Division of Financial Institutions Final Opinions Letters

Letter Subject  Date
Quarterly Reporting Obligations 10/15/19
Agent of Payee Exemption – Online Platform for Goods or Services 10/10/19
Virtual Currency – 10/04/19 -3 10/04/19
Virtual Currency – 10/04/19 -2 10/04/19
Virtual Currency – 10/04/19 -1 10/04/19
Bitcoin ATMs not subject to MTA 10/01/19
Cryptocurrency Exchange Platform -10/01/19 10/01/19
Cryptocurrency Exchange Platform 09/30/19
Agent of Bank 08/26/19
Purchase of Cryptocurrency 08/01/19
Online Foreign Currency Exchange Services 07/18/19
Cryptocurrency Platform – Closed Loop Stored Value 06/25/19
MTA/ Agent-of-Payee 05/17/19
Providing program interface not money transmission 03/25/19
Agent of Affiliate Licensee 03/20/19
Payment processing service not exempt as agent of payee (Amended) 02/21/19
Payment processing service not exempt as agent of payee – 01/09/19 01/09/19
Payment processing service not exempt as agent of payee – 01/18/19 01/18/19
Technological/customer service support not money transmission 12/21/18
Sending instructions not money transmission 11/29/18
Payment processing service not exempt as agent of payee or factoring 11/14/18
Cryptocurrency Exchange Platform – 10/09/18 10/09/18
Digital Currency Dealer 10/09/18
Agent of payee – subsidiaries 09/11/18
Cryptocurrency Exchange – 08/15/19 08/15/18
Sale of Cryptocurrency Through an Exchange 07/06/18
Cryptocurrency Exchange 07/06/18
Agent of Payee Exemption – Successive Agents 04/05/18
Operator of a Payment System, Payroll Processing, Public Interest Exemption 02/27/18
Agent of Payee – Payment Processing – 02/27/18 02/27/18
Agent of Payee – Decline to Opine – Request for a legal opinion under Financial Code section 2010, subdivision (l) 02/20/18
Agent of Payee – Decline to Opine – Request for a legal opinion under Financial Code section 2010(l)  – 02/20/18 02/20/18
Agent of Payee – Decline to Opine – Request for a legal opinion   02/12/18
Agent of Payee Exemption – Goods or Services 02/06/18
Agent of Payee – Decline to Opine – Request for a legal opinion under Financial Code section 2010(l) – 01/04/18 01/04/18
Agent of Payee – Payment Processing – 12/21/17 12/21/17
Stored Value 06/06/17
Calculating Money Transmission Receivables 06/06/17
Exemption for agent of payee: Online games marketplace 05/08/17
Agent of a governmental subdivision 04/25/17
Calculating eligible securities 04/10/17
Tax payment service not exempt from the MTA 04/07/17
Receiving funds for reimbursement under money transmission law 04/07/17
Company Not Engaging in Money Transmission in California 04/07/17
Prepaid Card Reloading Service 11/29/16
Exemption based on public interest 11/07/16
Agent of payee exemption for payment processing service 11/03/16
Eligible Securities – FBO Account Titles 11/03/16
Eligible Securities/FBO Accounts 11/03/16
Reimbursement for foreign-currency sale is not money transmission. 10/06/16
Money Transmission in this State – 08/23/16 08/23/16
Lending Limits and Common Servicer 08/23/16
Exemption for Sale of Bank-Issued Stored Value Cards – 08/23/16 08/23/16
Exemption for Sale of Bank-Issued Stored Value Cards – 08/18/16 08/18/16
Sale, repurchase, and transfer of title to gold not money transmission 08/03/16
Foreign (other state) credit union not conducting business in California 05/11/16
Receiving Money for Transmission and Agent of Payee Exemption 05/19/16
Not exempt as agent of payee or agent of government agency 05/04/16
Exemption for Nonprofit Community Service Organization that provides Credit Counseling Services 05/02/16
Exemption for Agent of Payee: Software Developer 2/8/16
Exemption for Nonprofit Community Service Organization 1/19/16
Money Transmission in this State – 01/19/16 1/19/16
Reporting Financial Institutions as Agents 10/29/15
Rebuttal of Acquisition of Control – 10/20/15 10/20/15
Rebuttal of Acquisition of Control -10/05/15 10/05/15
Yankee CDs as Eligible Securities 10/02/15
Exemption for Agent of Payee Payment-Processing Service 09/11/15
Funds Held in Custodial Account as Eligible Securities 08/26/15
Receiving Money for Transmission 08/24/15
Foreign Activity Initiated by Customers in the United States 08/14/15
Foreign Currency Eligible Securities 07/30/15
Approval to Acquire Control 07/17/15
Exemption for agent of state child support agency 06/15/15
Exemptions for agent of payee and payroll processing service 05/15/15
Stored Value Gift Cards and Digital Goods 03/23/15
Eligible Securities – foreign currencies 03/09/15
Money transmitter application in mobile phone application; loan payments via check image and ACH transfer 02/24/15

DFI Final Opinions Letters Archives

2009-2011 Orders

Last updated: Oct 31, 2019 @ 1:35 pm