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ACI – 17th National Forum on Prepaid Card Compliance

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Presentation on theme: "ACI – 17th National Forum on Prepaid Card Compliance"— Presentation transcript:

1 ACI – 17th National Forum on Prepaid Card Compliance
January 30, 2017 State Regulatory and Enforcement Efforts Including Latest Challenges Associated with Money Transmitter Licensing Enforcement Donald J. Mosher Partner Schulte Roth & Zabel LLP Tweeting about this conference?

2 Disclaimer This information and any presentation accompanying it (the "Content") has been prepared by Schulte Roth & Zabel LLP ("SRZ") for general informational purposes only. It is not intended as and should not be regarded or relied upon as legal advice or opinion, or as a substitute for the advice of counsel. You should not rely on, take any action or fail to take any action based upon the Content. As between SRZ and you, SRZ at all times owns and retains all right, title and interest in and to the Content. You may only use and copy the Content, or portions of the Content, for your personal, non-commercial use, provided that you place all copyright and any other notices applicable to such Content in a form and place that you believe complies with the requirements of the United States’ Copyright and all other applicable law. Except as granted in the foregoing limited license with respect to the Content, you may not otherwise use, make available or disclose the Content, or portions of the Content, or mention SRZ in connection with the Content, or portions of the Content, in any review, report, public announcement, transmission, presentation, distribution, republication or other similar communication, whether in whole or in part, without the express prior written consent of SRZ in each instance. This information or your use or reliance upon the Content does not establish a lawyer-client relationship between you and SRZ. If you would like more information or specific advice on matters of interest to you please contact us directly.

3 Agenda States that Regulate Money Transmission
Money Transmitter Requirements Payment Processing Questions from Audience

4 States that Regulate Money Transmission
Alabama Arizona Arkansas California Colorado Connecticut Delaware Florida Georgia Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Wisconsin Wyoming Hawaii Alaska Washington, DC MT license required Massachusetts only regulates foreign money transmission and the issuance and sale of payment instruments. Wisconsin only regulates money transmitters with a physical presence. New Mexico recently enacted its new money transmitter law, effective January 1, 2017. South Carolina recently enacted its money transmitter law, and the law will be effective no earlier than June 9, 2017.

5 Money Transmitter Requirements
Money Orders Foreign and Domestic Money Transfers Stored Value / Prepaid Access Typical Coverage Receipts Prompt Remittance Posting Consumer Protection Permissible Investments (1:1; statutory trust) Surety Bond or Security Device Capitalization Safety & Soundness Agent Oversight: Contract Requirements; Appointment and Termination Recordkeeping; Periodic Reporting Examinations; C&Ds; Civil Action; Suspension & Revocation Supervision & Enforcement

6 Is an Agent of Payee Expressly Exempt?
Washington Maine Montana North Dakota Oregon Minnesota Vermont New Hampshire Idaho South Dakota Wisconsin Massachusetts New York Wyoming Michigan Rhode Island Connecticut Nebraska Iowa Pennsylvania New Jersey Nevada Ohio Washington, DC Utah Illinois Indiana Delaware Colorado West Maryland California Virginia Kansas Virginia Missouri Kentucky North Carolina Arizona Tennessee Oklahoma New Mexico South Carolina Arkansas Illinois – New Policy as of July 29, 2015 Kansas - Guidance MT , Nov 30, 2016 ( Kentucky – effective July 15, 2016 North Carolina – recent amendments incorporating agent of payee exemption are effective as of October 1, 2016 Pennsylvania – Effective 1/2/2017 (Penn MT Law, as amended by 2016 Pa. Laws 129 aka 2015 Pa. HB 850) Texas – Interpretive letters, e.g., Opinion Number 14-01, dated May 9, 2014; see also 7 Texas Admin Code § 33.4 Washington – Interpretive Statement Mississippi Georgia Alabama Texas Louisiana Alaska Express statutory agent of payee exemption Florida Policy/regulatory exemption for agent of payee Hawaii

7 THANK YOU Q & A

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