Kansas Money Transmitter License

Kansas Money Transmitter License: The Complete Guide to Getting Licensed in 2026

Everything you need to know about applying for, obtaining, and maintaining a Kansas money transmitter license — costs, timeline, requirements, and compliance obligations. Written by practitioners who do this for a living.

Last Updated: July 2026 · Regulatory Authority: Kansas Office of the State Bank Commissioner (OSBC) · Governing Law: Kansas Money Transmission Act, K.S.A. 9-555 through 9-596 (enacted by HB 2560, effective January 1, 2025; amended by HB 2591, effective July 1, 2026)

You’re Here Because You Need a Kansas Money Transmitter License

Whether you’re a fintech startup building a payments product, a remittance company expanding into the Great Plains, a cryptocurrency exchange serving Kansas residents, or an established MSB adding another state to your portfolio — you need a clear picture of what Kansas requires, what it costs, and how long it takes.

This page gives you that picture. No fluff. No generic overviews. Just the actual requirements, drawn from the statute, the NMLS process, and years of hands-on licensing experience.

If you want the full 2,500+ line deep-dive with section-by-section regulatory analysis, download our complete guide below.

Download the Complete Kansas MTL Guide

Kansas MTL at a Glance

Before you read another word, here’s the snapshot:

This table alone puts you ahead of 90% of applicants who walk into this process blind. But the details matter. Let’s get into them.

What It Actually Costs: The Real Numbers

Everyone asks, “What does it cost to get a Kansas money transmitter license?” The answer isn’t a single number. It’s a stack of costs, and most guides only mention the application fee. Here’s the full picture:

One-Time Application Costs

Annual Ongoing Costs

Bottom line: A lean operator with a simple business model and a small balance sheet should budget $115,000–$135,000 to get through the door (including the $100,000 minimum net worth). A mid-market fintech should budget $135,000–$195,000. A complex operation serving multiple customer segments or running virtual currency kiosks should plan for $195,000+.

Watch the net worth scale, not the floor. The $100,000 is only the minimum. Kansas requires the greater of $100,000 or 3% of your total assets up to $100 million — so a business with $10 million in total assets needs $300,000, and one with $50 million needs $1.5 million. Model your own balance sheet before you budget.

These are real numbers. If anyone tells you it costs “$1,750 to get licensed in Kansas,” they’re quoting the application fee and ignoring everything else.

The Surety Bond: It Scales With Liability, Not Annual Volume

Kansas’s surety bond isn’t one-size-fits-all — but it is widely misdescribed. It is not keyed to your annual transmission volume. Under K.S.A. 9-587 the required security is:

Read that middle row again. The bond is capped at $1,000,000. Older guides — including tier tables still circulating that multiply annual volume by 0.25% — describe the repealed Money Transmitter Act, not current law. Under the pre-2025 rule a large transmitter could face a bond in the millions. That is no longer how Kansas works.

Average daily money transmission liability means your outstanding Kansas money transmission obligations at the end of each day, added together and divided by the number of days in the quarter (K.S.A. 9-555). It measures money you are holding, not money you moved.

What you’ll actually pay: You don’t pay the full bond amount. You pay an annual premium — typically 0.75% to 1.5% of the face amount for applicants with strong credit and clean backgrounds. Applicants with credit issues, limited operating history, or higher-risk business models may pay 3–5%.

So on a $200,000 bond, your annual premium is roughly $1,500–$3,000 in most cases.

How the bond scales: If your average daily Kansas liability last quarter was $120,000, your bond is $200,000 — the floor. At $600,000 average daily liability, your bond is $600,000. At $1.5 million, your bond is $1,000,000 — the cap. And a well-capitalized applicant whose tangible net worth exceeds 10% of total assets stays at $200,000 no matter what, which is a genuine advantage worth structuring for. A licensee that simply posts the $1,000,000 maximum is excused from calculating average daily liability at all.

Timeline: What 3–10 Months Actually Looks Like

The Kansas Office of the State Bank Commissioner processes applications in a reasonable timeframe compared to many states. Here’s a realistic timeline breakdown:

Pro tip: The single biggest cause of delays is incomplete documentation. If you submit a clean, complete application with all exhibits on day one, you can realistically be licensed in 3–4 months. If the OSBC has to chase you for missing documents, expect 6–9 months or more.

The 120-day clock is your friend — and completeness is the trigger. Under K.S.A. 9-567 the OSBC must approve or deny within 120 days after your application is deemed complete. If it does neither, the application is considered approved and the license takes effect the first business day after the 120 days expire. The commissioner can extend for good cause, and multistate-process timeframes don’t count against the clock. But note what starts it: completeness, not filing. Every deficiency letter resets your position, which is precisely why front-loading the exhibits pays. Separately, if you fail to cure an incomplete application within 60 days of written notice, it is deemed abandoned and your $1,750 is gone.

Who Needs This License (And Who Doesn’t)

Kansas defines money transmission in K.S.A. 9-555, and the definition is narrower and more precise than the old law it replaced. Money transmission means selling or issuing payment instruments to a person in Kansas; selling or issuing stored value to a person in Kansas; receiving money for transmission from a person in Kansas; or payroll processing services. Since 1 July 2026 it also captures virtual currency kiosk activity and three-party crypto exchanges. If you do any of the following involving Kansas residents, you need a license:

Activities That Require Licensing

• Money transfers — Accepting funds from Person A and transmitting to Person B (domestic or international)

• Payment processing — Facilitating fund transfers between payers and payees (if you handle transmission, not just processing)

• Digital wallets — Holding customer funds and enabling transfers

• Prepaid/stored value cards — Issuing or selling prepaid instruments used for fund transmission

• Three-party crypto exchange — Acting as an intermediary that facilitates an exchange of money for virtual currency between a buyer and seller for a fee (licensable since 1 July 2026)

• Virtual currency kiosks — Operating, marketing, or facilitating a crypto kiosk physically located in Kansas (licensable since 1 July 2026)

• Bill payment services — Accepting consumer funds and transmitting to billers

• Payroll processing — Providing payroll processing services to employers

• Cross-border remittance — International money transfers (traditional or digital)

Who Is Exempt

Kansas lists its exemptions in K.S.A. 9-556. The ones that matter most in practice:

• Banks and credit unions — Federally insured depository financial institutions, plus bank holding companies and Edge Act corporations

• Securities broker-dealers — Registered under federal or state securities law, but only to the extent of their operation as a broker-dealer. Futures commission merchants and designated boards of trade get the same narrow treatment.

• Government agencies — Federal, state, and local, including counties and municipalities; also the US Postal Service

• Agents of a payee — Where a written agreement exists, the payee holds the agent out publicly, and the payor’s obligation is extinguished on the agent’s receipt

• Agents of a payor for payroll processing — A Kansas-specific carve-out with its own conditions

• Lawyers, accountants, bookkeepers, and real estate brokers — Acting in that professional capacity

• Employees of a licensee or authorized delegate — Acting within the scope of employment, as employees rather than independent contractors

Two traps in this list. First, Kansas grants no exemption to insurance companies. Guides that tell you otherwise are describing a different state. If an insurer’s activity meets the definition of money transmission, the only available relief is a discretionary exemption from the commissioner under K.S.A. 9-556(a)(16) — not an entitlement.

Second, the burden is on you. Under K.S.A. 9-556(b) the commissioner may require anyone claiming an exemption to produce information and documentation proving it. Unlicensed activity is a severity level 9 nonperson felony where you take more than $500 in compensation in any 30-day period, and a class A nonperson misdemeanor below that. Do not build a business on an exemption you have not papered.

Crypto operators, read the next section carefully. Kansas’s position is more permissive than most guides claim — and it changed two weeks before this page was updated. Do not assume you need a license, and do not assume you don’t.

The Application: What OSBC Actually Wants to See

Filing through NMLS involves completing several form types and uploading substantial documentation. Here’s what you’re walking into:

Before you start: the published NMLS checklist for Kansas is out of date. As of this update, the “KS Money Transmitter License New Application Checklist (Company)” on the NMLS site is still stamped 7 July 2020. It predates the Kansas Money Transmission Act entirely — it cites the repealed K.S.A. 9-509, states a $250,000 net worth requirement, and describes the old bond rule as annual Kansas volume × 0.25%. All three are superseded. The current requirements are in K.S.A. 9-586 and 9-587. The checklist remains useful for its document-upload guidance, which is largely unchanged, but do not budget from its financial figures. Where a stale checklist and the current statute conflict, the statute governs — and we’d suggest confirming with OSBC licensing staff in writing before you file.

NMLS Forms

• MU1 (Company Form) — Entity information, business activities, contact details, financial condition. This is the application itself.

• MU2 (Individual Form) — For each control person: personal history, employment, education, disclosure questions. Must be attested by the control person before the MU1 can be submitted.

• MU3 (Branch Form) — For branch offices, if applicable

There is no “MU4” in this process — MU4 is the mortgage loan originator form and has nothing to do with money transmission. Authorized delegates are not reported on a form at all; they go through NMLS UAAR (Uniform Authorized Agent Reporting), quarterly, even in quarters with no changes. Kansas asks you to include company-owned Kansas branches in your UAAR filing.

Required Supporting Documents

Financial Package:

• Audited or reviewed financial statements (balance sheet, income statement, cash flow)

• Tangible net worth calculation worksheet (showing asset – liabilities – intangible assets)

• 3–6 months of business bank statements (or startup projection if new entity)

• Personal financial statements for all beneficial owners (25%+ equity)

• 2–3 years of tax returns (business and personal)

• Proof of tangible net worth meeting the K.S.A. 9-586 scale (floor $100,000)

• A permissible investments schedule — book/market value as of your most recent audited and interim statements, a description of what you will report as outstanding payment liabilities, and your permissible investments policy

• A flow of funds chart and narrative for each transaction type, from first customer contact to funds reaching the beneficiary

Compliance Package:

• Written AML/BSA program with Know Your Customer (KYC) procedures, plus your most recent independent review of it

• Suspicious Activity Reporting (SAR) procedures (the federal MSB threshold is $2,000 — see the note below)

• Designated compliance officer with qualifications documented

• Customer identification program (CIP)

• OFAC sanctions screening procedures

• Staff training program outline

• Virtual currency transaction monitoring (if applicable)

Operational Package:

• Detailed business plan with financial projections (3–5 years)

• Technology systems description and security measures

• Customer complaint handling procedures

• Refund and cancellation policies

• Fee disclosure templates

• Disaster recovery and business continuity plan

• Anti-money laundering monitoring protocols

Background Package:

• FBI fingerprints for all principals, officers, directors, and 25%+ owners

• Signed authorization for background investigation

• Resumes/CVs for all key personnel

• Disclosure of any criminal history, regulatory actions, or litigation

• Personal credit report authorization

Myth to kill before it costs you: the SAR threshold is $2,000, not $5,000. We see this stated backwards constantly, including on pages that ought to know better. As a money services business, your SAR obligation under 31 CFR 1022.320 attaches at $2,000 — transactions conducted or attempted, involving or aggregating $2,000 or more, where you know, suspect, or have reason to suspect the transaction is suspicious. The $5,000 figure people quote is the bank threshold under a different regulation, and it does not apply to you. (A narrow $5,000 rule exists for issuers reviewing clearance records of their own money orders and traveler’s checks — that is the only place it belongs.)

No state, Kansas included, sets its own SAR threshold. This is federal law, uniform across all fifty states. If your Kansas AML program is calibrated to $5,000, you are under-reporting by design, and an examiner will find it.

The AML program is not a formality. Your program must demonstrate how you’ll identify, investigate, and report suspicious activity, and Kansas wants your most recent independent review uploaded alongside it. Don’t copy-paste a generic AML template and expect it to pass muster with the OSBC.

Kansas’s Tangible Net Worth Requirement

Kansas replaced its old flat $250,000 requirement on 1 January 2025 with a sliding scale. Under K.S.A. 9-586, every licensee must maintain at all times a tangible net worth of:

Tangible net worth is defined in K.S.A. 9-555 as aggregate assets excluding all intangible assets, less liabilities, determined in accordance with US GAAP. Note that this is a GAAP test — not a modified cash basis test — and the statute says so explicitly.

This applies at application and must be maintained continuously. Key points:

• Demonstrated at initial application through your most recent audited or unaudited financial statements

• GAAP-compliant, per the statutory definition

• Intangible assets (goodwill, patents, trademarks, customer lists) are excluded by definition

• The commissioner may exempt any applicant or licensee, in part or in whole, from the net worth requirement. Kansas dropped the model act’s “for good cause shown” qualifier, making this discretion unusually broad. It is not something to count on, but it is worth knowing the door exists.

• If your net worth becomes inadequate and you fail to remedy it within 10 days, that is a ground for suspension or revocation

This capital is not a fee — it stays in your business. But the OSBC will scrutinize how it’s deployed. If it’s all locked up in illiquid assets with no operational capital, you’ll face pushback. Demonstrate financial capacity to operate the business.

Separately, permissible investments. Under K.S.A. 9-588 you must hold permissible investments with a market value at least equal to your aggregate outstanding money transmission obligations. Those investments are held in statutory trust for your customers and are beyond the reach of your other creditors in insolvency. Note for crypto firms: no virtual currency has been approved as a permissible investment by the commissioner.

Why Kansas Is a Strong Licensing Jurisdiction

If you’re building a multistate licensing strategy, Kansas deserves a spot in your portfolio. Here’s why:

A genuinely modern statute. HB 2560 repealed the old Kansas Money Transmitter Act outright and replaced it with the Kansas Money Transmission Act, effective 1 January 2025 — Kansas adopted the CSBS model act nearly wholesale. That matters practically: definitions, control tests, permissible investments and net worth now track the same language a dozen-plus other states use, so your multistate compliance work compounds instead of fragmenting.

Low capital entry point. Kansas’s $100,000 tangible net worth floor is the MTMA standard — the same test Texas applies, the greater of $100,000 or 3% of total assets — and set against California’s sliding scale it sits at the accessible end of the national range. Kansas offers a straightforward path: $1,750 application fee, $200,000 minimum bond capped at $1,000,000, and tangible net worth starting at $100,000. New York is commonly cited around $500,000, but NYDFS sets requirements case by case — treat any fixed figure for New York with suspicion.

The OSBC is professional and responsive. Located in Topeka, the OSBC has a reputation for clear communication and collaborative engagement with applicants. They’ll challenge incomplete applications, but they won’t ghost you.

A real deemed-approval clock. Kansas commits to a decision within 120 days of completeness, and your license issues automatically if it misses. Not every state gives you that.

A hard bond ceiling. The $1,000,000 statutory cap means your bonding cost stops growing at a knowable point — and if your tangible net worth exceeds 10% of total assets, you stay at $200,000 permanently. For a well-capitalized operator this is one of the more attractive bond regimes in the country.

Crypto clarity — of a kind. Kansas doesn’t create a separate, expensive crypto license. It also doesn’t sweep all crypto activity into money transmission the way some guides claim. The OSBC has published a virtual currency position since 2014 and has kept it current through the recodification. Whether that clarity helps or hurts you depends entirely on your model — see the virtual currency section below.

Regional fintech ecosystem. Kansas City (straddling Kansas and Missouri) is a growing fintech hub with strong banking infrastructure, technology talent, and correspondent banking relationships. Getting a bank account as an MSB is hard everywhere — it’s comparatively easier when licensed in a state with strong banking heritage.

Multistate leverage. NMLS filing means your application data is already in the federal system. Adding additional states becomes progressively easier — you’re supplementing existing filings, not starting from scratch.

After You’re Licensed: Ongoing Compliance

Getting the license is step one. Keeping it requires continuous compliance:

Annual Obligations

• License renewal — Your license expires 31 December every year. The renewal fee is set annually by the commissioner and is tiered on your Kansas dollar volume: a floor of $1,500, capped at $4,000 for in-state licensees and $25,000 for out-of-state licensees. Pay it no more than 60 days before expiration, and get your renewal in and complete by 1 December — applications received from 2–31 December, or incomplete as of 1 December, draw a late fee of up to $1,000. Miss the year entirely and reinstatement between 1 January and 28 February costs $1,000.

• Audited financial statement — Filed within 90 days after your fiscal year end (not calendar year end), GAAP, prepared by an independent CPA with a certificate of opinion

• Surety bond maintenance — Continuous coverage, recalculated against your average daily Kansas transmission liability

Continuous Obligations

• Report of condition — Quarterly, within 45 days of each calendar quarter end. Destination-country reporting rides in the Q4 filing only.

• Authorized delegate report — Quarterly via UAAR, within 45 days of each quarter end, even when nothing changed

• SAR filing — File within 30 days of initial detection. The federal MSB threshold is $2,000, not $5,000 — Kansas sets no separate threshold.

• CTR filing — Currency Transaction Reports for cash transactions over $10,000

• Record retention — Records maintained for at least 3 years. You may keep them outside Kansas, but must make them accessible to the commissioner on seven business days’ notice.

• Customer complaint tracking — Document all complaints, investigations, and resolutions

• Key individual changes — Notify the OSBC within 15 days of the appointment taking effect, with full K.S.A. 9-564 information within 45 days. The commissioner has 90 days to disapprove; silence is approval.

• Change of control — You must obtain the commissioner’s written approval before the change of control occurs. “Control” means 25% of voting shares — but also the power to appoint a majority of key individuals, or to exercise a controlling influence. The 25% figure alone understates the trigger; a transaction with no equity movement can still require approval.

• Adverse events — Report within one business day of having reason to know of a bankruptcy, receivership or dissolution petition, or a proceeding to revoke or suspend your license in any state or country. Within three business days for a felony conviction of the licensee, a key individual, a person in control, or an authorized delegate.

Regulatory Examinations

K.S.A. 9-559 gives the commissioner examination authority but publishes no fixed cycle — no statutory “every 12 to 24 months.” Exams may be conducted on-site or off-site, jointly with other states or federal agencies, and the OSBC may accept another regulator’s examination report as its own official report. In practice, expect timing to follow your risk profile and compliance history rather than a calendar.

You pay for it. Under K.S.A. 9-559©, unless the commissioner directs otherwise, the licensee bears all costs reasonably incurred in an examination — including examinations of your authorized delegates. Budget for this; most guides omit it entirely.

During an exam, regulators will review:

• Financial statements and capital adequacy (tangible net worth maintenance)

• Permissible investments coverage against outstanding money transmission obligations

• Transaction records and processing controls

• AML program effectiveness and SAR filing history

• Virtual currency controls (if applicable)

• Customer complaint handling

• Technology security and data protection

• Surety bond adequacy relative to average daily transmission liability

Don’t treat compliance as a cost center. The companies that lose their licenses — and they do — are the ones that treat compliance as an afterthought. Build it into your operations from day one. It’s cheaper to do it right than to fix it after an examination finding.

Virtual Currency & Crypto: What Kansas Requires

This is the section most guides get backwards, so read it carefully.

Kansas did not adopt the model act’s optional virtual currency provisions. When HB 2560 enacted the Kansas Money Transmission Act, the phrase “virtual currency” appeared nowhere in it. “Money” is defined in K.S.A. 9-555 as a medium of exchange authorized or adopted by the United States or a foreign government — and the OSBC’s position, published as guidance MT 2014-01 since 2014 and expressly reviewed and confirmed as still applicable under the new act, is that cryptocurrency is not “money” or “monetary value” under the Kansas Money Transmission Act. An entity engaged solely in transmitting decentralized cryptocurrency does not need a Kansas license.

Then, on 1 July 2026, HB 2591 amended the definition of money transmission — narrowing the question rather than reversing it. Current law:

What Is Money Transmission

• Three-party exchanges — where an intermediary facilitates an exchange of money for virtual currency between a buyer and a seller for a fee or gain, with at least one person located in Kansas

• Virtual currency kiosks — engaging in virtual currency transactions for a fee from a kiosk physically located in Kansas

• Receiving sovereign currency for transmission — if you take a customer’s dollars against a promise to make them available to someone else, that is money transmission regardless of what the crypto leg looks like

What Is Not Money Transmission

• Two-party exchanges — where you trade your own inventory of virtual currency or money with a customer for a fee or gain, in any manner other than from a Kansas kiosk. This is treated as a sale of goods between two parties.

• Crypto-to-crypto exchange — expressly excluded by statute, other than from a Kansas kiosk, because cryptocurrency is not “money”

• Transfer of cryptocurrency by itself — receiving crypto with intent to transmit it to another party is not money transmission, including for intermediaries

If you operate a virtual currency kiosk in Kansas, this is now urgent. Kiosk operators are deemed to be engaged in money transmission and must be licensed. Operators unlicensed as of 1 July 2026 have 60 days to apply, and may continue operating while a complete application is under review — but must cease if denied. The Virtual Currency Kiosk Consumer Protection Act also layers on obligations no other Kansas licensee faces: a $1,000 cap on a customer’s initial transaction, $1,000/day and one transaction per 72 hours for the following 14 days with a $10,000 aggregate, then $10,500/day thereafter; a fee cap of the greater of $5 or 18% of the transmission amount, with the bid-ask spread expressly counted as an indirect charge; a 72-hour holding period on funds, during which the customer may demand a full refund of an initial transaction for any reason; fraud-based refunds where the customer reports within 30 days with a police report or sworn declaration; refunds paid within 10 business days; on-screen scam warnings acknowledged by tap and by email, in Spanish where the transaction is in Spanish; live toll-free customer service during operating hours; blockchain analytics software; a full-time consumer protection officer who may not own more than 20% of the operator; and quarterly kiosk location reports. Strict liability attaches to the ID-verification requirements.

Additional considerations for crypto operators:

• No virtual currency has been approved as a permissible investment by the commissioner under K.S.A. 9-588 and 9-589. You cannot back Kansas customer obligations with crypto.

• On tangible net worth, the CSBS multistate guidance the OSBC links treats virtual currency as an intangible asset that must be subtracted from total assets — except where it is unencumbered and held against a corresponding customer liability denominated in the same virtual currency. Crypto held for your own account is subtracted. That guidance expressly does not apply to fiat-backed payment stablecoins.

• If you regularly handle virtual currency, expect to provide a current third-party security audit of all relevant computer and information systems

• Your AML program should still address crypto transaction monitoring, velocity patterns, private key management, and sanctions screening — a Kansas licensing exclusion is not a BSA exclusion

• Stablecoins are unresolved. A fiat-backed payment stablecoin may look more like “monetary value” or stored value than like Bitcoin, and neither the statute nor MT 2014-01 answers it cleanly. If you issue or redeem stablecoins, verify your position with the OSBC directly before relying on the crypto exclusions above.

Kansas’s approach is narrower than its reputation: if you receive money — sovereign currency — for transmission, you need a license. If you deal purely in crypto, generally you do not. If you run a kiosk, you now do. And the federal MSB layer applies to you regardless of any of this.

Multistate Strategy: Where Kansas Fits

Most money transmitters don’t operate in just one state. Kansas is an excellent addition to a national licensing footprint:

Pair it with: Texas and Oklahoma for Southwest/Central coverage. Missouri does require its own license — the Money Order/Money Transmitter (Sale of Checks) license from the Missouri Division of Finance, with its own bond and an April 15 expiry. Do not skip it on the assumption that Kansas City coverage comes free; operating unlicensed there is a class A misdemeanor. Layer in Illinois, Michigan, and Minnesota for Midwest reach. Then tackle harder states (New York, California) once you have operating history and a compliance track record.

Sequencing note. Illinois’s full MTMA took effect 1 January 2026 and Virginia’s on 1 July 2026, so the model act’s language is now shared across a growing bloc — Kansas work carries over. Colorado adopted the MTMA only in part (effective 6 August 2025) and omitted the optional virtual currency provisions, so its crypto position is unresolved. California’s separate crypto regime, the Digital Financial Assets Law, went live 1 July 2026.

NMLS simplifies multistate — but not everywhere. Because Kansas uses NMLS, your application data, company information, and individual records are already in the system. Adding states becomes progressively easier. Note that Colorado, Nevada and Florida do not use NMLS for money transmitter licensing, so budget separate workflows for those.

FinCEN registration is separate. Regardless of how many states you’re licensed in, you must also register as a Money Services Business (MSB) with FinCEN. This is a federal requirement, separate from state licensing, and must be renewed biennially.

Key Contacts & Resources

Download the Full Guide

This page covers the essentials. The full guide goes deeper — 2,500+ lines covering every section of the licensing process, from AML program architecture to examination preparation to emerging regulatory trends specific to Kansas.

Need Help With Your Kansas Application?

Faisal Khan LLC is a cross-border payments and licensing consultancy. We help fintechs, payment companies, remittance operators, and crypto businesses navigate money transmitter licensing across all 50 states, DC, and US territories.

If you need help with your Kansas money transmitter license application — or you’re building a multistate licensing strategy and want to do it right — get in touch.

© 2026 Faisal Khan LLC. All rights reserved. This page is for informational purposes only and does not constitute legal, financial, or regulatory advice. Licensing requirements change — always verify current requirements with the Kansas Office of the State Bank Commissioner directly. See our full disclaimer for details.

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