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Comments Requested (Round 2): 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. Last year, CSBS requested comment on MSB model law language focused on four issue areas identified by the Fintech Industry Advisory Panel – Control, Activity and Exemption Definitions, Safety & Soundness, and Supervision.

To finalize the areas of Control and Supervision, CSBS seeks a second round of comments on updates based on the 2019 comments. Because the language is narrowed to less controversial issues and mostly adopted from industry comments, CSBS requests all comments by COB Wednesday, March 11th. Comments will be made available on this page after the comment period closes.

Access Request for Comments

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 March 11, 2020


The materials for public consideration are as follows:


Contact Information

For questions, please email [email protected]

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