The New York Money Transmitter License guide (Faisal Khan LLC, July 2026) calls New York the most expensive and slowest state license in the country, built around correcting two claims repeated almost everywhere else.
First, New York does use NMLS for the money transmitter license (MU1/MU2) and UAAR for agent reporting — the difference from other states is substance, not plumbing. Second, and more striking: New York has no published net worth requirement. Article 13-B contains no net worth provision, and the $500,000 figure quoted across comparison tables is actually the § 643(1) surety bond floor, copied into the net worth column by guides quoting each other for years. As the guide puts it, "you cannot pre-clear New York by hitting a number, because there is no number to hit."
The application fee is $3,000, but the license is perpetual — no renewal filing. The bond starts at $500,000 (plus a separate $750,000 minimum for traveler's checks), with no volume ladder; the Superintendent sets it above the floor on four factors that notably exclude annual volume. The 90-day statutory decision clock is easily extended by the applicant's own "written consent," so realistic timing is 12–24 months, longer for foreign principals.
On crypto, the guide flags a commonly reversed rule: Article 13-B is a fiat statute, and virtual currency transmission triggers the separate BitLicense (23 NYCRR Part 200), not the MTL. A New York limited-purpose trust company charter is exempt from the BitLicense and can conduct money transmission without a separate MTL at all.
What the guide covers:
- Year-one costs ranging roughly $63,500 to $423,000+, plus BitLicense costs on top
- Permissible investments under § 651, the real ongoing financial test
- The FILMS examination scale used to grade licensees
- Change-of-control's separate 150-day deemed-approval clock
- The federal $2,000 SAR threshold, and why citing a "New York threshold" fails with examiners