Law or Regulation: CA AB-1489 (ULC Model Act) NY Bitlicense CA Money Transmission Law TX Money Transmission Law Basic Info: California Assembly members have The Bitlicense was promulgated in NY in 2015. CA has a money transmission licensing law like Texas also has a money transmission introduced a model law from the Unlike the ULC model act, it is a regulation rather 53 other states and territories. As with several licensing law. The Texas regulator has said ULC. It has yet to pass. than a law and the text is completely different. states, the text of the law may require that businesses dealing only in companies to get licensed. Unlike do not need liceses but other states, the regulator has refused to either exchanges handling fiat money as well as grant licenses to cryptocurrency companies or cryptocurrency do need licesnses. publicly say that licensing requirements don't apply. How is the category of Businesses with “the power to Businesses that do any of the following: Businesses that “receive money or monetary Businesses that engage in “the receipt of businesses that need licenses execute unilaterally or prevent “receiving for transmission,” value in the United States for transmission within money or monetary value by any means in defined? indefinitely a virtual currency “transmitting virtual currency,” “storing, holding, or outside the United States by electronic or exchange for a promise to make the transaction” on behalf of a or maintaining custody or control of virtual other means.” Regulator has never said publicly money or monetary value available at a customer. currency on behalf of others,” “buying and selling whether "monetary value" includes or later time or different location." But, the virtual currency as a customer business,” other cryptocurrencies. regulator has said that "cryptocurrencies “performing exchange services as a customer as currently implemented cannot be business,” “controlling, administering, or issuing considered money or monetary value a virtual currency.” under the Money Services Act."

Who must obtain a license? Hosted Wallet Providers Yes Yes Maybe No Custodial Exchanges Yes Yes Maybe No Miners No Maybe No No Software wallet developers No Maybe No No Multi-sig wallet providers No Maybe Maybe No Full node operators No Maybe No No Lighting node operators No Maybe Maybe No providers (persons who facilitate exchange without taking custody). No Yes No No

Persons holding their own cryptocurrency or holding it for personal/family/ or business No Maybe Maybe No purposes. Small businesses holding less than $5,000 annually for customers No Yes Maybe No

Issuers of new decentralized No Yes Maybe No cryptocurrencies. Investors buying and selling on their No Maybe No No own account.