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Comments: MSB Model Law

As part of CSBS’s Vision 2020, state regulators have committed to adopting an integrated, 50-state licensing and supervisory system that recognizes standards across state lines. One of the primary areas for Vision 2020 is state regulation of money services businesses. For much of the past year, CSBS and a working group of state volunteers have been developing model language for money services businesses ("MSBs") laws. CSBS is happy to announce that a draft version of the language is now ready for public consideration.

State regulators are committed to a transparent and inclusive approach to developing MSB policy. CSBS requests public comment on the Draft Model Language and seeks feedback on specific questions that will help inform state regulators as we continue to streamline MSB regulation. All comments will be made available at CSBS reserves the right to reject comments with inappropriate content.

Comments Submitted

Company Comment Letter Link
Blackhawk Link [PDF]
Electronic Transactions Association Link [PDF]
Financial Innovation Now Link [PDF]
Hunton Andrews Kurth Link [PDF]
Mastercard Link [PDF]
Mezu (N.A.), Inc. Link [PDF]
Morrison Foerster Link [PDF]
National Consumer Law Center/Consumer Reports Link [PDF]
Netchex Link [PDF]
Third Party Payment Processors Association Link [PDF]
Transferwise Link [PDF]
Remitly Link [PDF]

Due Date

Comments were requested on the Draft Model Law Language for MSBs by November 1, 2019


The materials for public consideration are as follows:


Contact Information

For questions, please email [email protected]