The Pennsylvania money transmitter license, administered by the Department of Banking and Securities (DoBS) under 7 P.S. §§ 6101–6118 as amended by Act 7 of 2025, carries one of the steepest capital bars in the country. Pennsylvania has not adopted the Money Transmission Modernization Act, so there is no graduated scale — a pre-revenue startup owes the same fixed capital as a national transmitter.
The bond is flat at $1,000,000 regardless of size, with no small-operator tier, and it only moves up: DoBS can require more after an examination, but nothing in the act allows a reduction. Net worth is a flat $500,000 tangible, and since Act 7 it must be shown through audited GAAP financials — reviewed or in-house statements no longer qualify. Crypto coverage reversed twice in six years: permissive guidance from 2019 was replaced by an interpretive Statement of Policy in October 2024, then written directly into statute (§ 6102(a)(2)) on 26 August 2025, with no grace period.
What the guide covers:
- Application fee $5,000; renewal $5,000, due annually with presumptive renewal absent a 20-day DoBS objection
- A 6–12 month timeline, with no statutory decision clock or deemed approval
- Why crypto held on the company's own balance sheet may count for nothing toward the net worth test under GAAP
- The narrow four-clause exemption list (§ 6103) — broker-dealers, insurers and low-volume transmitters get none
- Unlicensed transmission graded a felony under § 6116, with examination costs billed to the licensee
- Federal AML law written directly into state statute under § 6111.1(2)