By Deborah S Thoren-Peden, JiJi Park, Elsa S Broeker and Amy L Pierce
On 11 July 2013, Connecticut governor Dannel Malloy signed into law Senate Bill 911, which amends the state’s Money Transmission Act to remove the explicit exemption from licensure previously afforded to agents of exempt entities, including agents of federal and state banks and credit unions. Connecticut Senate Bill 911 (SB 911) amends Connecticut’s Money Transmission Act (the Act), Conn. Gen. Stat. §§ 36a-595 et seq., to revise among other things, the agent licensing requirements and exemptions.
Most notably, the amended law distinguishes between agents of licensed money transmitters and agents of entities or persons exempt from licensing under the Act, such as banks and credit unions organised under the laws of Connecticut, another state or the US.
Beginning 1 October 2013, an agent of an entity or person exempt from licensing under the Act may be subject to licensure if the agent engages in the business of money transmission or the advertising or soliciting of money transmission services for itself or on behalf of an entity or person otherwise exempt from licensing under the Act. Conn. Gen. Stat. § 36a-597(a), as amended…
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