The Tennessee Money Transmitter License guide (Faisal Khan LLC, July 2026) covers one of the cheapest, most straightforward Money Transmission Modernization Act states — with a crypto position that runs opposite to what most published guides claim.
The Tennessee Department of Financial Institutions has stated directly, in its published Virtual Currency Statement of Policy, that it "does not regulate virtual currency" — the licence and its bond do not cover virtual currency transmission at all. Tennessee declined the MTMA's optional virtual currency provisions, so there is no Tennessee licence that blesses a pure crypto business; operators who assume otherwise budget for cover they will never get. Virtual currency kiosks are banned outright from 1 July 2026.
The guide also flags a live documentation trap: TDFI's own NMLS checklists still describe the repealed pre-2024 regime — the old net worth and bond figures and repealed statute sections — and third-party surety sites repeat the stale numbers.
What the guide covers:
- Regulator and statute: Tennessee Department of Financial Institutions, under TCA §§ 45-7-101–144, effective 1 January 2024
- Fee: $250 via NMLS, a fraction of comparable states such as New York's $3,000
- Bond (§ 45-7-136): greater of $50,000 or 100% of average daily Tennessee liability, capped at $800,000
- Tangible net worth (§ 45-7-135): greater of $100,000 or the standard 3%/2%/0.5% sliding scale
- Renewal deadline: the licence expires at close of business 31 December with no grace period and no late-fee cure
- No FinCEN-registered MSB exemption — federal registration is additional, not a substitute
Year-one costs run roughly $12,050 to $84,250 excluding the $100,000 capital requirement, and the burden of proving any exemption sits with the claimant.