On February 20, 2019, Evan Minsberg was quoted by Paymentfaciliator.com on new initiatives by the Conference of State Bank Supervisors (CSBS) related to state money transmission regulation.
The article discussed the steps released by the CSBS in regard to its plans to implement feedback from its Fintech Industry Advisory Panel. The CSBS plans to expand the use of the Nationwide Multistate Licensing System to all nonbank industries supervised at the state level. Also among the advisory panel’s recommendations was the need to develop uniform practices across the states, standardizing definitions and procedures for money services business (MSB) licensure. The CSBS said it plans to develop what it called a "50-state model MSB law." The group also recommended forming a working group to "evaluate differences in state MSB prudential requirements and explore harmonization opportunities through regulatory and state legislative action."
Evan commented that the steps the organization has outlined in this announcement would all benefit payment facilitators that are considering applying for money transmitter licenses by clarifying definitions of money transmission and expanding use of the NMLS licensing portal. However, the core issue of each state individually reviewing license applications remains cumbersome.
"At the end of the day, the application review process would continue to be a real hurdle," he said.
Evan also pointed to a related CSBS initiative announced last year, in which 7 states had agreed to accept the others' findings on certain elements of the licensing application. According to a CSBS spokesperson, that initiative has expanded to include 21 states.
"That was a significant step forward which, if adopted nationwide, would absolutely streamline the licensing process, particularly if that level of reciprocity expanded to the majority of the application," Minsberg said.