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Massachusetts Finalizes Comprehensive Money Transmission Regulations

By A.J. Dhaliwal, Mehul Madia & Maxwell Earp-Thomas on November 6, 2025
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On October 24, 2025, the Massachusetts Division of Banks (DOB) finalized a suite of regulatory amendments implementing the Massachusetts Money Transmission Act. The final regulations, 209 Mass. Code Regs. §§ 44.00, 45.00, 48.00, and 801 Mass. Code Regs. § 4.02, take effect November 7. The changes establish a uniform licensing and compliance regime for all entities engaged in money transmission, replacing prior requirements that applied only to check cashers, check sellers, and foreign transmittal agencies.

The DOB’s rulemaking provides application, licensing, recordkeeping, and bonding standards for money transmitters operating in Massachusetts. The rules also requires annual and quarterly call reports, audited financial statements within 90 days of fiscal year-end, and prompt notice to the DOB of ownership changes or other material developments.

Putting It Into Practice: Several states have recently overhauled their money transmission laws to align with newer statutory models and create more uniform licensing and supervision standards (previously discussed here, here, and here). With several states recently revising similar rules, regulators appear focused on bringing consistency to how transmission activity is defined, licensed, and monitored. Companies operating in multiple jurisdictions should expect this effort to continue as states look to standardize oversight and close remaining gaps in their regulatory approaches.

Photo of A.J. Dhaliwal A.J. Dhaliwal

A.J. is a partner in the Finance and Bankruptcy Practice Group in the firm’s Washington, D.C. office.

Read more about A.J. DhaliwalEmail
Photo of Mehul Madia Mehul Madia

Mehul Madia, special counsel in the firm’s Washington, D.C. office, provides deep consumer finance and fintech expertise to clients, leveraging more than 15 years’ of public and private sector experience.

Read more about Mehul MadiaEmail
Photo of Maxwell Earp-Thomas Maxwell Earp-Thomas

Max is an associate in the Finance & Bankruptcy Practice Group in the firm’s Orange County office.

Read more about Maxwell Earp-ThomasEmail
  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Consumer Finance and Fintech Blog
  • Organization:
    Sheppard, Mullin, Richter & Hampton LLP
  • Article: View Original Source

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