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Considering money transmitter licenses for your fintech? You've probably heard MTLs are expensive and complex, and although there's truth to that, Brico is helping you get them more easily than ever before. The purpose of this post is to demystify the process, providing you with the right information to budget accurately and avoid surprises.
Most guides only cover MTL application fees, but that's just the beginning. The total cost of ownership (TCO) for money transmitter licenses includes initial application costs, ongoing maintenance fees, and scaling surety bonds that grow with your business. Understanding your full TCO is essential for accurate financial planning and ROI analysis.
This guide covers everything: the upfront costs to get your licenses and the ongoing costs to keep them. Whether you're a payment company, digital wallet, or launching a new money movement product, here's what to expect.
Why US Licensing Is Uniquely Complex
If you're a founder—especially one who's launched in other markets first—the US licensing structure may catch you off guard. Unlike most countries, the United States doesn't have a single national money transmission license.
In the UK, you apply to the FCA. In the EU, PSD2 creates a passporting framework. In most of Latin America, Asia, and Africa, there's one national regulator to work with. The US is fundamentally different: money transmission is regulated at the state level, not federally.
This means obtaining authorization to operate nationwide requires licensing from up to 53 separate jurisdictions: each of the 50 states, plus Washington DC, Puerto Rico, and US territories. Each jurisdiction maintains its own:
- Application forms and investigation fees and required documentation
- Net worth and permissible investment requirements
- Surety bond ranges and formulas (often tied to transaction volume)
- Background check, credit, and fingerprinting procedures
- Approval timelines and examination cadence (anywhere from 2 months to 18+ months)
- Renewal schedules and quarterly reporting obligations
For teams used to launching with a single regulatory approval, this is a fundamentally different challenge. It's why US expansion often takes longer and costs more than entering other major markets.
Because laws and fees change, teams must treat any static chart as a planning tool, then validate against current statutes, regulations, and NMLS checklists before making commitments.
Related: LB Finanzas | Demystifying MTLs for U.S. Expansion
What Are the Costs Involved for Money Transmitter Licenses?
MTLs require two types of investment: initial application costs and ongoing maintenance costs. Let's break down both.
Part 1: MTL Application Costs (Year One)
What Goes Into Initial MTL Costs?
State Application Fees Each state charges its own fees, ranging from a few hundred to several thousand dollars. The variation is significant: California charges $5,000 while Delaware charges just $172.50.
Surety Bonds Surety bonds protect consumers and are a critical part of licensing. Costs vary based on transaction volume, business model, company financials, and your overall risk profile. Expect to pay 1-3% of the total bond amount as an annual premium.
Registered Agents + Secretary of State Fees To qualify to do business and receive service of process in each state, entities usually appoint a registered agent and file Secretary of State or equivalent registrations. These fees run approximately $100-200 per state, covering your registered agent and state filing requirements.
Background Checks & Fingerprinting Many states require FBI and state criminal checks, credit reports, and associated NMLS processing fees per control person. These can add several hundred to several thousand dollars overall, depending on the number of directors, officers, and significant owners.
Under these assumptions, total Year‑One direct licensing outlay for a full 50‑state + DC footprint, including background checks and fingerprinting costs, falls in the $250,000–$350,000 range, excluding legal, advisory, and internal team costs.
Breaking Down the Year One Costs by Each State
Here’s a full breakdown of all 50 states broken by the major cost category. Please note that surety bonds are an estimated amount and can range between 1-3% of the total bond amount.
Related: MTL Financial Requirements and Net Worth Readiness
Part 2: MTL Maintenance Costs (Year Two and Beyond)
Getting licensed is just the beginning. Maintaining your MTLs also has associated costs each year. . That said, they are an asset you can monetize, so think about them as a long term investment.
What Goes Into Annual Maintenance Costs?
License Renewal Fees & Assessments States charge annual renewal fees plus assessments. Assessments vary by state; some are based on transaction volume, others charge a fixed fee to all MTL holders (similar to a property tax).
Surety Bonds Bond costs in year two and beyond are equal to or greater than year one.
- Bond amounts may be recalculated based on higher transaction volumes and risk profile updates.
- Underwriting may adjust pricing bands over time.
Here's the kicker: for high‑growth businesses with large transaction volumes in many states, annual bond premiums across all jurisdictions can be several hundred thousand dollars. In aggressive growth scenarios, aggregate premiums can reach the high six figures. A champagne problem, but one worth knowing about.
Registered Agents + Secretary of State Fees These fees increase slightly in maintenance years, typically running $200-400 per state.
Total Annual Maintenance Costs (All 50 States + DC)
Note: Surety bond costs scale with transaction volume. High-volume companies will pay significantly more.
In this type of scenario, a full 50‑state + DC footprint often generates ~$225,000–$280,000+ in maintenance‑year direct costs, before internal staff, legal, and advisory costs.
Maintenance Costs by State
Montana and Other Special Cases
Montana is currently unique in that it does not maintain a dedicated state‑level money transmitter license regime, and the Division of Banking and Financial Institutions has stated that it does not regulate money transmitters as such. However:
- Businesses may still need other state licenses depending on their activities.
- Federal MSB registration with FinCEN is still required where the business meets the federal definition of a money services business.
When modeling “$0 MTL cost” for Montana, teams should treat that as “no dedicated money transmitter license fee” rather than “no licensing or compliance obligations of any kind.”
Key Takeaways
Based on 2025 assumptions.
- Highest-cost states for applications: Texas ($10,000), Hawaii ($10,000), Colorado ($7,500)
- Highest-cost states for maintenance: California ($12,275), Texas ($8,168), Pennsylvania ($5,100), Michigan ($5,100), Kansas ($5,100), Washington ($5,100)
- Highest surety bond states: Pennsylvania, Kentucky, Michigan, New York, Puerto Rico
- Budget tip: California alone accounts for 13% of annual renewal costs in the model above. If you're prioritizing states, factor maintenance costs into your ROI calculations, not just application fees.
Plan Your MTL Budget With Confidence
MTLs are a significant investment, but they're also a valuable asset that enables product innovation and healthy margins. Understanding the full cost picture—both upfront and ongoing—helps you make informed decisions about your licensing strategy.
Ready to discuss your MTL roadmap? Contact Brico to explore how we can help you navigate the licensing process efficiently.
Disclaimer: This article is for informational purposes only and does not constitute legal, financial, or regulatory advice. Brico is not a law firm and does not provide legal counsel. Licensing requirements vary by state and depend on your specific business model and circumstances. You should consult with qualified legal counsel before making any licensing decisions or taking action based on this content.
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