Regulatory Alerts2002-11-22
Pennsylvania Department of Banking Letter on Money Transmission Activity
The Pennsylvania Department of Banking determined that a company and a distributor operating a prepaid debit card program must obtain licenses under the state Money Transmitter Act. The Department concluded that these entities are transmitting money for a fee and do not qualify for exemptions because no formal agency relationship exists with the issuing bank. Licensing is only waived if a formal agency relationship is established between the entities and the bank or between the company and the distributor.
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