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Comments on Model State Payments Law

In February 2019, CSBS sought public input on issues related to state money transmission and payments regulation as regulators begin work on model legislation to introduce in all 50 states.

The Request for Information (RFI) solicits comments about several areas of law and regulation, including money transmission activities and exemptions, personal vetting requirements for investors, state supervision, and coordination between states.

Access the Request for Information

The comments received by CSBS are available below.

Company Comments

Activities and Exemptions

AirPlus PDF
Electronic Transactions Association PDF
First Data PDF
National Payroll Reporting Consortium PDF


Money Services Businesses Association PDF
TransferWise PDF


Financial Innovation Now PDF
Consumer Reports & National Consumer Law Center PDF
PayPal PDF
The Money Services Round Table PDF


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