Who needs to register?
Under Michigan statute, all entities providing money transmission services must obtain the appropriate license from the Department of Insurance and Financial Services and comply with the provisions of the act. In Michigan, only businesses selling or issuing payment instruments or stored value devices, or receiving money or monetary value for transmission, must obtain a money transmitter license.
Michigan Department of Insurance and Financial Services (previously known as the Office of Financial and Insurance Regulation)
What are the money transmitter license requirements?
Registering as a money transmitter in Maine requires the following fees and documentation:
- $600 investigation fee
- $2,500 license fee plus $50 for each additional location, not amounting to more than $3,000
- Any additional license transition fees or investigation fees
- Net worth of $100,000 plus $25,000 for each location and delegate, not amounting to more than $1,000,000
- Intended amount of authorized delegates and locations plus a list of such
- Organizational flow chart if not a wholly owned subsidiary
- Step-by-step description of money transmission service to be provided
- Web address through which business will be conducted and security and privacy precautions
- Description of material litigation and criminal convictions in the past ten years
- Money transmitter policies and procedures applicant will use to assure compliance with anti-money laundering and Bank Secrecy Act requirements
- Confirmation of FinCEN filing
- Compliance officer and plans for regular independent review and monitoring of authorized delegate compliance
- Date and location of any bankruptcy or receivership proceedings
- List of all officers and members of Board of Directors and Board of Trade, executive committee, controlling persons, partners, sole proprietors, shareholders of 20%, members of LLC and affiliation disclosure
- Documentation of any convictions or criminal charges, administrative proceedings regarding professional or occupational licenses, liability in any lawsuit or arbitration involving allegations of fraud, misappropriation, conversion of funds, misrepresentation or breach of fiduciary duty
- Personal or business bankruptcy history
- Financial service licenses issued by other states
- Prior experience in consumer financial services business and firms
- Employment history over past ten years
- Firms, companies, corporations or other business organizations where applicant has been a director, officer, employee, partner, owner, or member
- List of all additional persons with any ownership interest in the applicant company, including company, residence and percent ownership (including corporate stockholders)
- Michigan Resident Agent for which process is served in Michigan
- Written business plan that includes at a minimum the scope of the business, financial arrangements, relationships and agreements, the target market, sources of funding and credit, use of authorized delegates and employees, and any other information relevant to the money transmission business
- Financial Statement Disclosure for each of the previous two years, if available, signed and notarized
- Contact person
- Company’s state and date of origin
- List any license number, type of license and the name of the regulatory agency issuing license if licensed in any other state
- Financial Statement disclosure and tax ID including fiscal year end (just a personally filled out balance sheet)
What are the general bonding requirements?
Bonding requirements for Michigan money transmitters include a $500,000 bond plus $10,000 bond for each additional location, not amounting to more than $1,500,000.
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.