Money Transmitter License: Business Plan Requirements

Learn what regulators require in your MTL business plan. Get section-by-section guidance on financial projections, compliance, and risk management.

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Business plan documents with financial projections and charts spread across a desk, representing money transmitter license application requirements

A well-constructed business plan is the roadmap regulators use to assess your company's readiness, viability, and risk. States want to see how you'll operate, secure customer funds, scale responsibly, and comply with laws at every step. 

What Regulators Look For in MTL Business Plans

  • Clear description of business model, products, and target market
  • Evidence you understand legal responsibilities, anti-money laundering (AML), and consumer protection compliance
  • Realistic financial projections and operational plans tailored for money transmission
  • A business plan that's credible, well-organized, and specific to the money transmitter license—not generic

Required Sections and Components

Each state has its own nuance of what they want to see and they are quite strict about including state specific sections, so you should work with an expert like Brico to create these documents. But at a high-level your business plan should include:

  • Executive Summary
  • Business Description (company, mission, and objectives)
  • Market Analysis
  • Organization & Management (org chart, key personnel)
  • Product/Service Details
  • Operations & Technology
  • Regulatory Compliance & Risk Management
  • Marketing & Sales Plan
  • Financial Projections
  • Appendices (supporting documents, resumes, etc.)

Executive Summary Best Practices

  • Provide a concise overview of the business, business model, and strategic goals
  • Summarize key risks and your approach to address them
  • Highlight why your team and solution are uniquely qualified for licensed money transmission

Market Analysis Requirements

  • Define target market, customer segments, and industry trends
  • Include competitor analysis and your unique value proposition
  • Present realistic growth opportunities with supporting data

Operations and Technology Sections

  • Operational plan covering transaction lifecycle, staffing, and controls
  • Technology infrastructure—security protocols, data protection, and how technology enables compliance
  • Vendor management if using third-party services

Risk Management Documentation

  • Identification of operational, financial, cyber, regulatory, and reputational risks
  • Description of controls: AML program, transaction monitoring, and disaster recovery solutions
  • Policy and training documents showing ongoing compliance oversight

Common MTL Business Plan Mistakes

Avoid these frequent errors:

  • Using generic templates lacking money transmission specifics for each of the states. Your application will be delayed if you are not submitting the business plan exactly how the regulators want it
  • Missing or unrealistic financial and market analysis
  • Overlooking compliance, risk, and regulatory documentation
  • Unclear organizational structure and role definitions

FAQs

Why do states require specific business plan formats for money transmitter licenses?

Each state has its own nuance of what they want to see and they are quite strict about including state-specific sections. Your application will be delayed if you are not submitting the business plan exactly how the regulators want it, which is why working with an expert is recommended.

What are common mistakes to avoid in an MTL business plan?

Common mistakes include using generic templates that lack money transmission specifics for each state, missing or unrealistic financial and market analysis, overlooking compliance, risk, and regulatory documentation, and having an unclear organizational structure and role definitions.

What sections should be included in an MTL business plan?

An MTL business plan should include an executive summary, business description, market analysis, organization and management structure, product/service details, operations and technology, regulatory compliance and risk management, marketing and sales plan, financial projections, and appendices with supporting documents.

What do regulators look for in a money transmitter license business plan?

Regulators look for a clear description of your business model, products, and target market; evidence you understand legal responsibilities including AML and consumer protection compliance; realistic financial projections and operational plans tailored for money transmission; and a business plan that's credible, well-organized, and specific to the money transmitter license.

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