TITLE: Conference of State Bank Supervisors Issues Money Transmission Modernization Act Guidance on Stablecoin and Lease Accounting
BODY:
On April 23, 2026, the Conference of State Bank Supervisors (CSBS) issued new implementation guidance under the Money Transmission Modernization Act (MTMA) addressing the treatment of stablecoins and right-of-use leases in tangible net worth calculations.
The guidance clarifies how stablecoins and right-of-use leases apply under Section 2.01(bb) of the MTMA, which governs the calculation of tangible net worth. Tangible net worth (capital) is a core component of the MTMA framework, which establishes standards for surety bonds, permissible investments with 1-for-1 reserves, and other regulatory and supervisory requirements. The guidance was developed to address questions arising from the evolution of money transmission technologies and products, ensuring consistent application of MTMA requirements across state regulators and covered institutions. The CSBS Non-Depository Supervisory Committee, an advisory group of state supervisors, oversaw the guidance development in consultation with the Money Transmitter Regulators Association.
To date, 31 states have adopted the MTMA in full or in part, establishing a nationwide baseline for large, multistate money transmitters. Legislation is currently pending in Alaska, Louisiana, Maryland, Michigan, and Oklahoma. Firms licensed in any adopting state must comply with MTMA standards at the enterprise level, extending those requirements across their broader operations. The CSBS previously issued guidance in 2025 clarifying the treatment of virtual currency under the MTMA. As the MTMA's reach continues to expand and new implementation questions emerge, the CSBS will continue to engage states, build consensus, and provide clear direction to regulators and industry stakeholders.