Regulatory Alerts2025-06-20
Money Transmitter Modernization Act Guidance – Tangible Net Worth and Virtual Currency
The Conference of State Bank Supervisors issued guidance clarifying that money transmitters must include all virtual currency assets in total assets when calculating the minimum tangible net worth requirement under the Money Transmission Modernization Act. While virtual currency is generally classified as an intangible asset that must be subtracted from total assets to determine tangible net worth, this guidance permits licensees to exclude such assets if they hold corresponding customer liabilities denominated in the same virtual currency. This exception applies only to unencumbered assets held for ordinary course business transactions, ensuring that capital requirements reflect the actual risk profile of satisfying specific customer obligations.