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: Feb 3, 2023 @ 11:21 am