet the strictest version of each and keep evidence in several formats.

CSBS describes the MTMA as a single set of nationwide standards, so that a company licensed in one adopting state meets largely the same requirements in the next. CSBS

What does the MTMA require of money transmitters?

The model law sets the template; each state's enactment is what binds. Several states have adjusted details when adopting it, for example by adding letters of credit as a permissible investment. Always read the enacted statute in the state, not only the model text.

CSBS has also issued interpretive guidance, including on how stablecoins and right-of-use lease assets are treated in the tangible net worth calculation. CSBS: MTMA guidance on stablecoins and lease accounting

Which states have adopted the MTMA?

Adoption is moving, so treat any count as dated:

• CSBS's 2025 annual report said five states enacted the MTMA in 2025, bringing the total to 27. CSBS Annual Report 2025
• CSBS's MTMA page, dated September 2026, reports 31 states with the law enacted in full or in part, and lists pending legislation in Alaska, Louisiana, Maryland, Michigan and Oklahoma. CSBS
• CSBS publishes a state-by-state legislative tracker. Use it, not a blog list, before deciding where to apply first. CSBS: pending and enacted MTMA legislation

"In full or in part" matters. A state that adopted only some sections may still apply its older rules to the rest.

How does the MTMA change a licensing plan?

Consider an illustrative US launch of a cross-border wallet that will hold customer balances and send money abroad:

1. Map the money flow first. Who holds customer funds, who sends the instruction and who settles? That decides whether you are a money transmitter at all, or whether a licensed partner is. See map the money first.
2. Register with FinCEN as a money services business. Registration is filed within 180 days of establishment and renewed every two years; it is separate from state licensing. FinCEN
3. Sequence states by adoption. In MTMA states, one capital, bond and liquidity model can be reused. In non-adopting states, budget for state-specific requirements.
4. Build the liquidity control into the ledger. A 100% permissible-investment requirement is a daily treasury control, not a year-end report: outstanding customer obligations must be calculated and covered continuously.
5. Plan for remittance-specific rules. If you send consumer remittances, the CFPB Remittance Rule and, for cash-funded transfers, the 1% federal excise tax also apply. See the US remittance tax and the CFPB Remittance Rule.

What does the MTMA not do?

• It does not create a single national license. Each state still issues its own.
• It does not replace federal obligations such as FinCEN registration, Bank Secrecy Act compliance or OFAC screening.
• It does not decide whether a particular product is money transmission; state law and regulators do, sometimes through statutory exemptions. Get counsel to read the enacted statute in each state.

FAQ

Is the Money Transmission Modernization Act a federal law?

No. It is a model law written by the Conference of State Bank Supervisors. It only applies in a state after that state enacts it, in full or in part.

How many states have adopted the MTMA?

CSBS reported 31 states with the MTMA enacted in full or in part as of September 2026, up from 27 at the end of 2025. Check the CSBS tracker for the current list.

Do I still need a license in every state if a state adopted the MTMA?

Yes. The MTMA standardizes requirements across adopting states, but each state still licenses money transmitters operating there.

What are the main MTMA requirements?

Tangible net worth that scales with the business, permissible investments equal to 100% of customer funds, a surety bond, standardized control and vetting rules, and common supervision standards.

Is FinCEN registration the same as a money transmitter license?

No. FinCEN registration as a money services business is a federal requirement, and FinCEN states that it does not satisfy state licensing requirements.