Last year, we noted that the Banking Department of the Vermont Department of Financial Regulation had taken the position that its money transmission law “does not exempt a payment processor or an agent of a payee from [money transmission] licensure.” Vermont’s Governor now has signed legislation that creates a statutory exemption from the money transmission licensing law for payment processors, provided that certain conditions are met. Given the somewhat unique nature of this exemption, however, payments services companies, whether payee agents, payment processors, platforms, or marketplaces, should review their compliance approaches in light of this new exemption.
Read our client alert.