SESSION OF 2024
SUPPLEMENTAL NOTE ON SENATE BILL NO. 406
As Amended by House Committee on Financial
Institutions and Pensions

Brief*
SB 406, as amended, would repeal and replace the
Kansas Money Transmitter Act (KSA 9-508 et seq.) with the
Kansas Money Transmission Act (Act). The bill would require
the State Bank Commissioner (Commissioner) to provide
oversight of the electronic transmission of money and
establish the powers, duties, and responsibilities of the
Commissioner under the Act. The bill would also establish a
licensing and renewal process for persons licensed under the
Act. Additionally, the bill would establish penalties for
violations of the Act.
The bill would become effective and be in force from and
after January 1, 2025, and its publication in the statute book.
Kansas Money Transmission Act
Definitions (Section 1)
The bill would define terms as used in the Act, including:
● “Money” would mean a medium of exchange that is
authorized or adopted by the United States or a
foreign government. “Money” includes a monetary
unit of account established by an
intergovernmental organization or by agreement
between two or more governments;
____________________
*Supplemental notes are prepared by the Legislative Research
Department and do not express legislative intent. The supplemental
note and fiscal note for this bill may be accessed on the Internet at
http://www.kslegislature.org
● “Money transmission” would mean any of the
following:
○ Selling or issuing payment instruments to a
person located in Kansas;
○ Selling or issuing stored value to a person
located in Kansas;
○ Receiving money for transmission from a
person located in Kansas; or
○ Payroll processing services.
“Money transmission” would not include the provision of
solely online or telecommunications services or network
access.
● “Person” would mean any individual, general
partnership, limited partnership, limited liability
company, corporation, trust, association, joint stock
corporation, or other corporate entity identified or
recognized by the Commissioner; and
● “Tangible net worth” would mean the aggregate
assets of a licensee excluding all intangible assets,
less liabilities, as determined in accordance with
United States generally accepted accounting
principles.
Exemptions (Section 2)
The bill would provide a list of entities the Act would not
apply to:
● An operator of a payment system to the extent that
such operator provides processing, clearing, or
settlement services between persons exempted
under this subsection or licensees in connection
with wire transfers, credit card transactions, debit
card transactions, stored value transactions,

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automated clearing house transfers, or similar
funds transfers;
● A person appointed as an agent of a payee to
collect and process a payment from a payor to the
payee for goods or services other than money
transmission provided to the payor by the payee if:
○ A written agreement exists between the payee
and the agent directing the agent to collect
and process payments from payors on the
payee’s behalf;
○ The payee holds the agent out to the public
as accepting payments for goods and
services on the payee’s behalf; and
○ Payment for the goods and services is treated
as received by the payee upon receipt by the
agent so that the payor’s obligation is
extinguished and there is no risk of loss to the
payor if the agent fails to remit the funds to
the payee;
● A person that acts as an intermediary by
processing payments between an entity that has
directly incurred an outstanding money
transmission obligation to a sender and the
sender’s designated recipient, if the entity:
○ Is properly licensed or exempt from licensing
requirements under this act;
○ Provides a receipt, electronic record, or other
written confirmation to the sender identifying
the entity as the provider of money
transmission in the transaction; and
○ Bears sole responsibility to satisfy the
outstanding money transmission obligation to
the sender, including the obligation to make
the sender whole in connection with any
failure to transmit the funds to the sender’s
designated recipient;
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● The U.S. government and any agency, bureau,
department, office, or instrumentality, corporate or
otherwise, thereof, including any official, employee,
or agent of any such entity;
● Money transmission by the U.S. Postal Service
(USPS) or by an agent of the USPS;
● Any state office or officer, department, board,
commission, bureau, division, authority, agency, or
institution of this state, including any political
subdivision thereof, and any county, city, or other
municipality;
● A federally insured depository financial institution,
bank holding company, office of an international
banking corporation, foreign bank that establishes
a federal branch pursuant to federal law; a
corporation organized pursuant to the federal Bank
Service Company Act, or a corporation organized
to do foreign banking under federal law;
● Electronic funds transfer of governmental benefits
for a federal, state, county, or governmental agency
or instrumentality thereof or on behalf of a state or
governmental subdivision, agency, or
instrumentality thereof;
● A board of trade designated as a contract market
under federal law or a person that in the ordinary
course of business provides clearance and
settlement services for a board of trade to the
extent of the board of trade’s operation as or for
such a board;
● A futures commission merchant registered under
federal commodities law to the extent of the
registrant’s operation as such a futures commission
merchant;

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● A person registered as a securities broker-dealer
under federal or state securities law to the extent of
such registrant’s operation as such a securities
broker-dealer;
● An individual employed by a licensee, authorized
delegate, or any person exempted from the
licensing requirements of the Act when acting
within the scope of employment and under the
supervision of the licensee, authorized delegate, or
exempted person as an employee and not as an
independent contractor;
● A person expressly appointed as a third-party
service provider to or agent of a state office or
officer, department, board, commission, bureau,
division, authority, agency, or institution of this
state, including any political subdivision thereof,
and any county, city, or other municipality, solely to
the extent that:
○ Such service provider or agent is engaging in
money transmission on behalf of and
pursuant to a written agreement with the
exempt entity that sets forth the specific
functions that the service provider or agent is
to perform; and
○ The exempt entity assumes all risk of loss and
all legal responsibility for satisfying the
outstanding money transmission obligations
owed to purchasers and holders of the
outstanding money transmission obligations
upon receipt of the purchaser’s or holder’s
money or monetary value by the service
provider or agent;
● A person engaging in the practice of law,
bookkeeping, accounting, real estate sales, or
brokerage;

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● A person appointed as an agent of a payor for
purposes of providing payroll processing services
for which such agent would otherwise need to be
licensed if:
○ There is a written agreement between the
payor and the agent that directs the agent to
provide payroll processing services on the
payor’s behalf;
○ The payor holds the agent out to employees
and other payees as providing payroll
processing services on the payor’s behalf;
and
○ The payor’s obligation to a payee, including
an employee or any other party entitled to
receive funds via the payroll processing
services provided by the agent, is not
extinguished if such agent fails to remit such
funds to the payee; and
● A person exempt by any rules or regulations
adopted or by an order issued if the Commissioner
finds such exemption to be in the public interest
and that the regulation of such person is not
necessary for the purposes of this Act.
The Commissioner would be permitted to require that
any person claiming to be exempt from licensing provide
information and documentation to the Commissioner
demonstrating that such person qualifies for any claimed
exemption.

Implementation—State Bank Commissioner (Section 3)
To carry out the purposes of the Act, the Commissioner
could:
● Enter into agreements or relationships with other
government officials or federal and state regulatory
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agencies and regulatory associations to improve
efficiencies and reduce regulatory burden by
standardizing methods or procedures and sharing
resources, records, or related information under
this act;
● Use hire, contract, or employ analytical systems,
methods, or software to examine or investigate any
person subject to this act;
● Accept from other state or federal government
agencies or officials, licensing, examination, or
investigation reports made by such state or federal
government agencies or officials; and
● Accept audit reports made by an independent
certified public accountant or other qualified third-
party auditor for an applicant or licensee and
incorporate the audit report in any report of
examination or investigation.
The Commissioner would have the broad administrative
authority to:
● Administer, interpret, and enforce this act;
● Promulgate rules and regulations necessary to
implement this act; and
● Set proportionate and equitable fees and costs
associated with applications, examinations,
investigations, and other actions required to
provide sufficient funds to meet the budget
requirements of administering and enforcing the
Act for each fiscal year and to achieve the
purposes of this act.


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Confidentiality (Section 4)
Except as otherwise provided, the following documents
would be deemed confidential and not subject to disclosure
under the Kansas Open Records Act (KORA):
● All information or reports obtained by the
Commissioner from an applicant, licensee, or
authorized delegate; and
● All information contained in or related to an
examination, investigation, operating report, or
condition report prepared by, or on behalf of, or for
use of the Commissioner or financial statements,
balance sheets, or authorized delegate information.
The provisions of this act providing for confidentiality of
public records would expire on July 1, 2030, unless the
Legislature reviewed and reenacted such provisions in
accordance with KORA prior to that date.
The Commissioner would be permitted to disclose
information not otherwise subject to disclosure to
representatives of state or federal agencies who promise in a
record that such representatives will maintain the
confidentiality of the information or where the Commissioner
finds that the release is reasonably necessary for the
protection and interest of the public in accordance with
KORA.
Public Information
The bill would state the following information contained
in the records of the Office of the State Bank Commissioner
(OSBC) is not confidential and may be made available to the
public:
● The name, business address, telephone number,
and unique identifier of a licensee;

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● The business address of a licensee’s registered
agent for service;
● The name, business address, and telephone
number of all authorized delegates;
● The terms of or a copy of any bond filed by a
licensee, provided that confidential information,
including, but not limited to, prices and fees for
such bond is redacted; or
● Copies of any orders of the OSBC relating to any
violation of or regulations implementing this act.
This section would not be construed to prohibit the
Commissioner from disclosing to the public a list of all
licensees or the aggregated financial or transactional data
concerning those licensees.

Examination (Section 5)
The bill would authorize the Commissioner to conduct
an examination or investigation of a licensee or authorized
delegate or otherwise take independent action authorized by
this act, by any rules and regulations adopted, or by an order
issued under this act as reasonably necessary or appropriate
to administer and enforce the Act, regulations implementing
this act, and other applicable federal law. Under this authority,
the Commissioner could:
● Conduct an examination on-site or off-site as the
Commissioner may reasonably require;
● Conduct an examination in conjunction with an
examination conducted by representatives of other
state agencies, agencies of another state, or the
federal government;


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● Accept the examination report of another state
agency, an agency of another state, or the federal
government, or a report prepared by an
independent accounting firm, which, on being
accepted, would be considered an official report of
the Commissioner; and
● Summon and examine under oath or subpoena a
key individual or employee of a licensee or
authorized delegate and require such individual or
employee to produce records regarding any matter
related to the condition and business of the
licensee or authorized delegate.
Provision of Records
A licensee or authorized delegate would be required to
provide the Commissioner with full and complete access to all
records the Commissioner would reasonably require to
conduct a complete examination. The records would be
provided at the location and in the format specified by the
Commissioner. The Commissioner could utilize multistate
record production standards and examination procedures
when such standards would reasonably achieve these
requirements.
Unless otherwise directed by the Commissioner, the
licensee would be required to pay all costs reasonably
incurred in connection with an examination.

Multistate Supervision (Section 6)
To administer and enforce the provisions of the Act and
minimize the regulatory burden, the Commissioner would be
authorized to participate in multistate supervisory processes
established between states and coordinated through the
Conference of State Bank Supervisors (CSBS), money
transmitter regulators associations, and affiliates and
successors thereof for all licensees that hold licenses in
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Kansas or other states. As a participant in such established
multistate supervisory processes, the Commissioner could:
● Cooperate, coordinate, and share information with
other state and federal regulators in accordance
with examination provisions of the Act (Section 5);
● Enter into written cooperation, coordination, or
information-sharing contracts or agreements with
organizations, the membership of which is made
up of state or federal governmental agencies; and
● Cooperate, coordinate, and share information with
organizations, the membership of which is made
up of state or federal governmental agencies, if the
organizations agree in writing to maintain the
confidentiality and security of the shared
information in accordance with disclosure
provisions of the Act (Section 4).
The Commissioner could not waive, and nothing in the
Act would constitute a waiver of, the Commissioner’s
authority to conduct an examination or investigation or
otherwise take independent action authorized by the Act,
rules and regulations adopted, or an order issued under the
Act to enforce compliance with applicable state or federal law.
A joint examination, investigation, or acceptance of an
examination or investigative report would not be construed to
waive an examination assessment provided for in this act.

Relationship to Federal Law (Section 7)