Commerce rails that clear the second customers tap

Michigan (DIFS — Money Transmission Services Act)

**Capital + bonding:** Act 250 §13 requires GAAP statements proving at least $100K net worth plus $25K per Michigan location or authorized delegate (capped at $1M) and a surety bond between $500K and $1.5M; queue CPA-reviewed financials and a surety facility that scales with delegate onboarding (MCL 487.1013). **Permissible investments & trust accounting:** Sections 31–32 force us to hold permissible investments (cash, FDIC-insured CDs, U.S. obligations, tightly limited delegate receivables, etc.) at least equal to outstanding instruments and transmitted funds, with receivables capped at 20% of the total portfolio and 10% per delegate; build a monthly reconciliation that proves compliance before each call report (Act 250 of 2006, §§31–32). **Authorized delegate controls:** Delegate agreements must be written, require Act compliance, and enforce remittance SLAs; prep onboarding kits (KYC evidence, remittance timing, audit rights) plus a playbook for issuing cease notices if DIFS orders a suspension (MCL 487.1033).

New York (DFS — Banking Law Article 13-B)

**Licensing trigger:** Banking Law §641 bars money transmission without a DFS license; ensure the MU1 narrative clarifies agent-of-payee structures and that every NY-facing workflow sits inside the license perimeter (NY Banking Law §641). **Bond sizing:** DFS sets the bond floor at $500K (and $750K for traveler’s checks) but often escalates based on locations, agents, and financial strength, so we should model $500K / $1M / $2M scenarios and pre-negotiate capacity (NY Banking Law §643). **Permissible investments:** Section 651 requires permissible investments equal to outstanding payment instruments/traveler’s checks, with GAAP net-carrying value allowed only if market value stays ≥80% of carrying; lock the reserve mix (cash, treasuries, MMFs) to satisfy both DFS and DIFS coverage tests (NY Banking Law §651).

California (DFPI — Money Transmission Act)

**Licensing scope:** Financial Code §2030 requires a DFPI license before we advertise or provide money transmission; confirm every CA workflow (Blox Marketplace PWAs, BXT payouts, reserve sweeps) is described in the application narrative (Cal. Fin. Code §2030). **Security deposit / bond:** Section 2037 mandates a cash/securities deposit with the State Treasurer or a surety bond sized to obligations—minimum $500K or 50% of outstanding stored value/payment instruments (capped at $2M) plus $250K–$7M for transmission balances; engage a surety early and pre-clear collateral if we prefer to post securities (Cal. Fin. Code §2037). **Treasurer logistics:** Opening the pledged-securities account can take 4–6 weeks; start the Security Deposit Agreement, authorized signers list, Fedwire instructions, and custodian acknowledgments now so the bond/deposit is ready when DFPI issues conditional approval.