Nebraska Money Transmitters Act Updates
Summary
The Nebraska Department of Banking and Finance has updated the Money Transmitters Act (LB 474), effective October 1, 2025. Key changes include increased maximum surety bond requirements, adjusted application and renewal fees, and codified requirements for audited financials and timely transaction completion.
What changed
The Nebraska Department of Banking and Finance (NDBF) has enacted updates to the Nebraska Money Transmitters Act through LB 474, which will take effect on October 1, 2025. The amendments significantly alter surety bond requirements, increasing the maximum coverage from $250,000 to $500,000 based on average daily money transmission liability, while maintaining the minimum at $100,000. Application fees will rise from $1,000 to $1,500, renewal fees from $250 to $750, and a new $1,500 change-of-control fee is introduced. Additionally, the act codifies existing departmental practices regarding audited financial statements, requiring them within ninety days of the fiscal year-end, and establishes a ten-day timeframe for customer refund requests under specific conditions. The regulatory approach to networked supervision and cooperative state licensing is also formalized.
Money transmitters licensed in Nebraska must review LB 474 to ensure compliance by the October 1, 2025 effective date. This includes assessing current surety bond coverage to meet the new maximum, budgeting for increased application and renewal fees, and ensuring internal processes align with the codified requirements for audited financials and timely transaction completion and refunds. Failure to comply with these updated regulations could result in regulatory action by the NDBF.
What to do next
- Review LB 474 for compliance with updated Nebraska Money Transmitters Act requirements.
- Assess and adjust surety bond coverage to meet the new maximum of $500,000.
- Update internal processes to comply with codified requirements for audited financials and timely transaction completion/refunds.
Source document (simplified)
Updated Surety Bond Requirements This update maintains the lowest bond coverage required of $100,000 but increases the maximum bond coverage from $250,000 to $500,000, which is based on the newly defined “Average Daily Money Transmission Liability.” LB 474 retains the Department’s ability to file a claim on the bond on behalf of customers. Adjustment to Application and Renewal Fees LB 474 increases the application fee from $1,000 to $1,500, while increasing the renewal fee from $250 to $750, and establishing a change-of-control fee of $1,500 for licensees. Audited Financials This update also codifies current Department requirements for licensees to provide audited financial statements ninety days after the end of the fiscal year. The Department has granted reasonable extensions for licensees and will continue to do so. Timely Transmissions and Refunds LB 474 codifies a requirement for licensees to complete payment obligations within the time stated on the instrument entered between the customer and the licensee, unless fraud is suspected. LB 474 establishes a process for refunds for transactions within ten days of written request from the customer under certain conditions. Networked Supervision LB 474 codifies the Department’s existing practice of leveraging a networked supervision approach to regulation, in which the Department can coordinate examinations with other state agencies and enter into information sharing agreements with other state or federal agencies. The Department has utilized this cost-saving and best-practice approach for both mortgage banker licenses and money transmitter licenses. Consistent State Licensing The update codifies the Department’s current practice of utilizing a cooperative approach among state regulators to review applications. Questions Licensees and applicants should review LB 474 to ensure compliance with the updates to the Nebraska Money Transmitters Act. If you have questions, please call NDBF at (402) 471-2171 or email dob.consumerfinance@nebraska.gov. ###
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