What is the Model Money Transmitter Law?

It’s a standardized framework intended to unify and streamline MTL requirements across different states. It aims to reduce inconsistencies among state statutes and close gaps that fraudsters could exploit.

Do all states automatically adopt the model law?

No. Each state decides whether and how to implement the model law. Some may adopt it fully, others partially, and some may have their own statutes but may incorporate similar language from the model.

How does the model law impact payroll specifically?

The model law explicitly mentions “payroll processors” when defining “money transmitters.” This direct reference makes it clearer that regulators can require payroll service providers to get licensed, depending on how the state interprets “receiving funds for transmission”.

Could states exclude payroll processors even if they adopt the model law?

Yes. Some states might add carve-outs or exemptions. Others might keep the payroll language intact. The final word depends on each state’s legislative process and how regulators interpret that legislation.