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July 03, 2020

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July 02, 2020

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State regulators agree to multistate licensing process for money service businesses

The Conference of State Bank Supervisors (CSBS) announced yesterday that seven states have agreed to a multi-state compact that, according to the CSBS, “standardizes key elements of the licensing process for money services businesses (MSB).”

The seven states consist of Georgia, Illinois, Kansas, Massachusetts, Tennessee, Texas and Washington.  The CSBS expects other states to join the compact.  Under the compact, if one participating state has reviewed key elements of a company’s operations in connection with the company’s application for money transmitter license (IT, cybersecurity, business plan, background check, and compliance with the federal Bank Secrecy Act), the other participating states will accept that state’s findings.

The CSBS describes the compact as “the first step among state regulators in moving towards an integrated, 50-state system of licensing and supervision for fintechs.”  It is expected to significantly streamline the MSB licensing process.

Copyright © by Ballard Spahr LLPNational Law Review, Volume VIII, Number 38


About this Author

John Socknat, Partner

John D. Socknat is the Co-Practice Leader of Ballard Spahr's Mortgage Banking Group. John uses his knowledge and breadth of the business issues affecting the residential and commercial mortgage banking industries and the legal landscape to advise clients on compliance and licensing matters under state and federal law.

John's clients include mortgage and consumer finance companies, financial institutions, servicers, collection agencies, title companies, real estate brokers, and secondary-market investors. He focuses his practice in matters...

Stacey Valerio, Of counsel
Of Counsel

Stacey L. Valerio focuses her practice on the mortgage banking industry. Stacey has more than 20 years' experience, including nearly a decade at the State of Connecticut Department of Banking's Consumer Credit Division, where she handled licensing and enforcement matters, with primary focus on the mortgage industry. In that role, she counseled the Consumer Credit Division, served as an administrative hearing officer, and drafted legislation, legal opinions, and rulings. The position also involved working with various other state and federal agencies, including the state Office of the Attorney General, the FBI, and the CFPB. Stacey was active with the State Regulatory Registry LLC's Lawyers Committee for many years, serving as its chair from 2014 to 2017, and was actively involved with the American Association of Residential Mortgage Regulators (AARMR), serving as a director and an officer.

Stacey has experience counseling clients on a wide variety of regulatory matters at the federal and state levels. Her experience includes licensing and regulatory compliance, legislative initiatives, contract drafting, and the Nationwide Multistate Licensing System & Registry (NMLS).


  • George Washington University National Law Center (J.D. 1995)

Member, The George Washington Journal of International Law & Economics

  • University of Pennsylvania (B.A., summa cum laude, 1991)

Phi Beta Kappa

  • Wellesley College (1988-1989)


  • Connecticut
  • Massachusetts
  • District of Columbia
  • U.S. Court of Appeals for the Federal Circuit