The Florida Money Transmitter License guide (Faisal Khan LLC, July 2026) covers licensing under F.S. Chapter 560, administered by the Office of Financial Regulation's Division of Consumer Finance — and the single fact that trips up most applicants.
Florida does not use NMLS. Applications are filed on Florida's own numbered forms through the REAL System, a parallel filing universe with its own calendar; anyone told to file an MU1 has been misinformed. The security device is equally distinctive: it ratchets automatically, calculated at 2% of prior-year Florida transaction volume, rounded up to the next $50,000 increment, between a $50,000 floor and $2,000,000 ceiling, and 250 or more branch or vendor locations triggers the ceiling automatically.
What the guide covers:
- Fees: $375 non-refundable application fee, plus $38 per branch and per authorised vendor location
- Net worth: $100,000 plus $10,000 per additional Florida location, capped at $2 million — the statute says "net worth," not tangible net worth
- Exemptions: only three — depository institutions, the United States, and Florida's own political subdivisions; no carve-out for broker-dealers or insurers
- Virtual currency: following State v. Espinoza and CS/HB 273, the test turns on unilateral ability to execute or block a transaction, not the mere presence of crypto
- Timeline: 90 days from a completed application under F.S. 120.60(1), with deemed approval if the OFR does not act
- Penalties: unlicensed activity is a felony under F.S. 560.125, graded by dollar amount transmitted
