United States. Every state. Every licensed entity.

Money transmitters are licensed and examined by each state they operate in, and payment stablecoin issuers by their federal or state stablecoin regulator.

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Rules applied: California, Texas, Florida, New York and Washington permissible investments. GENIUS Act stablecoin reserves.
Reports prepared: NMLS MSB Call Report, quarterly. GENIUS Act monthly reserve report.
Checked: Every business day, for each licensed entity, in US dollars.

What each regulator expects.

Every state requires a licensee to hold permissible investments, at market value, at least equal to what it owes its customers, at all times. What counts, and how much of it, differs by state.

California

Licensed money transmitters, including issuers of stored value and payment instruments. Supervised by Department of Financial Protection and Innovation.

Cal. Fin. Code §§2081, 2082, 2083

RequirementWhat the rule saysReference

What must be coveredOutstanding payment instruments and stored value issued or sold in the US, plus money received for transmission in the US and not yet paid out.§2081(a), (d)

WhenAt all times, at market value under GAAP.§2081(a)

Counted without limitCash, deposits at insured institutions and obligations backed by the full faith and credit of the United States.§2082(b); §2083(b)(1)

Issuer limitNo more than 10% of eligible securities from one issuer. US agency obligations have no class limit but are subject to this issuer limit.§2083(a)(1)

Agent receivablesUp to 25% in total and 10% from any one agent. Receivables unremitted for 45 business days count at zero.§2083(a)(2); §2082(d)

Rated instruments and fundsCommercial paper, rated debt and money market funds up to 20% each and 50% combined. Government and AAA funds are exempt from the 20% only.§2083(a)(3)-(6)

Foreign-currency depositsUp to 10%, and only with the commissioner's prior approval.§2082(c)(2); §2083(a)(7)

How Safeheld applies it. The 25% limit is applied to all agent receivables, including those under seven days old (stricter). A foreign-currency deposit counts only when the approval reference is recorded on the holding.

Texas

Licensed money transmitters, including those transmitting stablecoin. Supervised by Texas Department of Banking.

Tex. Fin. Code §§152.355, 152.356

RequirementWhat the rule saysReference

What must be coveredAll outstanding money transmission obligations.§152.355(a)

WhenAt all times, at market value under GAAP.§152.355(a)

Counted without limitCash, deposits, certificates of deposit, US government, agency and municipal obligations, letters of credit, and the part of a surety bond above Texas average daily liability.§152.356(a)(1)-(5)

StablecoinCounts only up to the obligations received in the same stablecoin.§152.356(a)(6)

Delegate receivablesUnder seven days old, up to 50% in total and 10% from any one delegate. Older receivables do not count.§152.356(b)(1)-(2)

Rated instruments and fundsShort-term rated investments, commercial paper, rated debt, tri-party repo, other money market funds and restricted funds up to 20% each and 50% combined.§152.356(b)(3)

Foreign depositsUp to 10%, only with a satisfactory last examination rating and a qualifying foreign bank.§152.356(b)(4)

How Safeheld applies it. Limits are measured against the subtotal of classes with no limit, as the Department's permissible investment report does. Each stablecoin is limited to the obligations received in that coin.

Florida

Licensed money services businesses engaged in money transmission or selling payment instruments. Supervised by Office of Financial Regulation.

Fla. Stat. §560.210

RequirementWhat the rule saysReference

What must be coveredThe face amount of all outstanding money transmissions and payment instruments issued or sold in the US.§560.210(1)

WhenAt all times, at market value under GAAP.§560.210(1)

CountedCash, deposits, bankers' acceptances, debt in the three highest rating grades, US government, agency and state obligations, money market funds and receivables.§560.210(1)(a)-(h)

ReceivablesStop counting when more than 90 days past due or doubtful of collection.§560.210(1)(h)

Virtual currencyHeld in like kind and left out of the requirement.§560.210(2)

LimitsNo statutory concentration limits.§560.210

How Safeheld applies it. Demand borrowing agreements are not counted (stricter). A receivable the firm marks past due is never counted.

New York

Licensed money transmitters and sellers of payment instruments and traveler's checks. Supervised by New York State Department of Financial Services.

N.Y. Banking Law §§640(9), 651

RequirementWhat the rule saysReference

What must be coveredOutstanding payment instruments and traveler's checks.§651

ValuationMarket value at least equal to the obligations, or net carrying value at least equal with market value at least 80% of it.§651(i)-(ii)

CountedCash, deposits at commercial banks, bankers' acceptances, prime commercial paper, and government and corporate debt in the top three rating grades.§640(9)(i)-(vi)

Other depositsDeposits at other institutions and foreign banks count only with the superintendent's approval.§640(9)(vii)

LimitsNo statutory concentration limits.§640(9)

How Safeheld applies it. Money received for transmission and not yet paid out is added to the requirement, in line with NYDFS supervisory practice (stricter than §651). Both valuation tests are run.

Washington

Licensed money transmitters. Supervised by Department of Financial Institutions.

RCW 19.230.200, 19.230.210; WAC 208-690-085

RequirementWhat the rule saysReference

What must be coveredAverage daily transmission liability for the month.RCW 19.230.200(1)(a)

WhenAt all times, at market value under GAAP.RCW 19.230.200(1)

Counted without limitCash, deposits, bankers' acceptances, debt in the three highest grades, government obligations and restricted funds holding these assets.RCW 19.230.210(1)(a)-(d), (f)

Delegate receivablesUp to 30% in total and 10% from any one delegate, not past due or doubtful.RCW 19.230.210(1)(e)

Listed securities and card receivablesListed debt, listed equity and designated card receivables up to 20% each, 50% combined and 10% per person, measured against total permissible investments.RCW 19.230.210(2)-(3); WAC 208-690-085(2)

Pledged assetsPledged or restricted assets do not count.RCW 19.230.210(4)

How Safeheld applies it. The 10% per person limit is applied across the limited classes together (stricter). The like-kind duty for virtual currency is shown to the firm and not tested.

Payment stablecoin reserves

Permitted payment stablecoin issuers. Supervised by Primary federal or state payment stablecoin regulator.

GENIUS Act (Pub. L. 119-27) §4(a)

RequirementWhat the rule saysReference

What must be coveredEvery outstanding payment stablecoin, with identifiable reserves on an at least 1 to 1 basis.§4(a)(1)(A)

Eligible reservesUS coins and currency, Federal Reserve balances, demand deposits or insured shares at insured depository institutions, and government money market funds investing only in eligible reserves.§4(a)(1)(A)(i), (ii), (vi)

Treasuries and repoTreasury bills, notes and bonds of 93 days or less, overnight repo backed by such bills, and overnight reverse repo collateralized by Treasuries.§4(a)(1)(A)(iii)-(v)

Tokenized reservesTokenized forms of eligible cash, deposits, Treasuries and funds count in their own category.§4(a)(1)(A)(viii)

RehypothecationPledged or reused reserves do not count, except for repo margin, standard custody and Treasury bills sold under repo to meet redemptions.§4(a)(2)

Monthly disclosurePublish outstanding stablecoins and reserve composition each month, examined by a registered public accounting firm and certified by the CEO and CFO.§4(a)(1)(C); §4(a)(3)

How Safeheld applies it. Holdings without the terms the Act tests (maturity, overnight term, collateral, settlement route, fund eligibility) are not counted. Treasury bills sold under a redemption repo are not counted, so the cash received is not counted twice.

Returns and reports.

What is filed, when and where, and exactly what Safeheld produces for it.

MSB Call ReportState regulators through NMLS

How often: Quarterly
Due: 45 days after quarter end
Filed through: NMLS upload, then the NMLS completeness check and submission

Upload file

A CSV in the NMLS upload layout, with permissible investment and state transaction items filled from the reconciled figures. NMLS calculates its own totals.

Monthly reserve reportIssuer website and the stablecoin regulator

How often: Monthly
Due: Set by implementing regulations
Filed through: Published by the issuer; CEO and CFO certification to the regulator

Review pack

Reserve composition by category, average tenor and custody location from the month's checked reserves. Both certifications and the accounting firm's examination are recorded before approval.

Destination country schedules in the fourth quarter call report, and the notes NMLS asks for on large "other" items, are completed in NMLS. Every report is reviewed and approved by your team before it is filed.

Every day

What Safeheld runs for the United States.

Reconcile. Bank, FBO, settlement and custody statements matched to your ledger, for each licensed entity, in US dollars.

Investigate. Every holding classed under each state's rules. Aged receivables, missing approvals and amounts over a limit are shown with the section that excludes them.

Forecast. Money expected in and out over the next 24 hours, 7 and 30 days, so a funding need is seen before the cutoff.

Act. Top-ups and transfers proposed, approved by up to three people within limits, then sent to the bank as an ISO 20022 payment file.

Report. Each state's result kept day by day for examination, and the call report and reserve report built from the same figures.

Nexus Payments IncUSD, 30 Sep 2026, 5:00 pm ETMeets

Owed to customers$21,406,118.00

Counted under the rules$21,520,600.00

Excess$114,482.00

Permissible investment tests

CaliforniaCal. Fin. Code §2081Meets

TexasTex. Fin. Code §152.355Meets

New YorkBanking Law §651Meets

FloridaFla. Stat. §560.210Meets

WashingtonRCW 19.230.200Meets

Each state is tested on its own. The same holdings are never counted as extra assets, and no surplus moves between states or entities.

Questions.

Does one set of holdings satisfy every state?

Each state is tested separately against its own requirement, classes and limits. A holding can count in one state and be excluded or capped in another, so Safeheld shows a result for each state you are licensed in, from the same holdings.

How are agent and delegate receivables treated?

By each state's own age and concentration test: 45 business days and 25% in California, under seven days and 50% in Texas, 90 days past due in Florida, and 30% in Washington. Receivables outside the test are excluded and listed with the reason.

Are stablecoins a permissible investment?

In Texas, only up to the obligations received in the same stablecoin. Florida and Washington require virtual currency owed to customers to be held in like kind. Safeheld records which coin each holding is and limits it accordingly.

Which states do you cover?

California, Texas, Florida, New York and Washington have rule sets today, applied to each licensed entity's figures every business day. Entities licensed in other states are reconciled the same way, and further state rules are added as rule sets.

When does the GENIUS Act apply?

On the earlier of 18 January 2027 and 120 days after final implementing regulations are issued. Safeheld tests reserves against section 4(a) now, so the monthly report is ready when the obligation starts.

Does Safeheld file the call report?

No. Safeheld produces the CSV in the NMLS upload layout. Your team uploads it, runs the NMLS completeness check and submits.

Guides.

All guides

United States · 12 minPermissible Investments by State: The Rule in Every Licensing JurisdictionAlmost every state that licenses money transmitters sets a permissible investment test; 35 use the MTMA model, and most others apply older statutes.Read guide United States · 9 minPermissible Investments for Money Transmitters: What the Rules RequirePermissible investments for US money transmitters: the MTMA rule, what counts, concentration limits, NMLS call report reporting and a worked example.Read guide United States · 10 minWhat Is the NMLS MSB Call Report, and How Is It Filed?The MSB Call Report is the quarterly NMLS filing for licensed money services businesses, due 45 days after quarter end, covering finances, transactions and investments.Read guide

More guides.

Authorized delegate receivables

Average daily money transmission liability

Virtual currency like-kind requirements

GENIUS Act eligible reserves

The GENIUS Act monthly reserve report

Customer money in the United States, accounted for every day.

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