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Texas Department of Banking fines payroll processor for alleged unlicensed money transmission

October 9, 2026

On October 6, the Texas Department of Banking entered a consent order with a New York-based payroll processing company to resolve findings that it engaged in unlicensed money transmission in the state. The company’s services included collecting funds from employer clients through the automated clearinghouse system, holding those funds, and disbursing them to employees, tax authorities, garnishing entities and employee benefit providers.

According to the order, the department discovered while reviewing the company’s 2024 license application that it had been providing payroll processing services in Texas since 2014. The department concluded that this activity constituted licensable money transmission under both former Chapter 151 of the Texas Finance Code and its replacement, Chapter 152, which took effect on September 1, 2023, and expressly includes payroll processing services within the definition of money transmission. The company was acquired in April 2025 by a licensed Texas money transmitter, which appointed it as an authorized delegate, and the company withdrew its pending application effective June 17. The order noted that the authorized delegate appointment exempts the company from licensing requirements for activity within the scope of that appointment. Under the terms of the order, the company must pay a $275,000 administrative penalty within 30 days and may not engage in money transmission in Texas unless it is licensed or exempt under Chapter 152. The company neither admitted nor denied the findings.