The Indiana money transmitter license guide (Faisal Khan LLC, July 2026) covers a state that adopted the MTMA effective 1 January 2024 but deliberately left out both the virtual currency and payroll processing provisions — while adding a requirement almost no other state has.
Most guides miss it: Indiana requires a crime insurance policy under IC 28-8-4.1-1005, an Indiana-specific modification to the model act, covering loss by criminal act or dishonesty with a principal sum at least equal to the surety bond — meaning at least $300,000 of coverage from day one, on top of the bond itself. The bond runs the greater of $300,000, notably higher than the MTMA norm, or average daily in-state liability, capped at $500,000.
What the guide covers:
- Fees are not fixed in statute — IC 28-8-4.1-503(c) leaves them to the DFI, so operators must confirm current amounts before budgeting
- Tangible net worth under IC 28-8-4.1-1001: greater of $100,000 or 3%/2%/0.5%, worked to $1.5M on $50M in assets and $11M on $500M
- A 120-day deemed-approval clock, but an application that expires one year after initial review if not completed
- Crypto expressly excluded from the MTMA definition of money, but a business mixing crypto services with customer fiat handling can still trigger licensure
- Exemptions narrower than assumed — insurance companies, attorneys holding client funds, nonprofits and check cashers are not exempt
- A state supplemental questionnaire requiring FBI checks on every 10%+ owner and, for anyone domiciled outside the US in the last decade, a third-party investigative background report
The bigger practical shift under the MTMA: Indiana now captures business-purpose money transmission, not just personal or household transfers — reaching activity like jail and prison commissary funding that was previously unlicensed.