The Colorado money transmitter licence guide (Faisal Khan LLC, July 2026) covers a regime that the Division of Banking (DORA) and State Banking Board rewrote from the ground up: the Money Transmission Modernization Act (HB 25-1201) took effect 6 August 2025, repealing and replacing the old Money Transmitters Act under C.R.S. § 11-110-101 et seq.
Two things separate Colorado from most MTMA states. It runs outside NMLS entirely — applicants file directly on the Division's own forms. And unlike most states, there is no statutory deadline for the Banking Board to decide and no deemed approval, so the only clock in the process is a 30-day window to respond after a denial. Late filings are punished hard: up to $750 per day for a report of condition and up to $750 per day for the annual financial statement, among the harshest penalties in the country.
What the guide covers:
- Bond formula — the greater of $250,000 or 100% of average daily Colorado money transmission liability, capped at $1,000,000; posting the maximum bond excuses the calculation entirely
- Tangible net worth — the greater of $100,000 or 3% of the first $100M in assets, 2% to $1B, 0.5% above, replacing the old flat $50,000-plus-per-branch formula
- Crypto status — genuinely unresolved; "virtual currency," "digital asset" and "stablecoin" appear nowhere in the statute, and Colorado adopted the MTMA without its optional crypto provisions
- The agent-of-a-payee exemption, newly codified and requiring all three of a written agreement, public holding-out, and extinguished payer obligation
- A background-check trigger for anyone who has lived outside the US in the last ten years
- A fee-timing trick — licences issued between 1 July and 31 December pay a halved $3,000 fee and get an extended first term
Authorised delegates cover employees only, not independent contractors, and the burden of proving any exemption sits with the applicant.