Who needs to register?
Under Connecticut statute, all entities engaging in the business of issuing or selling payment instruments or stored value, receiving money or monetary value for current or future transmission, or the business of transmitting money or monetary value within the United States or to locations outside the United States by any and all means must obtain a money transmitter license in the state.
Who is the regulator?
Connecticut Department of Banking
What are the money transmitter license requirements?
Registering as a transmitter in the state of Connecticut requires the following fees and documentation:
- Identifying information
- Business web address
- Identification for contact employee and consumer complaint employee
- Location of books and records
- Officers, members, partners, and trustee information
- Name of any share holder owning 10% of corporation; ownership percentage of partners in the business
- Any corporation holding 25% of stock
- Book and market values of permissible investments in most recent statement, and 30 days before filing
- Total dollar amount of applicant’s outstanding instruments and transmissions in Connecticut and the US (most recent statements and 30 days prior)
- Articles of Incorporation, Articles of Organization, Partnership Agreement, Trust Agreement, and Organizational Chart of indirect owners
- Authority to do business in Connecticut
- Personal and Business History Statement for all control persons and direct owners
- Most recent audited unconsolidated financial statement, including balance sheet and receipts and disbursement for the preceding year, prepared by an independent CPA; an interim financial statement 30 days before filing
- Agent List and information compiled in an excel spreadsheet
- Letter of Acknowledgement from US Department of Treasury indicating business is a registered MSB
- Minimum net worth is determined by nature of business. If issuing money orders, then the net worth minimum is $100,000. If issuing travelers checks or electronic payment instruments, the net worth minimum is $1,000,000. If a money transmitter who is not issuing stored value, the net worth minimum is $500,000. If a money transmitter who is issuing stored value, the net worth minimum is either $500,000 or a higher amount determined by Commissioner.
- License fees vary depending on time of registration. Firms registering between October 1 of any odd-numbered year to September 30 of any even-numbered year must pay a nonrefundable investigation fee of $625 and a license fee of $2,250. Firms registering between October 1 of any even-numbered year to September 30 of any odd-numbered year must pay a nonrefundable investigation fee of $625 and a license fee of $1,250.
Note: The Commission may conduct state or national criminal history records check of of applicants and partner, director, trustee, principal officer, member and any share holder owning 10% or more of each of the businesses’s securities. A separate application and fee is required for each place of business.
What are the general bonding requirements?
Bonding requirements are determined based upon the average amount of money received or the average amount of money transferred for two previous reporting quarters. Bonding amount is determined by the greater of the two amounts.
If the weekly average is $150 or less: $300,000
If the weekly average falls between $150 – $250: $500,000
If the weekly average is greater than $250: $1,000,000
Disclaimer: Information provided by Shipkevich, PLLC and any of its affiliated web pages is for general educational purposes only, and should not be taken as legal advice.