Money Transmission Modernization Act (MTMA)
Money Transmission Modernization Act (MTMA) is a model law from the Conference of State Bank Supervisors. It gives US states one set of standards for licensing and supervising money transmitters.
This page explains the rules in general terms and is not legal or regulatory advice. Check the primary source and take advice on how the rules apply to your firm.
United States: model law approved by the CSBS Board on 9 August 2021. Effective dates vary by state as each legislature enacts it. Per CSBS, at least 31 states had enacted it in full or in part at the time of review; its 8 October 2026 enactments chart lists 35, some not yet in effect.
How it works
The CSBS Board approved the final model on 9 August 2021, after work by regulators and industry experts. It sets a common floor covering stored value, payment instruments and fiat and virtual currency transmission. Each state must enact it through its own legislature. Per CSBS, at least 31 states have enacted it in full or in part; its state enactments chart dated 8 October 2026 lists 35, some with effective dates still to come. Check the current CSBS chart before relying on the count.
According to the CSBS, licensees in at least one adopting state account for 99% of reported money transmission activity. Core provisions cover net worth, surety bonds and permissible investments. Net worth is the greater of $100,000 or a tiered share of total assets. The bond is the greater of $100,000 or average daily liability, with a bracketed $500,000 cap.
Uneven adoption means rules still differ by state. The CSBS notes examiners have applied the law inconsistently and has begun issuing unified implementation guidance. Treasury teams should map each state's enacted version, not the model, when sizing capital and coverage.
Example
Illustrative example: A licensee's average daily money transmission liability in one state over the last three months is $320,000. The model bond is the greater of $100,000 or $320,000, so $320,000. If that liability rose to $700,000, the bracketed cap would hold the bond at $500,000.
Frequently asked questions
Has every state adopted the MTMA?
No. Per CSBS, at least 31 states have enacted it in full or in part, and its state enactments chart dated 8 October 2026 lists 35, some with effective dates still to come. Some adopted only selected sections. Check each state's statute and the current CSBS chart for the version in force.
Does the MTMA cover virtual currency transmission?
Yes, the model's scope includes virtual currency transmission alongside fiat, stored value and payment instruments. How each state applies that scope depends on its enacted text and any separate digital asset laws.
Related terms
Sources
- CSBS Money Transmission Modernization Act (MTMA) · Conference of State Bank Supervisors
- CSBS Releases Model for the Future of Payments Regulation · Conference of State Bank Supervisors
- CSBS Money Transmission Modernization Act (model law text) · Conference of State Bank Supervisors (hosted by NMLS)
- MTMA State Enactments (8 October 2026) · Conference of State Bank Supervisors
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