Massachusetts requires a Foreign Transmittal Agency license from the Division of Banks for fintechs transmitting money in the state. This guide covers the regulatory framework, application process, and ongoing compliance requirements for fintech companies.
How to Get a Money Transmitter License in Massachusetts
Massachusetts is a major financial hub and an important state for fintechs targeting the Northeast US market. The state has its own regulatory framework for money transmission — referred to as a Foreign Transmittal Agency license — administered by the Massachusetts Division of Banks.
Does My Fintech Need a Massachusetts Money Transmitter License?
Under Massachusetts General Laws Chapter 169 (the Foreign Money Transmitters law), any person or entity engaged in the business of transmitting money on behalf of the public to foreign countries must be licensed as a Foreign Transmittal Agency. Additionally, businesses transmitting money domestically within or through Massachusetts may require licensure depending on the nature of their services.
The Massachusetts Division of Banks regulates both foreign and domestic money transmission activities. Companies offering payment services, digital wallets, or funds transfer services to Massachusetts residents or businesses should evaluate their obligations carefully.
Exempt from licensure are federally chartered banks, state-chartered banks regulated by the FDIC, and other specifically regulated financial institutions. Most non-bank fintech companies fall outside these exemptions and require licensure.
Key Requirements at a Glance
Fee and financial requirements are updated periodically. Always verify current amounts on NMLS or at the Massachusetts Division of Banks website before filing.
What You Will Need to Apply
Business Documentation
- Certificate of good standing from your state of formation (dated within 90 days of application)
- Articles of incorporation or organization
- Organizational chart showing full ownership structure including all entities and individuals with 10% or more ownership
- Audited financial statements — typically two to three years, or from inception for newer companies
- Business plan describing your money transmission activities, products, and projected Massachusetts transaction volume
- Description of all products and services involving money transmission
- List of all agents, sub-agents, and authorized delegates used in Massachusetts operations
Individual Background Checks
All principals, officers, directors, and controlling persons (typically those with 10% or more ownership or control) must complete MU2 forms in NMLS and submit fingerprints for criminal background checks through an NMLS-approved vendor. The Massachusetts Division of Banks reviews these records as part of its character and fitness assessment.
Surety Bond
A surety bond naming the Commonwealth of Massachusetts as obligee is required. The Division of Banks sets the required bond amount — verify the current requirement on NMLS before obtaining your bond. The bond must remain in force for the life of your license.
Net Worth Documentation
Applicants must demonstrate the required minimum tangible net worth through financial statements reviewed by the Division of Banks.
AML Compliance Program
A written AML/BSA compliance program must be submitted as part of the application. The program must be tailored to the specific products and customer base your company serves and must meet Bank Secrecy Act standards.
Agent Network Documentation
If you use authorized delegates or agents to conduct money transmission in Massachusetts, you must disclose these relationships and demonstrate adequate oversight of your agent network. Massachusetts has specific requirements around agent supervision and record-keeping.
How to Apply Through NMLS
- Create or log in to your NMLS company account at mortgage.nationwidelicensingsystem.org
- Complete the MU1 (company) form with full business information and disclosure history
- Add all required control persons and have each complete an MU2 form with their own NMLS account
- Upload all Massachusetts-specific required documents through the NMLS document upload system
- Arrange fingerprinting for all required individuals through an NMLS-approved vendor — complete this early as processing takes 4–8 weeks
- Pay the application fee through NMLS
- Monitor your NMLS dashboard for deficiency notices from the Division of Banks and respond within the allotted time to avoid delays
Ongoing Compliance After Approval
- Annual license renewal through NMLS — typically completed between November and January for the following year
- Annual financial reporting of Massachusetts transaction volumes and outstanding payment obligations
- Surety bond maintenance — your bond must remain in force at the required amount at all times
- Agent registration updates — any changes to your authorized delegate or agent network must be reported to the Division of Banks
- Material change notifications — ownership, leadership, and business activity changes must be reported within required timeframes
- Examination readiness — the Division of Banks conducts periodic examinations of licensed money transmitters
Massachusetts in a Multi-State Licensing Strategy
Massachusetts is a priority license for fintechs targeting the Northeast — particularly those serving Boston's dense population of financial services companies, universities, and technology firms. The Massachusetts Division of Banks is known for thorough application reviews, particularly around AML program quality and agent oversight. Fintechs that license in Massachusetts alongside New York, Connecticut, and Rhode Island achieve strong New England coverage. See our fintech licensing strategy guide for a full prioritization framework.
Frequently Asked Questions
Is Massachusetts money transmission licensing different from other states?
Massachusetts uses the term "Foreign Transmittal Agency" for its license category rather than "money transmitter license," though the core licensing requirements are similar to other NMLS states. The regulatory framework under Chapter 169 has some state-specific provisions around agent supervision that differ from standard money transmitter acts.
Does Massachusetts require a physical office?
Massachusetts does not require a physical in-state office for licensure. A registered agent with a Massachusetts street address is required.
Does Massachusetts license cryptocurrency businesses?
The Massachusetts Division of Banks has indicated that virtual currency activities that constitute money transmission may require a Foreign Transmittal Agency license. Cryptocurrency businesses should consult with qualified legal counsel and engage with the Division of Banks directly to assess their specific obligations.
How long does the Massachusetts application review take?
Review timelines typically range from 90 to 180 days after a complete application is submitted. Applications with deficiencies or incomplete documentation can take significantly longer. See our guide on how long it takes to get a money transmitter license for more context across states.
This article is for educational purposes only and does not constitute legal or compliance advice. Licensing requirements change. Verify current requirements directly with the Massachusetts Division of Banks and on NMLS before filing.
