Division of Financial Institutions Final Opinions Letters You can search the list by entering any part of Letter Subject or Date in the Search field. Search: Please note: For full functionality of this page, JavaScript must be enabled. Letter Subject Date MTA – Registered clearing house and payment processing service exemptions 10/13/20 International Settlement Service – Decline to Opine – 10/06/20 10/06/20 Video game – digital assets – 08/28/20 08/28/20 Sale of Foreign Currency – 08/06/20 08/06/20 Payment processing service not exempt as agent of payee – 08/05/20 08/05/20 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 2/8/16 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 DFI Final Opinions Letters Archives 2009-2011 Orders Key Consumer Links Consumer Alerts Consumer Advisories Search for DFPI Licensees Licensees and Industries Regulated by the DFPI Actions, Orders and Administrative Hearing Decisions File a complaint Submit a Public Records Request News & Info LinksNews Newsroom Press Releases Monthly Bulletins Important Notices Information DFPI Forms Resources Last updated: Oct 19, 2020 @ 10:51 am
