2021 Strategic Planning Conference

The Need for Common Standards

States continue to have different standards for the same situation States with substantially similar standards continue to utilize different requirements Independent processes for nationally operating companies persist

“Create a federal money transmitter license. State money transmitter laws date back to the days when Wells Fargo actually operated a stagecoach and the federal government played a minimal role in financial regulation. There’s no good case for maintaining state-specific money transmitter regulation particularly given the number of large, national money transmitters . There’s no obvious benefit from the 50-state regime, as the substantive requirements are materially similar. Money transmitters that operate nationally merely end up complying with the strictest of regimes. A federal money transmitter license, coupled with some sort of federal insurance for funds held by money transmitters (such as balances in a PayPal or Venmo account) would be a simple move that would help reduce unnecessary regulatory burdens.”

‐ Adam Levitin’s recommendations to the House Financial Services Committee

The Future of MSB Supervision

A streamlined supervisory system • Exam cycles based on risk and resource availability • National standards and common policies • Harmonized regulation that relies on technology and data analytics The Vision

Current Environment

A manual supervisory system

• Calendar year exam cycles • 50 sets of standards and varying policies • Independent regulation hindered by state specific requirements