Financial Institutions Law Final Opinions Letters

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Letter Subject	Date
Cryptocurrency Exchange Platform	11/03/22
Agent of the payee for NPO donations; operating account funds related to exempt activities not stored value	06/09/22
Purchase and Sale of Virtual Currency	04/08/22
Digital Asset Trading Platform Services	03/23/22
Digital Currency Trading Platform	02/22/22
Referral of customers to financial institutions not money transmission	02/22/22
Agent of Payee	01/14/22
Purchase and Sale of Digital Assets; Payment Processing Services	12/06/21
Purchase of Cryptocurrency – 10-25-21	10/25/21
Virtual currency wallet and exchange platform not subject to licensing under the MTA	10/20/21
Cryptocurrency-to-precious metals dealer not subject to licensing under the MTA	10/20/21
Asset-backed Tokens and other Cryptocurrency	10/20/21
Cryptocurrency and Agent of Payee Exemption – Payment Processing Service	10/20/21
Agent of Payee Exemption – 09-24-21	09/24/21
Bitcoin ATM Kiosk – 09-02-21	09/02/21
Bitcoin ATM Kiosk – 08-11-21	08/11/21
Bitcoin ATM Kiosk	08/11/21
Agent of Payee – Fund Transfers in Connection with Real Estate Closing Transactions	07/30/21
Specified cryptocurrency activities not subject to licensing under the MTA	05/27/21
Bitcoin ATM kiosks not subject to licensing under the MTA – 05-25-21	05/25/21
Bitcoin ATM Kiosk – 04-29-21	04/29/21
Bitcoin ATM kiosks not subject to licensing under the MTA – 04-29-21	04/29/21
Cryptocurrency Exchange not subject to licensing under the MTA	03/10/21
Transactions in which recipients are paid before company is reimbursed are not subject to licensing under MTA – 02-11-21	02/11/21
Purchase and Sale of Cryptocurrency – 02/09/21	02/09/21
Agent of Payee Exemption – Payments to Daily Fantasy Sports Providers for Closed Loop Stored Value – 02/05/21	02/05/21
Agent of Payee exemption for Online Travel Marketplace, Payroll Processing exemption, Agent of Payee exemption for Online Marketplace for Independent Contractors, Internet Escrow Agent not engaging in money transmission – 01/28/21	01/28/21
Licensee’s Intercompany Receivables fall within definition of Money Transmission Receivables under Financial Code section 2040(d) – 01/28/21	01/28/21
Armored Car Company providing Cash Management Services to Bitcoin ATM Operators not Engaging in Money Transmission – 01/27/21	01/27/21
Agent of Payee Exemption – Online Gaming/Sports Betting – 01/25/21	01/25/21
Bitcoin ATMs/ Kiosks – 01/04/21	01/04/21
Bitcoin ATMs – 11/10/20	11/10/20
Bitcoin ATM not subject to licensing under the MTA – 10-27-20	10/27/20
Bitcoin ATMs – 10/27/20	10/27/20
MTA – Registered clearing house and payment processing service exemptions	10/13/20
International Settlement Service – Decline to Opine – 10/06/20	10/06/20
Bitcoin ATM not subject to licensing under the MTA – 10-01-20	10/01/20
Exemption for distribution of other authorized deductions from employees’ wage or salaries	09/11/20
Video game – digital assets – 08/28/20	08/28/20
Sale of Foreign Currency – 08/06/20	08/06/20
Cryptocurrency – Escrow Accounts and Exchanges – 07/28/20	07/28/20
Agent of Payee Exemption – Payment Processing Service – 07/10/20	07/10/20
Online foreign currency exchange service – 07/01/20	07/01/20
Agent of payee – Tax payments – 06/30/20	06/30/20
Exemption for Operator of Payment System – 06/29/20	06/29/20
MTA- Agent of Payee- 06/29/20	06/29/20
Sending instructions not money transmission – 06/09/20	06/09/20
MTA – payroll processing – 04/24/20	04/24/20
Cryptocurrency Exchange Platform – 04/13/20	04/13/20
Cryptocurrency ATMs – 04/07/20	04/07/20
MTA – payroll processing – 04/06/20	04/06/20
Cryptocurrency Exchange Platform – 02/25/20	02/25/20
Digital and physical stored value gift cards and donations to non-profit organizations for corporate reward and incentive programs	02/19/20
Agent of Payee Exemption – Charitable Donations – Decline to Opine	01/28/20
Agent of Payee Exemption – Payment Processing Service	01/27/20
Cryptocurrency Exchange Platform – 12/24/19	12/24/19
Bitcoin ATM not subject to MTA	12/16/19
MTA Exemptions	12/12/19
Cryptocurrency ATM	12/11/19
Agent of Payee Exemption – Bill Payment	11/26/19
Cryptocurrency Exchange Platform – 10/28/19	10/28/19
Quarterly Reporting Obligations	10/15/19
Agent of Payee Exemption – Online Platform for Goods or Services	10/10/19
Virtual Currency – 10/04/19 -3	10/04/19
Virtual Currency – 10/04/19 -2	10/04/19
Virtual Currency – 10/04/19 -1	10/04/19
Bitcoin ATMs not subject to MTA – 10/01/19	10/01/19
Cryptocurrency Exchange Platform -10/01/19	10/01/19
Cryptocurrency Exchange Platform – 09/30/19	09/30/19
Agent of Bank	08/26/19
Purchase of Cryptocurrency	08/01/19
Agent of Payee Exemption – Guest Checkout product	07/23/19
Online Foreign Currency Exchange Services	07/18/19
Cryptocurrency Platform – Closed Loop Stored Value	06/25/19
MTA/ Agent-of-Payee	05/17/19
MTA – payroll processing	04/18/19
Providing program interface not money transmission	03/25/19
Agent of Affiliate Licensee	03/20/19
Payment processing service not exempt as agent of payee (Amended)	02/21/19
Cryptocurrency Exchange Platform – 01/28/19	01/28/19
Payment processing service not exempt as agent of payee – 01/09/19	01/09/19
Payment processing service not exempt as agent of payee – 01/18/19	01/18/19
Technological/customer service support not money transmission	12/21/18
Sending instructions not money transmission – 11/29/18	11/29/18
Payment processing service not exempt as agent of payee or factoring	11/14/18
Cryptocurrency Exchange Platform – 10/09/18	10/09/18
Digital Currency Dealer	10/09/18
Agent of payee – subsidiaries	09/11/18
Cryptocurrency Exchange – 08/15/19	08/15/18
Sale of Cryptocurrency Through an Exchange	07/06/18
Cryptocurrency Exchange	07/06/18
Agent of Payee Exemption – Successive Agents	04/05/18
Operator of a Payment System, Payroll Processing, Public Interest Exemption	02/27/18
Agent of Payee – Payment Processing – 02/27/18	02/27/18
Agent of Payee – Decline to Opine – Request for a legal opinion under Financial Code section 2010, subdivision (l)	02/20/18
Agent of Payee – Decline to Opine – Request for a legal opinion under Financial Code section 2010(l) – 02/20/18	02/20/18
Agent of Payee – Decline to Opine – Request for a legal opinion	02/12/18
Agent of Payee Exemption – Goods or Services	02/06/18
Agent of Payee – Decline to Opine – Request for a legal opinion under Financial Code section 2010(l) – 01/04/18	01/04/18
Agent of Payee – Payment Processing – 12/21/17	12/21/17
Stored Value	06/06/17
Calculating Money Transmission Receivables	06/06/17
Exemption for agent of payee: Online games marketplace	05/08/17
Agent of a governmental subdivision	04/25/17
Calculating eligible securities	04/10/17
Tax payment service not exempt from the MTA	04/07/17
Receiving funds for reimbursement under money transmission law	04/07/17
Company Not Engaging in Money Transmission in California	04/07/17
Prepaid Card Reloading Service	11/29/16
Exemption based on public interest	11/07/16
Agent of payee exemption for payment processing service	11/03/16
Eligible Securities – FBO Account Titles	11/03/16
Eligible Securities/FBO Accounts	11/03/16
Reimbursement for foreign-currency sale is not money transmission.	10/06/16
Money Transmission in this State – 08/23/16	08/23/16
Lending Limits and Common Servicer	08/23/16
Exemption for Sale of Bank-Issued Stored Value Cards – 08/23/16	08/23/16
Exemption for Sale of Bank-Issued Stored Value Cards – 08/18/16	08/18/16
Sale, repurchase, and transfer of title to gold not money transmission	08/03/16
Foreign (other state) credit union not conducting business in California	05/11/16
Receiving Money for Transmission and Agent of Payee Exemption	05/19/16
Not exempt as agent of payee or agent of government agency	05/04/16
Exemption for Nonprofit Community Service Organization that provides Credit Counseling Services	05/02/16
Exemption for Agent of Payee: Software Developer	02/08/16
Exemption for Nonprofit Community Service Organization	1/19/16
Money Transmission in this State – 01/19/16	1/19/16
Reporting Financial Institutions as Agents	10/29/15
Rebuttal of Acquisition of Control – 10/20/15	10/20/15
Rebuttal of Acquisition of Control -10/05/15	10/05/15
Yankee CDs as Eligible Securities	10/02/15
Exemption for Agent of Payee Payment-Processing Service	09/11/15
Funds Held in Custodial Account as Eligible Securities	08/26/15
Receiving Money for Transmission	08/24/15
Foreign Activity Initiated by Customers in the United States	08/14/15
Foreign Currency Eligible Securities	07/30/15
Approval to Acquire Control	07/17/15
Exemption for agent of state child support agency	06/15/15
Exemptions for agent of payee and payroll processing service	05/15/15
Stored Value Gift Cards and Digital Goods	03/23/15
Eligible Securities – foreign currencies	03/09/15
Money transmitter application in mobile phone application; loan payments via check image and ACH transfer	02/24/15

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Last updated: Nov 7, 2022 @ 5:28 pm