ETA Responds to Conference of State Bank Supervisors’ (CSBS) Request for Information on Model State Payments Legislation

Dear Emerging Payments Task Force:

The Electronic Transactions Association (“ETA”) appreciates the opportunity to provide
comments on behalf of the payments and FinTech industry. ETA encourages states to work
together to harmonize requirements for money transmitters and urges all system participants
including regulators, policymakers, and money transmitters to move towards a regulatory
framework that can promote innovation rather than hamper it. The regulatory framework must
allow for innovation and changing expectations of consumers brought on by technology while
protecting consumers, providing stability of transactions, and guarding against fraud. Furthermore,
ETA encourages CSBS to coordinate with all parts of the policymaking system including
legislative bodies and regulatory agencies at the state and federal level to ensure more expedient
state adoption of a harmonized money transmitter regulatory framework.

ETA is the leading trade association for the payments industry, representing over 500 companies
that offer electronic transaction processing products and services. ETA’s members include
financial institutions, mobile payment service providers, mobile wallet providers, and non-bank
online lenders that make commercial loans, primarily to small businesses, either directly or in
partnership with other lenders. ETA member companies are creating innovative offerings in
financial services, revolutionizing the way commerce is conducted with safe, convenient, and
rewarding payment solutions and lending alternatives.

Read ETA’s full comments here.