California’s Money Transmission Act (Cal Fin Code Section 2000 et seq.) underwent another facelift this year. AB 2209‘s changes were signed by Governor Brown last month, and will go into effect January 1, 2015.
Some key changes & clarifications:
1. A Big One: Exemption for an “Agent of Payee”
“Section 2010 (l) A transaction in which the recipient of the money or other monetary value is an agent of the payee pursuant to a preexisting written contract and delivery of the money or other monetary value to the agent satisfies the payor’s obligation to the payee.”
2. Reports required if money transmission was made by mobile device or other electronic application
Licensees must also report whether money transmission activity was made via mobile or other electronic application in addition to other reporting requirements, such as transaction volume, etc.
3. Changes to various disclosure, notice and receipt requirements for transactions made via the web or on mobile devices.