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Request for 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.

CSBS encourages commenters to provide actionable language and redline edits to the proposed language. 

Following the comment period, CSBS will continue the policy-making process with a focus on the most impactful measures for Vision 2020. Depending on feedback received, this may involve finalizing less controversial issues before standardizing more complex matters.

Comments may be submitted by any of the following methods:

Email Comments

Send comments via email to Preferred file format is PDF (Portable Document Format).

Paper Comments

Send paper comments to:

Attn: MSB Model Law
Conference of State Bank Supervisors
1129 20th Street NW, 9th Floor
Washington, D.C. 20036

Due Date

Comments are requested on the Draft Model Law Language for MSBs by November 1, 2019. CSBS acknowledges this is a short comment period and commits to working with interested parties that may seek additional time or forums to share their input.


The materials for public consideration are as follows:


Contact Information

For questions, please email