On October 5, the Texas Department of Banking entered a consent order with an Illinois-based technology company that processes payments for consumers enrolled in debt relief programs, finding that it engaged in unlicensed money transmission. Under the company’s service, customers authorize transfers from their primary bank accounts to an account that holds the funds and pays them out to creditors under a schedule negotiated by the customer and a debt management service. The department sent the company an inquiry letter on August 8, 2024, and, after reviewing its business, concluded that it was engaged in licensable activity. The company later restructured its business to qualify for an exemption from licensure under Texas Finance Code § 152.004.

The banking commissioner found that the company had conducted money transmission in Texas without a license, was not an authorized delegate of a license holder and, at the time of the department’s initial inquiry, was neither excluded from licensure nor granted an exemption. The commissioner concluded that the company violated Finance Code § 152.101 and its predecessor, § 151.302, which prohibit engaging in money transmission without a license unless an exception applies. Under the order, the company must pay a $77,728.84 administrative penalty within 30 days. The company neither admitted nor denied the findings, and the order does not prevent it from seeking a money transmission license in the future.