Skip to main content
Menu Icon Menu Icon

InfoBytes Blog

Financial Services Law Insights and Observations

CSBS responds to regulators’ request on emerging technologies

Federal Issues CSBS State Issues Supervision Money Service / Money Transmitters Cryptocurrency Fintech

Federal Issues

On September 27, the Conference of State Bank Supervisors (CSBS) sent a letter to Ranking Member of the Senate Banking Committee Senator Pat Toomey (R-PA) detailing state bank regulators’ role in supervising money transmission and virtual currencies, in addition to recommending an activities-based approach to regulation. The letter is in response to a request by Senator Toomey for input on the regulation of financial technologies earlier this year. In Senator Toomey’s August 26 letter, he requested collection of public comments on proposed legislative language, among other things, to regulate emerging technologies. The Senator also requested that each proposal have a brief description that includes “how it will encourage the growth of cryptocurrency and blockchain technology” in the U.S. According to the letter from CSBS, state bank regulators are encouraging “Congress and federal regulators to focus on the activities at issue and making clarifications in existing laws, regulations, and interpretations,” and believe that “[a]n activities-based approach must be performed with collaboration from all stakeholders or risk one regulatory view overextending into areas where it would hurt innovation and consumers.” CSBS also points out that the Money Transmission Modernization Act established a regulatory baseline and represents a critical step in enhancing multistate harmonization in the money transmission industry. CSBS further discussed Networked Supervision, a strengthened collaboration which permits states to operate as a network. According to the letter, earlier this year, CSBS approved public priorities, which highlighted efforts that states will take to advance Networked Supervision  focused on money services businesses. CSBS states that these priorities “emphasize the states’ commitment to harmonization, collaboration, and innovation throughout the state regulatory system.”

Share page with AddThis