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Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake

An intake that maps your money-movement flows to money-transmission licensing, BSA/AML obligations, and whether you need a sponsor bank or BaaS partner.

21 min interview2026 currentFree to generateAttorney finish by callPDF & Word export

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What is a Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake?

Built for any fintech that moves, holds, or facilitates money or crypto: neobanks, wallets, payment apps, payroll, marketplaces with payouts, crypto on/off-ramps, or BaaS builders.

Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake template, current for 2026

Distinguishes the agent-of-payee and money-transmission exemptions, flags the multistate MSB/MTL patchwork and the states' coordinated MTL licensing framework, folds in FinCEN MSB registration and a written BSA/AML program (KYC, sanctions, SAR/CTR, Travel Rule for crypto), and adds a 2026-current sponsor-bank / BaaS oversight and third-party-risk note reflecting heightened regulatory scrutiny of bank-fintech partnerships.

How HDAi does this differently

Unlike a static form, HDAi runs a guided interview and assembles your Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake as you answer. When you want it finished, a licensed Hart David Carson attorney reviews it and tailors it to your facts before you sign. The interview and the first draft are automated. The judgment belongs to an attorney.

What you’ll be asked

A short interview in plain language that asks only what this document needs.

Which company is being assessed? Identify the legal entity whose money-movement flows we are mapping. Enter the exact legal name, entity type, and jurisdiction so the memo names the correct regulated person.
As-of date for this assessment The date the analysis reflects. Licensing thresholds and rules change, so we fix the memo to a specific date.
Who is preparing this intake (firm/counsel)? Names the drafter/reviewing counsel for the file. This is a draft for licensed-attorney review, so we record who prepared it.
Primary business contact and title The client-side person who answered these questions, so follow-up and reliance are traceable.
Describe your business and product in plain language A short narrative of what you do and how money moves. This frames every licensing and BSA conclusion that follows.
What stage is the product? Pre-launch vs. live changes urgency: unlicensed live money movement is the highest-risk posture.
Which money-movement activities do you perform? Each activity maps differently to money-transmission (MT) statutes and federal MSB rules. Select all that apply.
Do you ever take possession or control of customer funds? Taking custody/control of funds (even briefly) is the single most important MT trigger. If a bank or licensed processor holds all funds and you never touch them, your analysis is very different.
Where are customer funds actually held, and in whose name? Identify each account that ever holds customer money, giving the holding institution, the account title, its status as a segregated for-benefit-of (FBO) account or not, and whether balances are pooled or per-customer. Safeguarding and permissible-investment analysis turns on this.
How are customer funds safeguarded relative to your operating funds? The MTMA-model permissible-investment and safeguarding rules require customer funds to be protected from the licensee's creditors. Segregated FBO deposit, a statutory trust, or permissible investments each carry different protections.
Which bank or trust company holds the customer-fund account(s)? Name the depository or trust institution safeguarding customer funds so counsel can confirm the account structure and any FBO/pass-through insurance representations.
If you touch crypto/digital assets, describe how FinCEN treats most crypto money transmission as MSB activity. The details (custodial vs. non-custodial, hosted wallets, on- and off-ramps) drive the analysis.
For your crypto activity, are you custodial or non-custodial? This distinction is decisive under FinCEN's virtual-currency guidance. A custodial model (you hold keys or control assets) is almost always MSB money transmission. Non-custodial software, where the user retains total independent control of keys and value, may fall outside it.
Do you issue or redeem your own stablecoin / token? Issuing a payment stablecoin implicates the federal GENIUS Act (2025) permitted-payment-stablecoin-issuer regime and possible state trust/limited-purpose charters, on top of MT analysis.
Who are your customers? Consumer vs. business, and US vs. foreign, change licensing scope, BSA risk, and sanctions exposure.
Which higher-risk customer types or geographies do (or will) you serve? The AML risk assessment must be tiered. Select every category present so counsel can calibrate enhanced due diligence, sanctions screening, and monitoring rules. Select 'none' only if you are confident.
In which US states/territories will you serve customers? Money transmission is licensed state-by-state. List target states, or say 'all 50': this sizes the licensing project.
Will money move cross-border (into or out of the US)? Cross-border flows add OFAC sanctions screening, funds-travel-rule, and possible foreign-licensing questions.
Expected monthly transaction volume (USD) Volume affects examiner attention, surety-bond and net-worth requirements, and BSA program scale.
Average transaction size (USD) Larger tickets raise CTR/SAR and structuring exposure; micro-payments shift the risk profile.
Expected number of active customers (12-month) Scale helps right-size the compliance program and vendor selection.
How do you intend to move the money? This is the central question. You either get your own licenses or ride a partner's rails (bank, BaaS, or licensed processor) as an agent or program manager.
Named sponsor bank / BaaS / processor partner (if any) If a specific partner is in play, we flag partner-specific obligations (oversight, program agreements, chartered-bank exemption reliance).
Describe your BaaS / middleware / vendor stack for moving money and compliance List each vendor in the money-movement and compliance chain (sponsor bank, BaaS middleware, processor, KYC/IDV vendor, monitoring/sanctions vendor, ledger provider) and what each one does. 2025-2026 interagency guidance scrutinizes exactly these arrangements.
Who performs KYC, transaction monitoring, and the customer-funds ledgering/reconciliation? Regulators expect clarity on who actually runs each control and who owns the 'for benefit of' ledger and its reconciliation. Diffuse or vendor-only ownership is a documented risk area.
If using a partner, will you rely on the bank / agent-of-payee / processor exemption from state MT licensing? Several state MT exemptions (agent of a bank, agent of the payee, licensed-processor pass-through) can eliminate your own licensing, but only if the structure fits in practice and the exemption exists in each state. The agent-of-payee exemption in particular is state-specific and unavailable or narrowed in several key states. We test that.
Are you registered with FinCEN as an MSB? Federal MSB registration (BSA) is separate from state licensing and is due within 180 days of becoming an MSB.
Do you have a written BSA/AML compliance program today? An MSB must have a risk-based AML program (policies, BSA Officer, training, independent testing). We assess current maturity.
Who is (or will be) your BSA/AML Compliance Officer? Every AML program must designate a responsible officer. Name the person or note 'to be hired'.
Which BSA/AML controls do you have or plan? Maps your current controls against the required program elements so we can flag gaps.
Which consumer-protection and data-security controls are in place or planned? Money movement usually triggers EFTA/Regulation E error-resolution and disclosure duties, and holding customer data triggers the GLBA Safeguards Rule. Regulators and sponsor banks now examine these directly. Select all that apply.
Summarize any complaint, chargeback, fraud-loss, or dispute history Provide volumes and trends, including the chargeback ratio, fraud-loss rate, consumer complaints (including any filed with the CFPB or a state regulator), and any patterns. If pre-launch, say so and describe projected controls.
List your control persons and 25%+ beneficial owners, with background and any regulatory or criminal history State licensing and NMLS require control-person and beneficial-owner disclosures, fingerprinting, and background checks. For each control person or 25%+ owner give name, role/title, ownership %, and disclose any prior or pending regulatory action, license denial/revocation, litigation, bankruptcy, or criminal matter. Accuracy here is critical; omissions surface in licensing.
Has any regulator ever contacted, examined, investigated, or taken action against the Company or its control persons? Prior or pending regulator contact materially affects the licensing path and must be disclosed. This includes inquiries, examinations, subpoenas, cease-and-desist letters, consent orders, MSB registration revocations, and state-AG or CFPB matters.
Describe the regulator contact, action, or pending matter Identify the regulator, the date, the nature of the matter, its status or resolution, and any resulting undertakings. This is privileged intake for counsel.
Describe your surety-bond, net-worth, and audited-financials capacity State MT licensing requires minimum net worth, surety bonds (often scaled to volume and states), and, in many states, audited financial statements. Describe current net worth, available bonding capacity, and whether audited financials exist, so counsel can size the licensing project against capital.
Are you considering an alternative charter path instead of, or alongside, state MTLs? Depending on the model, a state trust-company charter, a state limited-purpose/special-purpose charter, or an OCC path can be an alternative or complement to 50-state MT licensing. This flags whether to scope that analysis.
List any money-transmitter or related licenses you already hold Existing licenses (any state MTL, NMLS presence, trust charter) change the scope of remaining work.
Target launch or expansion date Licensing can take many months; we sequence the plan against your timeline and flag where the date is unrealistic without a partner path.
Risk posture for going to market Sets how conservative the recommended path should be: a regulated activity carries enforcement, unwind, and personal-liability risk.
Anything else we should know, or specific questions? Capture edge cases, prior regulator contact, investor diligence deadlines, or specific worries so the memo addresses them.

Frequently asked

About the Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake and how HDAi works.

What is a Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake? +

A Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake is an intake that maps your money-movement flows to money-transmission licensing, BSA/AML obligations, and whether you need a sponsor bank or BaaS partner. Any fintech that moves, holds, or facilitates money or crypto can start here: neobanks, wallets, payment apps, payroll, marketplaces with payouts, crypto on/off-ramps, or BaaS builders.

Is HDAi's Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake legally binding? +

The Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake is a working document, and nothing in it becomes binding by signature. It organizes the facts and decisions the next step needs (an attorney's work, a filing, or a board decision). Treat the output as preparation, and have a licensed Hart David Carson attorney finish whatever follows from it.

Do I need a lawyer to use this Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake? +

You can generate and download the Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake in minutes, free of charge. A licensed Hart David Carson attorney can then review it and tailor it to your facts before you sign, which is the part no template can do.

What makes this Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake current for 2026? +

How long does the Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake take? +

Estimated time about 21 min (41 questions), depending on how much you already know. The document assembles as you answer. Export it as PDF or Word, or send it to a Hart David Carson attorney for review.

Does this Fintech: Money-Transmitter / BSA Compliance & Sponsor-Bank Intake work in my state? +

HDAi's interview is state-aware. If you ask an attorney to finish the draft, a licensed Hart David Carson attorney confirms it against your state's requirements before you rely on it. Validity and required formalities vary by state.

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Reviewed by Jonathan D. Herpy, Sr., Senior Partner · Last updated October 2026 · Template and page reviewed · Every generated draft is a draft, not legal advice