RI Currency Transmitter Transition Checklist (Company) - NMLS
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RI Currency Transmitter
Transition Checklist (Company)
CHECKLIST SECTIONS
General Information
License Fees
Requirements Completed in NMLS
Requirements/Documents Uploaded in NMLS
Requirements Submitted Outside of NMLS
GENERAL INFORMATION
Transition to NMLS
Companies holding the Rhode Island Division of Banking Electronic Money Transferor License or the Rhode
Island Division of Banking Sale of Check License are required to submit a license transition request through
NMLS by filing a Company Form (MU1) and an Individual Form (MU2) for each of their control persons by
December 31, 2019. The Currency Transmitter will be available in NMLS to submit the transition request starting
November 1, 2019. The transition to NMLS for this license is required.
Note: If you already have a record in NMLS and have submitted these forms in the past, you do not
need to re-enter your company information into NMLS. You will only need to identify the business
activities your company conducts and the states in which the various activities are conducted. Then, you
will select the appropriate license in RI, and complete a few state-specific fields.
It is important that current licensees have the appropriate transition number available when completing and
submitting their Company Form (MU1), so they are not charged a new application fee. The transition number
that licensees must use is their current RI License Number including any punctuation, capitalization, etc.
Example: 20200432MT
Any licensee that needs to amend or surrender a license (or execute any other action previously completed in
paper form must complete these actions within NMLS from November 1, 2019 onward. Paper forms will not be
accepted. RI encourages current licensees to update their information with RI by November 1, 2019, so there
will be no pending changes to submit at the time of transition.
On June 27, 2019, the Rhode Island State General Assembly passed House Bill 5847 Sub A entitled, An Act
Relating to Financial Institutions – Licensed Activities – Currency Transmissions (the “Act”). The Act makes
several changes (effective on January 1, 2020) to R.I. Gen. Laws 19-14 as they relate to the licensing of money
service businesses in Rhode Island. The major change is the creation of the Currency Transmission License,
which takes the place of both the Sale of Check and Electronic Money Transferor licenses. Entities will need to
obtain only one license to conduct such activity in Rhode Island. Please refer to the Act to see all changes.
Updated: 10/25/2019 Page 1 of 10Activities Authorized Under This License
This license authorizes the following activities…
o Electronic money transmitting
o Issuing or selling money orders or drafts
o Issuing or selling prepaid access/stored value
o Virtual currency exchanging and trading services
Document Uploads Guidance
Documents that must be uploaded to the Document Uploads section of the Company Form (MU1) in NMLS are
indicated in the checklist below. When uploading documents:
Follow the guidance in Document Upload Descriptions and Examples.
Only upload documents relevant to the company transition.
Only upload documents where there is a selectable document category. If inappropriate documents
are uploaded that should not be, you will be contacted by your regulator and asked to remove them
from NMLS.
Do not upload the same company documents multiple times. Generally, unless the document is
state-specific, if the document has already been uploaded for another state, a new upload is not
required unless changes have been made.
If a document previously uploaded has been revised, delete the old document and replace it with
the new document (history of the old document will remain in NMLS).
For state-specific documents (e.g., Surety Bonds), be sure to indicate the applicable state.
Helpful Resources
Transitioning an Existing Company License Quick Guide
Document Upload Descriptions and Examples
Individual Form (MU2) Filing Quick Guide
Financial Statements Quick Guide
Payment Options Quick Guide
License Status Definitions Quick Guide
Agency Contact Information
Contact the Division of Banking licensing staff by phone at (401) 462-9503 or send your questions via email to
dbr.bankinquiry@dbr.ri.gov for additional assistance.
For U.S. Postal Service Overnight Delivery
State of Rhode Island
Department of Business Regulation
Division of Banking
1511 Pontiac Avenue
Building 68-1
Cranston, Rhode Island 02920
THE APPLICANT/LICENSEE IS FULLY RESPONSIBLE FOR ALL OF THE REQUIREMENTS OF THE LICENSE FOR WHICH THEY ARE
APPLYING. THE AGENCY SPECIFIC REQUIREMENTS CONTAINED HEREIN ARE FOR GUIDANCE ONLY TO FACILITATE APPLICATION
THROUGH NMLS. SHOULD YOU HAVE QUESTIONS, PLEASE CONSULT LEGAL COUNSEL.
Updated: 10/25/2019 Page 2 of 10LICENSE FEES - Fees collected through NMLS are NOT REFUNDABLE OR TRANSFERABLE.
Complete RI Currency Transmitter Submitted via…
RI License/Registration Transition Fee: $1,105 NMLS (Filing
submission)
This fee includes an annual license fee of $1000, Training and
Technology fee of $50 and a Filing fee of $55.
NMLS Transition Fee: $100
This is your 2019/2020 NMLS Annual Processing Fee
Credit Report for Control Persons: $15 per control person. NMLS (Filing
submission)
FBI Criminal Background Check for MU2 Individual: $36.25 per person. NMLS (Filing
submission)
Uniform Authorized Agent Reporting Annual Processing Fee: An annual fee of NMLS (Agency Fee
twenty-five cents ($0.25) for each active authorized agent/delegate location Invoice)
reported through NMLS is invoiced on November 1st.
There is no fee for the first 100 active agents reported (Companies with 100
agents or less are not subject to the UAAR Processing Fee).
The fee is capped at $25,000 per licensee in any one year.
The invoiced amount is based on the number of active agents in the system as
of August 16th, (day after third quarter reporting deadline).
See the Uniform Authorized Agent Reporting Processing Fee Fact Sheet for
more information.
Updated: 10/25/2019 Page 3 of 10REQUIREMENTS COMPLETED IN NMLS
Complete RI Currency Transmitter Submitted via…
Submission of Company Form (MU1): Complete and submit the Company NMLS
Form (MU1) in NMLS. This form serves as the transition request for the
license/registration through NMLS.
See the Transitioning an Existing License Quick Guide for instructions on how to
submit the transition request.
When selecting your license in the Company Form (MU1), you will be asked to
enter your existing license number. Be sure to enter the company’s Rhode
Island License Number as the transition number.
All current licensees/registrants must transition their license onto NMLS on
or before December 31, 2019.
Financial Statements: Upload financial statements, including a Balance Sheet
NMLS
and Income Statement, prepared in accordance with Generally Accepted
Accounting Principles representing the Applicant’s (and all entities holding a
10% or more direct equity interest in Applicant, including any holding
companies) financial position within the ninety (90) day period immediately
preceding the filing of the jurisdiction specific checklist. If Applicant is a startup
company then Applicant need only upload a Balance Sheet. Financial
statements must reflect a positive net worth at all times.
NOTE: Financial statements are uploaded separately under the Filing tab and
Financial Statement submenu link. See the Financial Statement Quick Guide for
instructions.
Authorized Agents (Delegates) Locations: Licensees must use the NMLS NMLS
Uniform Authorized Agent Reporting (UAAR) functionality to report Authorized
Agents. Upon license approval, applicants are required to utilize the UAAR to
upload a list of agents who are authorized to conduct money services
businesses in the state of Rhode Island on the Applicant’s behalf. Agent
adjustments (additions, deletions, and modifications) must be submitted
through the UAAR on a quarterly basis, even if there are no changes to report.
For more information, consult the NMLS Resource Center.
Other Trade Name: If operating under a name that is different from the NMLS
applicant’s legal name, that name (“Trade Name”, “Assumed Name” or “DBA”)
must be listed under the Other Trade Names section of the Company Form
(MU1). Rhode Island DBR does not limit the number of other trade names.
Resident/Registered Agent: The Resident/Registered Agent must be listed NMLS
under the Resident/Registered Agent section of the Company Form (MU1) and
must match the information currently on record with Rhode Island Division of
Banking.
Updated: 10/25/2019 Page 4 of 10Primary Contact Employees: The following individuals must be entered into NMLS
the Contact Employees section of the Company Form (MU1).
1. Primary Company Contact.
2. Primary Consumer Complaint Contact.
Approvals and Designation: Enter the entity’s FinCen Registration Number. NMLS
Bank Account: Bank account information must be provided for the applicant’s NMLS
Operating and Primary Trust accounts, including accounts through which the
applicant’s payments instruments and prepaid access obligations will be paid in
the Bank Account section of the Company Form (MU1). Bank account
information is not required. The Bank Account section of the Company Form
(MU1) can be left blank.
Disclosure Questions: Provide a complete and detailed explanation and Upload in NMLS in the
document upload for each “Yes” response to Disclosure Questions made by the Disclosure Explanations
company or related control persons (MU2). section of the Company
Form (MU1) or
See the Company Disclosure Explanations Quick Guide for instructions.
Individual Form (MU2).
Qualifying Individual: Any person designated as a Qualifying Individual, f/k/a NMLS
Manager of Record of the main office must be identified on a company’s Form
MU1 filing and have a Form MU2 submitted along with the Form MU1.
This individual must have:
At least five (5) years’ experience in the Money Services Business
industry.
Hold physical employment at the main office (his/her) business
address must match the address listed as the “Main Office Address
on the Company Form.
Control Person (MU2) Attestation: Complete the Individual Form (MU2) in NMLS
NMLS. This form must be attested to by the applicable control person before it
is able to be submitted along with the Company Form (MU1).
Credit Report: Individuals in a position of control are required to authorize a NMLS
credit report through NMLS. Individuals will be required to complete an
Identity Verification Process (IDV) along with an individual attestation before a
license request for your company can be filed through NMLS. This
authorization is made when the Individual Form (MU2) is submitted as part of
the Company Form (MU1).
Updated: 10/25/2019 Page 5 of 10MU2 Individual FBI Criminal Background Check Requirements: The following NMLS
Individuals, as specified below, on the Company Form (MU1) are required to
authorize a FBI criminal background check (CBC) through NMLS.
Direct Owners
Natural Persons who directly or indirectly, own 10% or more of the
applicant.
Executive Officers
Executive Officers (CEO, President, Executive Vice President, Treasurer,
Secretary, CFO, COO, CIO, CCO) or those serving similar functions, and
any others required by the Director of Department of Business
Regulation.
Indirect Owners
Natural persons who own 10% or more of a direct or indirect owner of
the applicant.
Qualifying Individuals
All Qualifying Individuals, unless licensed as a Rhode Island Mortgage
Loan Originator.
After authorizing a FBI criminal background check through the submission of
the Company Form (MU1) and Individual Form (MU2), you must schedule an
appointment to be fingerprinted if new prints are required.
See the Criminal Background Check section of the NMLS Resource Center for
more information.
Note: If you are able to ‘Use Existing Prints’ to process the FBI criminal
background check, you DO NOT have to schedule an appointment. NMLS will
automatically submit the fingerprints on file.
Electronic Surety Bond: Electronic Surety Bond via NMLS in the amount of Electronic Surety Bond
$50,000 furnished and submitted by a surety company authorized to conduct in NMLS
business in Rhode Island.
See the ESB Adoption Table and the ESB for NMLS Licensees page of the NMLS
Recourse Center for more information.
Note: Surety bonds submitted via the Document Uploads section will not satisfy
this requirement.
Updated: 10/25/2019 Page 6 of 10REQUIREMENTS/DOCUMENTS UPLOADED IN NMLS
Complete RI Currency Transmitter Submitted via…
AML/BSA Policy: Upload the most recent version of Anti-Money Laundering Upload in NMLS: under
(AML) / Bank Secrecy Act (BSA) Policy and the most recent Independent Review the Document Type
of the AML/BSA Program. AML/BSA Policy in the
Document Uploads
AML/BSA Policy
section of the Company
This document should be named AML/BSA Policy [approval date mm-dd-yyyy]. Form (MU1).
Independent Review of AML/BSA Program
This document should be named AML/BSA Policy Independent Review [review
date mm-dd-yyyy].
Business Plan: Upload a business plan into NMLS identifying and describing the Upload in NMLS: under
activities the applicant intends to take in Rhode Island. The business plan the Document Type
should include a schedule listing the fees/charges the applicant plans to charge Business Plan in the
Rhode Island consumers for its services/products. Document Uploads
section of the Company
This document should be named [Company Legal Name] Business Plan.
Form (MU1).
Note: If the existing uploaded business plan already includes the above
information, an additional document does not need to be uploaded. A company
should only upload a single business plan. If state-specific material is required,
this information should be added to the existing uploaded business plan.
Certificate of Authority/Good Standing Certificate: Upload a State-issued and Upload in NMLS: under
approved document (typically by the Secretary of State’s office), dated not the Document Type
more than 60 days prior to the filing of the application through NMLS that Certificate of
demonstrates authorization to do business in Rhode Island Authority/Good
Standing Certificate in
This document should be named RI Certificate of Authority OR RI Certificate of
the Document Uploads
Good Standing].
section of the Company
Form (MU1).
Company Staffing and Internal Policies: Upload document(s) including Upload in NMLS: under
information on staffing and internal organizational policies and procedures. If the Document Type
submitting multiple policies, upload and name each policy separately. The Company Staffing and
document must include the following information: Internal Policies in the
Document Uploads
Information and Operational Security Policy
section of the Company
Business Continuity Policy Form (MU1).
Disaster-Recovery Policy
This document should be named [Name of Policy].
Updated: 10/25/2019 Page 7 of 10Flow of Funds Structure: Submit a description of each type of transaction or Upload in NMLS: under
service to be conducted. For each type, describe each step starting with the Flow of Funds Structure
first encounter with the consumer and ending at the completion of the in the Document
transaction when money is received by the beneficiary. Uploads section of the
Company Form (MU1).
This document should be named Flow of Funds Structure.
Note: If submitting multiple types of transactions or services to be conducted,
combine in single document for upload.
Formation Documents: Determine classification of licensee’s legal status and Upload in NMLS: under
submit a State certified copy of the requested applicable documentation Formation Document”
detailed below. Original formation documents and all subsequent in the Document
amendments, thereto including a list of any name changes. Uploads section of the
Limited Liability Partnership:
Company Form (MU1).
Certificate of Limited Liability Partnership; and This document should
Partnership Agreement (including all amendments). be named Formation
Limited Liability Company (“LLC”): Documentation [Date of
Articles of Organization (including all amendments); Creation (MM-DD-
Operating Agreement (including all amendments); YYYY)].
IRS Form 2553 or IRS Form 8832 if S-corp treatment elected; and
LLC resolution if authority not in operating agreement.
Corporation:
Articles of Incorporation (including all amendments);
By-laws (including all amendments), if applicable;
Shareholder Agreement (including all amendments), if applicable;
IRS Form 2553 if S-corp treatment elected; and
Corporate resolution if authority to complete application not in By-Laws or
Shareholder Agreement, as amended, as applicable.
Not for Profit Corporation
Documents requested of a Corporation; and
Proof of nonprofit status
o Internal Revenue Service (“IRS”) 501(c)(3) designation letter; or
o statement from a State taxing body or the State attorney general
certifying that: (i) the entity is a nonprofit organization operating
within the State; and (ii) no part of the entity’s net earnings may
lawfully benefit any private shareholder or individual; or
o entity's certificate of incorporation or similar document if it clearly
establishes the nonprofit status of the licensee; or
o Any of the three preceding items described, if that item applies to a
State or national parent organization, together with a statement by
the State or parent organization that the licensee is a local nonprofit
affiliate.
Management Chart: Submit a Management chart displaying the licensee’s Upload in NMLS: under
directors, officers, and managers (individual name and title). Must also identify Management Chart in
compliance reporting and internal audit structure. the Document Uploads
section of the Company
This document should be named [Company Legal Name] Management Chart.
Form (MU1).
Note: If the existing uploaded management chart already includes the above
information, an additional document does not need to be uploaded. A company
should only upload a single management chart.
Updated: 10/25/2019 Page 8 of 10Organizational Chart/Description: Submit a chart showing (or a description Upload in NMLS: under
which includes) the percentage of ownership of: Organizational
Chart/Description in the
Direct Owners (total direct ownership percentage must equate to
Document Uploads
100%)
section of the Company
Indirect Owners Form (MU1).
Subsidiaries and Affiliates of the licensee
This document should be named [Company Legal Name] Organizational Chart –
Description.
Note: If the existing uploaded Organizational Chart/Description already
includes the above information, an additional document does not need to be
uploaded. A company should only upload a single management chart.
Trust Account Authorization: Submit authorization allowing examination of Upload in NMLS: under
trust accounts used for the purpose of holding funds belonging to others. May Trust Account
require multiple documents when more than one account exists. Upload each Authorization in the
account authorization separately. Document Uploads
section of the Company
This document should be named [License Type]; [Indicate State]; [last 5 digits of
Form (MU1).
account number]. (eg. Debt Management, MD, xxxxx)
.
INDIVIDUAL (MU2) DOCUMENTS UPLOADED IN NMLS
Credit Report Explanations: Submit a line by line, detailed letter of explanation Upload in NMLS:
of all derogatory credit accounts along with proof of payoffs, payment under the Document
arrangements and evidence of payments made, or evidence of any formal Type Credit Report
dispute filed (documents must be dated). Accounts to address include, but are Explanations in the
not limited to: collections items, charge offs, accounts currently past due, Document Uploads
accounts with serious delinquencies in the last 3 years, repossessions, loan section of the
modifications, etc. Individual Form (MU2).
Note: Items regarding bankruptcy, foreclosure actions, outstanding judgments
or liens, or delinquent child support payments should be addressed in the
Disclosure Explanations section of your Individual Form (MU2).
This document should be named Credit Report Explanations – Sub Name –
Document Creation Date.
Updated: 10/25/2019 Page 9 of 10NMLS ID Number
Applicant Legal
Name
REQUIREMENTS SUBMITTED OUTSIDE OF NMLS
Complete RI Currency Transmitter Submitted via…
Sharing of Office Space: If applicant will occupy or share space with any other
Email to:
person/business at the proposed license location or within the same Suite/Unit
Emilia.giorno@dbr.ri.go
mail the following information:
v
The names of the other person/business and a description of the other
business; their relationship to Applicant; any other financial or non-
financial arrangements made between the businesses and any security
measures taken by Applicant to protect confidential consumer
information.
Updated: 10/25/2019 Page 10 of 10You can also read
