That's mostly right to my reading, but FinCEN letters are not laws. They're clarifications about regulations published in the Federal Register which are themsel

That's mostly right to my reading, but FinCEN letters are not laws. They're clarifications about regulations published in the Federal Register which are themselves clarifications about laws. FinCEN has published other letters that distinguish between money transmitters and "payment processors," the latter being companies that work exclusively on behalf of merchants to facilitate payments. Even though this interpretive ruling has the effect of a federal regulation, state agencies such as the California DFI choose to actively ignore these rulings and make up their own. So, what is California's interpretation? We don't know, because as Commissioner Barnes pointed out last Monday, the DFI hasn't issued any of its own interpretive rulings about the Money Transmission Act, ever, and before it does--even though it plans to--the legislature will likely amend the law, which means they'll delay some more. Now multiply this mess by 47. That's how clear it is. If you really want the details, my comment letter to the legislature is a good place to look. http://www.plainsite.org/flashlight/download.html?id=31313747 http://www.plainsite.org/flashlight/download.html?id=3131374... P.S. I'm not a lawyer. Don't listen to me.