United States – Maine

Other Developments

Maine's core non-bank payments licensing regime continues to run through the Money Transmission Modernization Act (MMTMA), 32 M.R.S. Chapter 79-A, effective August 9, 2024, which replaced the prior Money Transmitters Act and is administered by the Bureau of Consumer Credit Protection via NMLS. An administrative modernisation completed this cycle: the Bureau migrated its surety-bond process to Electronic Surety Bonds via NMLS beginning September 1, 2025, with all existing licensees required to convert by January 31, 2026 — a deadline that has now passed. The statute continues to exempt supervised financial organizations, i.e., banks, and payment-system operators processing between exempted persons or licensees from money-transmission licensure, preserving Maine's dual-track regime in which non-bank payment institutions are licensed by the Bureau of Consumer Credit Protection while bank-chartered PSPs are supervised separately by the Bureau of Financial Institutions.

On the conduct side, Maine sellers and merchants remain prohibited from imposing credit or debit card surcharges under 9-A M.R.S. §8-509, subject only to a narrow government-entity carve-out for taxes, fines, and fees — one of just four US jurisdictions, alongside Connecticut, Massachusetts, and Puerto Rico, maintaining a full surcharge ban as of 2026. That standing prohibition sits apart from a separate national development: the revised Visa/Mastercard interchange-fee antitrust settlement received preliminary federal court approval in June 2026, though final approval is not expected until late 2026 or early 2027, and the settlement carries no Maine-specific provisions.

Maine's community-banking and trust sector continued to consolidate. Gorham Savings Bank and Maine Community Bancorp completed their merger effective January 1, 2026, forming an enlarged Maine Community Bank that is now the largest mutual savings bank operating exclusively in Maine, with more than 370 employees. Separately, Corient Partners, LLC filed on April 3, 2026 to establish Corient Maine Trust Company, LP, and on June 3, 2026 applied to acquire substantially all trust assets of H.M. Payson & Co., with regulatory approval still pending.

On instant payments, a cohort of Maine state-chartered banks — Auburn Savings, Bangor Savings, First National Bank Damariscotta, Franklin Savings, and Maine Community Bank — are live on the Federal Reserve's FedNow Service. The Federal Reserve Board has also proposed, in an April 2026 public-comment release, to allow US banks and credit unions to use intermediaries within FedNow transfers, a step that would extend the domestic correspondent-banking model to the international leg of cross-border payments. Smaller Maine institutions already depend on correspondent structures for rail access: EasCorp, a corporate credit union correspondent, settles instant payments via a pooled joint account at the Federal Reserve Bank of New York on behalf of member credit unions, providing FedNow, RTP, ACH, and wire access without direct Fed master-account connectivity.

On enforcement, the Bureau of Consumer Credit Protection's consent-order practice against Bitcoin Depot sits alongside the Maine Attorney General's standing authority under the Maine Unfair Trade Practices Act to investigate and sue over unfair or deceptive payment practices, with consumers retaining a private right of action including recovery of attorney's fees. Separately, Maine's check cashers and cash-dispensing machine operators remain subject to registration and fee caps under Title 32 Chapter 80 — 5% of face value, or 6% without identification, with lower caps for government-benefit payment instruments — administered distinctly from full money-transmitter licensure. Maine residents also remain protected by the Notice of Risk to Personal Data Act, which requires 30-day breach notification to affected residents, nationwide credit-reporting-agency notification where more than 1,000 persons are affected, and notification to state regulators.

Cross-Monitor Connections

The Bitcoin Depot enforcement action, and the underlying crypto-kiosk fraud it addresses, involves scam proceeds that moved through unhosted wallets — an illicit-finance and fraud-proceeds dimension that sits beyond this monitor's consumer-protection scope and has been flagged to the Financial Illicit-finance Monitor for its own analysis of the wallet and proceeds pathway. On the AML/CFT side, Maine's Bureau of Financial Institutions conducts BSA/AML examinations of state-chartered institutions alongside safety-and-soundness and IT reviews, and MMTMA licensees separately cross-reference federal Bank Secrecy Act obligations; the Sentinel.gi payments-context feed that ordinarily supplies this monitor's illicit-finance framing was not accessible this cycle, so this remains standing statutory scaffolding rather than original analysis.

Outlook

The Visa/Mastercard interchange-fee settlement's final court approval is expected in the first quarter of 2027, though the timeline carries a half-year uncertainty band and the settlement will not alter Maine's own surcharge ban. Corient's application to acquire H.M. Payson & Co.'s trust assets remains before Maine regulators, and the Federal Reserve's proposal to permit intermediaries within FedNow transfers remains open for public comment with no confirmed final-rule date. Maine's consumer-protection stack around digital-money and kiosk activity is likely to remain the state's most active payments-regulatory vector, even as its core MMTMA licensing framework and card-surcharge rule stay stable.

Maine sellers and merchants are prohibited from imposing credit or debit card surcharges under 9-A M.R.S. §8-509, subject to a narrow government-entity carve-out. Kiosk operator Bitcoin Depot is now required, under a 2026 consent agreement, to comply with an unhosted-wallet-control provision requiring consumers to own and control their virtual wallets, and a Gramm-Leach-Bliley-Act-consistent information-security program mandated for kiosk operators under a 2025 amendment to Title 32 Chapter 80.

Maine has no dedicated stablecoin-issuer statute; the primary digital-money instrument is LD 1339 (chaptered 2025), which caps kiosk fees at the greater of $5 or 3% of transaction value, sets a $1,000 daily transaction limit, and requires at least three years of recordkeeping. Bitcoin Depot's consent agreement recovered $1.9 million for defrauded Maine consumers and required it to operate as a licensed money transmitter.

Maine has no DORA-equivalent operational-resilience or critical-third-party statute; the closest analogue is the 2025 requirement that kiosk and check-cashing operators maintain a Gramm-Leach-Bliley-Act-consistent information-security program.

Maine maintains an outright ban on credit and debit card surcharging, one of only four US jurisdictions with a full ban as of 2026, with no bespoke interchange regulation. The revised Visa/Mastercard interchange-fee antitrust settlement received preliminary federal court approval in June 2026, with final approval not expected until late 2026 or early 2027 and no Maine-specific provisions.

The Maine-Canada border, 611 miles long with 24 land ports of entry into Quebec and New Brunswick, is served by standard state money-transmitter licensing applied to remittance operators such as Western Union and MoneyGram; no Maine-specific cross-border instrument exists.

Gorham Savings Bank and Maine Community Bancorp completed their merger effective January 1, 2026, forming an enlarged Maine Community Bank, the largest mutual savings bank operating exclusively in Maine. Corient Partners, LLC filed on April 3, 2026 to establish Corient Maine Trust Company, LP, and applied on June 3, 2026 to acquire substantially all trust assets of H.M. Payson & Co.

The Bureau of Consumer Credit Protection and the Office of the Attorney General resolved the Bitcoin Depot matter via a consent agreement recovering $1.9 million in scam proceeds for Maine consumers. The Maine Attorney General is separately empowered by the Maine Unfair Trade Practices Act to investigate and sue over unfair or deceptive payment practices, with a private right of action for consumers.

Maine check cashers and cash-dispensing machine operators are subject to registration and fee caps under Title 32 Chapter 80, capped at 5% of face value or 6% without identification, with lower caps for government-benefit instruments, registered separately from full money-transmitter licensees.

A cohort of Maine state-chartered banks are live on the Federal Reserve's FedNow Service, and the 2025 virtual-currency-kiosk law represents a fast-turnaround regulatory response to the crypto-ATM product category.

The kiosk law entitles customers to a full refund, including fees, for fraud-induced transactions made within 90 days of a customer's first kiosk use, if reported to law enforcement within one year, introduced after the FBI reported $31 million in 2024 Maine crypto-fraud losses. Maine residents are also protected by the Notice of Risk to Personal Data Act, requiring 30-day breach notification, nationwide credit-reporting-agency notification above 1,000 affected persons, and state-regulator notification.

Maine's Bureau of Financial Institutions conducts BSA/AML examinations of state-chartered institutions alongside safety-and-soundness and IT reviews, and MMTMA licensees separately cross-reference federal Bank Secrecy Act obligations; the Sentinel.gi payments-context feed was not accessible this cycle, so this remains standing statutory scaffolding rather than original illicit-finance analysis.

EasCorp, a corporate credit union correspondent, settles instant payments via a pooled joint account at the Federal Reserve Bank of New York on behalf of member credit unions, providing FedNow, RTP, ACH, and wire access without direct Fed master-account connectivity. The Federal Reserve Board has proposed, in an April 2026 public-comment release, to allow banks and credit unions to use intermediaries within FedNow transfers, extending the domestic correspondent-banking model to the international leg of cross-border payments.

The Gorham Savings Bank merger with Maine Community Bancorp, completed effective January 1, 2026, and Corient Partners' filing to establish Corient Maine Trust Company, LP followed by its application to acquire substantially all trust assets of H.M. Payson & Co., together dominate trailing-twelve-month Maine commercial activity; deal values for both transactions are not publicly disclosed.

Outlook

The Visa/Mastercard interchange-fee settlement's final court approval is expected in the first quarter of 2027, subject to a half-year uncertainty band, without altering Maine's own surcharge ban. Corient's application to acquire H.M. Payson & Co.'s trust assets remains pending before Maine regulators, and the Federal Reserve's FedNow-intermediary proposal remains open for public comment with no confirmed final-rule date. Maine's regulatory trajectory is tightening on consumer-protection and digital-money regulation while its core licensing framework and card-surcharge rule remain stable.