Southwest · Last reviewed 2026-07
Texas money transmitter license
Requirements, bond, timeline, and crypto notes for the Money Transmitter License — for companies preparing an application or diligence questionnaire.
Key requirements
- Regulator
- Texas Department of Banking
- License
- Money Transmitter License
- Statute
- Texas Finance Code ch. 152 (Money Services Modernization Act); Supervisory Memorandum 1037 (rev. Jan 2025)
- Surety bond
- Often $300,000–$2,000,000 depending on volume
- Net worth
- Evaluated relative to volume under chapter 152; verify current thresholds
- NMLS
- Required
- Application fee
- Roughly $1,000–$3,000 plus NMLS fees, as of our last review
- Typical timeline
- 5–10 months
Crypto & virtual currency
Texas is one of the most important markets and one of the clearest on crypto policy. Supervisory Memorandum 1037 (revised January 2025) states that non-stablecoin virtual currency is generally not "money" for money transmission purposes, while certain payment stablecoins may be, and fiat legs of crypto transactions are licensed activity. Bonds often run $300,000–$2,000,000. Map each product carefully: a pure bitcoin exchange may sit outside the MTL, while a USDC redemption flow or dollar on-ramp generally does not. Confirm borderline models with the Department of Banking in writing. Requirements change frequently — always verify current figures and interpretations directly with the state regulator before filing.
Frequently asked questions
Does Texas require a license for crypto exchanges?
It depends. Under SM-1037 (rev. Jan 2025), non-stablecoin virtual currency is generally not money, so crypto-only exchange of bitcoin and similar assets often falls outside the MTL. Payment stablecoins may be treated as money, and any fiat leg requires licensure. Map each flow carefully.
What are Texas bond requirements?
As of our last review, bonds often run $300,000–$2,000,000 depending on transmission volume. Verify the current schedule with the Texas Department of Banking based on projected Texas activity.
How should I treat stablecoins in Texas?
SM-1037 indicates certain payment stablecoins may constitute money for transmission purposes even where non-stablecoin VC does not. Analyze stablecoin issuance, redemption, and transfer flows separately from bitcoin/ether exchange, and confirm borderline designs with the Department.
How long does Texas licensing take?
Plan for 5–10 months on a complete application. Texas is a high-volume shop with substantive review of financial condition and AML — incomplete flow-of-funds documentation is a common deficiency.
This page is educational and does not constitute legal advice. Requirements change frequently — always verify current figures and interpretations directly with Texas Department of Banking before filing.