There’s been a quiet—but meaningful—shift underway in the world of money transmission licensing (MTL) examinations. For years, companies have grown used to navigating a maze of state-specific requirements, each regulator with their own exam schedules, areas of focus, and documentation quirks. It’s never been easy, but at least it was familiar.
Now, that landscape is changing. And while the shift promises more alignment, it doesn’t mean less scrutiny—in fact, the opposite may be true.
From Siloed to Synchronized: The Rise of Unified Exams
Historically, MSBs (Money Services Businesses) approached regulatory exams like a patchwork quilt: prepare for California one year, Washington the next, maybe Texas the year after. But increasingly, states are banding together to conduct multi-state, multi-year examinations—a more collaborative model under what’s being called networked supervision.
This shift isn’t just theoretical. In a major exam that concluded last year (2024), California, along with Colorado, Kentucky, Massachusetts, New Hampshire, Ohio, Texas, and Washington, conducted a joint investigation into Block that ultimately resulted in a settlement and consent order for BSA/AML violations. It was a signal: unified exams are here, and they’re no longer exploratory—they’re enforcement-driven.
States like California and Washington are at the forefront of this push for networked supervision across MSBs. Many other state regulators across non-MSB financial services are taking part in joint exams, reflecting a broader trend across supervisory bodies: regulators are embracing shared frameworks to reduce redundancy, strengthen consumer protection, and get a fuller picture faster.
Why It’s Happening and Why It Matters
The goal of networked supervision is efficiency. If State A just examined your data security program, and State B wants to look at the same thing, why start from scratch? Through shared findings and coordinated scopes, regulators can cover more ground with fewer resources. For companies, this can sometimes mean fewer exams and less back-and-forth.
But here’s the flip side: when states pool information, they gain more visibility. That means issues that might have stayed local—or even gone unnoticed—can now become multi-state matters. You’re not being examined eight times, but if something’s wrong, you may be fined by eight different regulators.
This increased transparency is already uncovering patterns. Some regulators report a steady uptick in “less than satisfactory” MTL licensees—though they haven’t publicly drilled into exact reasons, many suspect familiar culprits: permissible investment practices, liquidity coverage, tangible net worth, and cybersecurity hygiene.
It’s also worth remembering that while exams are becoming more unified, priorities can still differ by state. For example, Pennsylvania continues to place high importance on advertising and marketing compliance—something that may only intensify as federal regulatory action cools off.
In fact, the Consumer Financial Protection Bureau (CFPB), before its recent leadership upheaval, explicitly encouraged state regulators and AGs to build “mini-CFPBs” and assert more aggressive enforcement and market-monitoring authority. That torch has already been picked up in many corners, (for instance NYDFS just hired a top CFPB executive to lead its consumer protection work) and it’s adding fuel to the fire of this unified examination trend.
What to Expect Going Forward: Raised Floors, Not Lowered Ceilings
It’s tempting to assume that unified exams mean smoother sailing for MTL licensees. And in some ways, that’s true: fewer duplicative requests, more predictability in scope. But in reality, the floor is being raised, not the ceiling lowered.
More data means earlier identification of red flags. More coordination means greater enforcement reach. And more visibility means that a small issue in one state can quickly become a multi-state firestorm.
In short: unified does not mean lenient. It means aligned—and alignment brings speed, scope, and consequences.
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