title: United States – Michigan Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-michigan/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Michigan US-MI schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 61 sourced findings · 8 sources in the cumulative register 14 Modules baseline.modules[] 61 Findings modules[].findings[] 3 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) No modules moved this cycle. ** United States federal law** that applies in United States – Michigan is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Michigan’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Michigan's money-transmission licensing framework is mid-transition. House Bill 5544, the Money Transmission Modernization Act, repeals and replaces the Money Transmission Services Act (MCL 487.1001-487.1047) with a Conference of State Bank Supervisors model licensing regime, including a like-kind virtual-currency reserve requirement for licensees transmitting virtual currency. The bill passed the Michigan House 97-10 on June 25, 2026, has been pending in Senate committee since July 1, 2026, and carries an engrossed repeal-effective date of July 1, 2027. This creates near-term regulatory uncertainty for crypto-adjacent money transmitters operating in or into Michigan, since the terms of the replacement regime are not yet settled. #### Other Developments **Coinbase Financial Markets, Inc.** stipulated with the Michigan Gaming Control Board to stop offering new sports-related event contracts to Michigan customers and to close out open positions by 12:00 a.m. Eastern time on October 10, 2026. The MGCB agreed not to pursue enforcement pending a Sixth Circuit appeal. This follows a similar agreement by Robinhood reached September 9, 2026, leaving Kalshi as the remaining operator still contesting the state's position in this product segment, subject to an injunction. **A Commodity Futures Trading Commission interim final rule**, effective October 19, 2026, excludes wagers placed with state- or tribal-licensed sportsbooks and casinos from the Commodity Exchange Act's swap definition, a federal development material to the pending Sixth Circuit litigation over whether sports-related event contracts fall under federal derivatives jurisdiction or state gambling-licensing jurisdiction. #### Cross-Monitor Connections The Money Transmission Modernization Act (HB 5544) is a parallel subject of the financial-integrity monitor's AML/CTF tracking, given that MSB licensees are already BSA-obliged entities at the federal layer; the state licensing standardization this bill would effect interacts with that federal compliance layer without altering it directly. The crypto monitor is tracking the same bill under its crypto-licensing module, given the virtual-currency like-kind reserve provision embedded in the CSBS model law. The Coinbase/MGCB stipulation and the CFTC rule are also relevant to advennt's gambling-regulatory tracking of the same enforcement actions, viewed there through a gambling-licensing rather than payments lens. #### Outlook The principal variable for Michigan's payments and licensing landscape is whether the Senate Finance, Insurance, and Consumer Protection Committee advances HB 5544 before the legislative session recesses, and whether the virtual-currency like-kind reserve provision survives committee review unchanged. On the litigation side, the Sixth Circuit's resolution of the federal-preemption question, now weighing against the CFTC's narrowing interim final rule, will determine whether sports-related event contract products can operate in Michigan outside the state gambling license at all. _2 earlier updates not shown here._ ###### Standing brief · as of 6 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal FinCEN's April 2026 notice of proposed rulemaking would overhaul Bank Secrecy Act AML/CFT program-effectiveness standards for institutions regulated under 31 CFR Part 1021, extending to Michigan's casino payment operations. The proposal would require board-level approval of AML/CFT programs, a documented risk-assessment methodology, and a US-located responsible officer for Part 1021 institutions, including casinos. The public comment period closed on 9 June 2026, and the final rule remains pending. If finalized as proposed, this governance-driven, risk-assessment-anchored standard would raise compliance costs for Michigan's Detroit commercial and tribal casino payment operations. This lead signal carries a preliminary confidence rating of probable, reflecting third-tier legal-commentary sourcing pending confirmation of the final rule text. #### Other Developments Michigan continues to license virtual-currency administrators and exchangers as ordinary money transmitters under the Michigan Money Transmission Services Act (MCL 487.1001 et seq.), with no dedicated virtual-currency licence in place. The state's licensing regime sets a minimum net worth requirement of $100,000, scaling toward $1,000,000 as licensees add locations or delegates. This licensing baseline sits alongside a live legislative track: Michigan House Bill 5544 and Senate Bill 835 would adopt the CSBS Money Transmission Modernization Act template, part of a 31-state modernization wave. HB 5544 extends the template to payroll processors, while SB 835 carves out a payroll-processor exemption for agents of the payor. Adoption would align Michigan with the broader MTMA wave while leaving virtual-currency activity licensed as ordinary money transmission rather than under a dedicated crypto framework. These licensing and conduct provisions apply to non-bank money-service businesses and payment or e-money institutions rather than to depository banks. The standing Payments Regulation and Conduct tracker records this MTMA modernization push as a watch item, and the jurisdiction risk tracker for Michigan currently reads stable, with primary-domain coverage spanning licensing, conduct, and correspondent-banking access. Separately, two federal developments overlay Michigan-licensed money-service businesses. FinCEN's Corporate Transparency Act beneficial-ownership rule has narrowed reporting scope to foreign entities only, exempting domestic entities and their beneficial owners; this reduces the beneficial-ownership transparency backdrop against which Michigan-registered payment and gaming-adjacent entities operate. The CTA beneficial-ownership final rule is pending review at the Office of Management and Budget's Office of Information and Regulatory Affairs since 5 June 2026, a disposition that will determine whether the domestic-entity exemption becomes permanent. These federal obligations apply across both bank and non-bank correspondent and settlement relationships touching Michigan-licensed entities. Two coverage gaps remain flagged for this jurisdiction: the full text of a Michigan Gaming Control Board technical bulletin on geolocation compliance has not been retrieved, and the CSBS legislative tracker underlying the MTMA bills is itself classified as a volatile, legislative-cycle source subject to revision. #### Cross-Monitor Connections The FinCEN AML/CFT program-effectiveness NPRM and the CTA beneficial-ownership scope narrowing are both flagged as illicit-finance relevant; original analysis of their financial-crime implications belongs to the Financial Integrity Monitor rather than this brief. This flag reflects high-confidence assessment that both federal developments carry illicit-finance salience beyond the payments-regulation lens applied here. No Sentinel-fed AML/CFT finding surfaced for US-MI this cycle, and coverage gaps were also noted for Michigan-specific merchant-acquiring enforcement and fintech M&A or funding activity. Michigan-specific merchant-acquiring enforcement and any Michigan fintech M&A or funding event remain under-indexed relative to the headline federal coverage captured this cycle. #### Outlook Three forward-dated milestones anchor the Michigan horizon. The MTMA modernization bills, HB 5544 and SB 835, carry an expected disposition around 2026-Q4, on a year-wide uncertainty band reflecting their proposed stage. FinCEN's Part 1021 AML/CFT final rule is expected around 2027-Q1, on a half-year uncertainty band, following the close of its consultation stage. The CTA beneficial-ownership final rule remains pending OMB review, with disposition expected around 2026-Q4 on a half-year uncertainty band; that disposition will determine whether the domestic-entity exemption becomes permanent. Michigan's pending MTMA adoption would align the state with the 31-state CSBS modernization wave, assessed at high confidence, though virtual-currency activity would remain licensed as ordinary money transmission rather than under a dedicated crypto framework. The narrowed CTA beneficial-ownership scope, assessed at high confidence, is judged to reduce the beneficial-ownership transparency backdrop against which Michigan-registered payment and gaming-adjacent entities operate, while the FinCEN Part 1021 governance standard, assessed as an elevated-impact development, is judged likely to raise compliance costs for Michigan's Detroit commercial and tribal casino payment operations if finalized as proposed. Taken together, these three milestones indicate a Michigan payments environment that remains under active reshaping at both the state licensing layer and the federal correspondent-banking overlay, warranting continued monitoring through year-end 2026 and into early 2027. trust tier: ai_unverified ###### Latest update · 25 August 2026 #### Regulatory Status Michigan's money-transmission licensing regime is in transition. The current statute, 2006 PA 250, remains in force, but House Bill 5544 -- which passed the Michigan House 97-10 on June 25, 2026, and was referred to the Senate Finance, Insurance, and Consumer Protection Committee on July 1, 2026 -- together with its Senate companion, SB 0835 (referred to the same committee on March 17, 2026), would replace it with the Money Transmission Modernization Act. As drafted and reported from committee, the MTMA excludes exchange, transfer, or custody of virtual currency not involving a transfer of legal tender from the money-transmission licensing definition, and would lower the surety-bond floor to $100,000 if enacted, effective January 1, 2027, with the current statute repealed July 1, 2027. #### Outlook Michigan's regulatory direction is assessed as liberalising for non-bank payment institutions and e-money-equivalent licensees specifically, contingent on Senate passage and gubernatorial signature. The regulatory horizon places the prospective effective date at January 1, 2027 with a half-year uncertainty band, reflecting that the bill remains at committee stage. No change to bank-supervised payment activity is indicated, since the reform operates within the money-transmission licensing track rather than prudential bank regulation. _1 earlier update not shown here._ ###### Standing brief · as of 6 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Michigan's payments regulatory posture is assessed as stable overall, anchored by ordinary money-transmission licensing of virtual-currency administrators and exchangers under the Michigan Money Transmission Services Act, a pending MTMA modernization track (HB 5544/SB 835), and a federal correspondent-banking and AML/CTA overlay that is evolving independently of state action. The jurisdiction has no dedicated virtual-currency licensing regime. Primary domains of activity this cycle are licensing and market access, conduct and safeguarding, and correspondent banking, settlement and access. #### Outlook Michigan's regulatory direction is assessed as stable, with the MTMA bills' enactment disposition expected around 2026-Q4 and the federal CTA and FinCEN Part 1021 overlays resolving on their own separate timelines through 2027-Q1. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-07-05 Michigan's money-transmission licensing framework (2006 PA 250, MCL 487.1001-487.1047) is being replaced by the Money Transmission Modernization Act (HB 5544 package, CSBS model law), pending Senate committee since July 1, 2026, with engrossed repeal date July 1, 2027. Standing sub-brief · as of 6 August 2026 144 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Michigan continues to license virtual-currency administrators and exchangers as ordinary money transmitters under the Michigan Money Transmission Services Act (MCL 487.1001 et seq.), with no dedicated virtual-currency licence in place; the Department of Insurance and Financial Services treats e-wallet and stored-value holding, and virtual-currency administration or exchange, as licensable money transmission. The state's licensing regime sets a minimum net worth requirement of $100,000, scaling toward $1,000,000 as licensees add locations or delegates. These requirements apply to non-bank money-service businesses and payment or e-money institutions, distinct from depository banks, which are licensed and supervised under separate bank-charter frameworks. #### Outlook This baseline is assessed as stable for now, but Michigan's pending MTMA modernization bills (HB 5544 and SB 835) would revise net-worth, surety-bond, and permissible-investment standards for money transmitters, including virtual-currency administrators and exchangers, without introducing a dedicated virtual-currency licensing regime. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access Michigan's money-transmission licensing framework under the Money Transmission Services Act (MCL 487.1001-487.1047) is mid-transition. House Bill 5544, the Money Transmission Modernization Act, would repeal this current statute effective July 1, 2027 and replace it with the Conference of State Bank Supervisors model licensing regime. The bill passed the Michigan House by a vote of 97-10 on June 25, 2026 and has been pending in the Senate Finance, Insurance, and Consumer Protection Committee since July 1, 2026. The replacement regime would bring Michigan into alignment with the CSBS model law framework already adopted in some form by a large number of other states, a structural shift toward multistate-examination acceptance intended to reduce duplicative state-by-state licensing burden for money transmitters operating across multiple jurisdictions. A distinguishing feature of the pending replacement is a like-kind virtual-currency reserve requirement: a licensee transmitting virtual currency would be required to hold like-kind virtual currency of the same volume obligated to consumers. This provision extends the licensing framework's reach into crypto-asset operators specifically, a market-access condition that does not exist under the current statute. For payment companies and crypto-asset operators either currently licensed in Michigan or considering market entry, the open question is the ultimate shape and timing of this replacement regime, since the bill remains in committee with no confirmed Senate timeline. #### Outlook Whether the Senate Finance, Insurance, and Consumer Protection Committee acts on HB 5544 before the legislative session recesses is the key near-term variable. If passed in its current form, the new licensing regime, including the virtual-currency reserve requirement, would take effect July 1, 2027, materially changing market-access conditions for payment companies and crypto-asset operators licensed to transmit money in Michigan. **1 earlier distinct update(s)** Periodic update · new data 2026-08-25 #### Licensing, Authorisation & Market Access Michigan's House Bill 5544, which adopts the Money Transmission Modernization Act (MTMA) as successor to 2006 PA 250, passed the Michigan House 97-10 on June 25, 2026, and was referred to the Senate Finance, Insurance, and Consumer Protection Committee on July 1, 2026. Its Senate companion, SB 0835, had been referred to the same committee on March 17, 2026, giving the reform two live legislative vehicles moving in parallel. As reported from committee, the MTMA's money-transmission definition expressly excludes the exchange, transfer, or custody of virtual currency that does not involve a transfer of legal tender, which functions as a scope carve-out for non-fiat crypto activity rather than a new licensing track for it. If enacted, the Act would take effect January 1, 2027, would repeal the current statute effective July 1, 2027, and would cut the surety-bond floor to $100,000, a materially lower fixed cost of market entry than the current regime imposes. The reform bears specifically on the non-bank layer of Michigan's payments market. Money-transmission licensing in Michigan, as elsewhere in the United States, applies to non-bank payment institutions and e-money-equivalent licensees; depository institutions conducting equivalent activity are supervised separately under prudential bank regulation rather than through the money-transmission licensing regime the MTMA would replace. A lower surety-bond floor therefore reduces a fixed compliance cost specifically for smaller non-bank money-transmission applicants seeking to enter or remain in the Michigan market, while the virtual-currency carve-out narrows the population of crypto-custody and crypto-exchange activity that requires a Michigan money-transmission license at all. #### Outlook The procedural marker to watch is movement in the Senate Finance, Insurance, and Consumer Protection Committee, where both HB 5544 and SB 0835 currently sit. Michigan's regulatory horizon places the Act's effective date at January 1, 2027, carrying a half-year uncertainty band that reflects the bill's current committee-stage status rather than enactment. Passage and signature would move Michigan from the current 2006 PA 250 regime to the multistate MTMA model with a lower bond floor and an explicit virtual-currency carve-out; absent that, the current regime continues to apply unchanged. **Sources and findings (7)** 1. T1 [https://www.legislature.mi.gov/documents/mcl/pdf/mcl-Act-250-of-2006.pdf](https://www.legislature.mi.gov/documents/mcl/pdf/mcl-Act-250-of-2006.pdf) 2. T1 [https://www.michigan.gov/difs/industry/licensing-cf/money-transmit](https://www.michigan.gov/difs/industry/licensing-cf/money-transmit) 3. T1 [https://origin-sl.michigan.gov/difs/0,5269,7-303-13648_60667_76248---,00.html](https://origin-sl.michigan.gov/difs/0,5269,7-303-13648_60667_76248---,00.html) 4. T1 [https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission](https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission) 5. T1 [https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm](https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm) 6. T2 [https://legiscan.com/MI/text/SB0835/id/3396679](https://legiscan.com/MI/text/SB0835/id/3396679) 7. T3 [https://fraxtional.co/feeds/blog/mi-money-transmitter-license](https://fraxtional.co/feeds/blog/mi-money-transmitter-license) ### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-07-05 Safeguarding rests on a permissible-investments requirement backed by surety bond, with DIFS examination/confidentiality powers under Section 26. The pending MTMA bill would introduce a statutory trust mechanism over permissible investments for customer benefit in insolvency, a stronger safeguarding model than current law but not yet in force. Standing sub-brief · as of 6 August 2026 143 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Financial Promotions Michigan House Bill 5544 would adopt the full CSBS Money Transmission Modernization Act template, including payroll processors, as part of a 31-state MTMA adoption wave. Companion Senate Bill 835 would adopt the same full MTMA template but with a payroll-processor exemption for agents of the payor. Both bills apply to non-bank money-service businesses and payment or e-money institutions rather than to depository banks, and neither introduces a dedicated virtual-currency licensing regime; Michigan would continue to license virtual-currency administrators and exchangers as ordinary money transmitters. #### Outlook HB 5544 and SB 835 are assessed as a High-confidence, elevated-impact development for Michigan's money-transmission conduct framework, with an expected enactment disposition around 2026-Q4 on a year-wide uncertainty band; Michigan's pending MTMA adoption would align the state with the broader 31-state CSBS modernization wave while leaving virtual-currency activity licensed as ordinary money transmission. Periodic update · new data 2026-08-11 #### Conduct, Safeguarding & Financial Promotions Michigan's non-bank payment-institution and e-money-issuer sector faces a modernizing conduct and licensing framework this cycle, driven by two companion bills moving through the state legislature. House Bill 5544 proposes full adoption of the Conference of State Bank Supervisors' Money Transmission Modernization Act template, including its treatment of payroll processors as licensable money transmitters, while Senate Bill 835 proposes the same core template with a payroll-processor exemption, treating such processors as agents of the payor rather than as entities requiring separate licensure. Both bills form part of a broader 31-state modernization wave coordinated through the CSBS template, under which participating states adopt harmonized net-worth, surety-bond, and permissible-investment standards for licensed money transmitters. This is a High-confidence, directly-sourced legislative development, evidenced by CSBS's own tracked legislative update, though neither bill has been enacted this cycle. The conduct-and-safeguarding significance of this modernization effort lies less in any single provision than in the broader alignment it represents: Michigan's money-transmission licensing regime would move toward the more contemporary, harmonized standard that a majority of US states have now adopted or are adopting. For non-bank payment institutions and e-money issuers licensed in Michigan, this creates a forward-looking conduct expectation: capital, safeguarding, and permissible-investment standards are likely to converge toward the CSBS template's baseline, even though the precise terms remain unsettled pending enactment. The payroll-processor question captured in the divergence between the House and Senate bills is itself a conduct-classification issue with direct financial-promotions and product-scope implications: whether a payroll processor is treated as an agent of the payor (exempt, per the Senate version) or as a licensable money transmitter in its own right (per the House version) determines whether that class of non-bank payment intermediary carries the full weight of Michigan's money-transmission conduct obligations, including bonding, net-worth, and associated safeguarding standards for customer funds. This is a bank-versus-non-bank-adjacent distinction in substance, since it determines which category of non-bank intermediary is drawn into the state's licensed-conduct perimeter and which remains outside it. #### Outlook The decisive near-term event for this domain is the legislative fate of House Bill 5544 and Senate Bill 835, expected to remain live through the fourth quarter of 2026; enactment of either bill, and in particular resolution of the payroll-processor exemption question between the House and Senate versions, would settle the conduct-classification question for that category of non-bank payment intermediary and would be the appropriate trigger to revisit this domain's signal level. Passage would also be the clearest evidence yet that Michigan intends to align fully with the 31-state CSBS modernization wave rather than retain its current, less harmonized standard. **Sources and findings (4)** 1. T1 [https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission](https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission) 2. T1 [https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission](https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission) 3. T1 [https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm](https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm) 4. T1 [https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification](https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification) ### W2 Stablecoins & Digital Money Probable confirmed 2026-07-05 Michigan has no dedicated state-level stablecoin issuance statute; the operative framework is the federal GENIUS Act (signed 2025-07-18), being implemented through OCC, FDIC and joint FinCEN/OFAC rulemakings during 2026, applicable nationwide including to Michigan state-chartered banks. Horizon · 2026-06-09 (±quarter) FinCEN/OFAC comment period closes on PPSI AML/CFT proposed rule_consultation · TT1_ Horizon · 2026-05-01 (±quarter) OCC comment period closes on GENIUS Act implementing rule_consultation · TT1_ Horizon · 2026-06-09 (±quarter) FinCEN/OFAC comment period closes on PPSI AML/CFT proposed rule_consultation · TT1_ Standing sub-brief · as of 7 July 2026 206 words · last cycle 2026-07-05 #### Stablecoins & Digital Money Michigan has no dedicated state-level stablecoin statute; the operative framework for both bank and non-bank issuers serving Michigan is the federal GENIUS Act, signed into law on 2025-07-18, which establishes a federal framework for payment-stablecoin issuance, operation and regulation applying nationwide. Three implementing rulemakings are proceeding in parallel through 2026. The OCC has proposed a rule governing stablecoin issuance and custody activities of national banks, federal savings associations, federal branches, and federal- or state-qualified payment stablecoin issuers, with comments due 2026-05-01 — a track that directly shapes the issuer pathway available to Michigan state-chartered banks. The FDIC proposed, on 2025-12-19, application requirements and procedures for FDIC-supervised institutions, including Michigan state nonmember banks, to issue payment stablecoins through a subsidiary. And FinCEN and OFAC jointly proposed a rule, with comments due 2026-06-09, treating permitted payment stablecoin issuers as Bank Secrecy Act financial institutions subject to AML and sanctions-compliance obligations. #### Outlook With both the OCC and FinCEN/OFAC comment periods now closed, final rule text and effective dates are the next milestones to watch; these will determine the practical issuance pathway — and compliance burden — for any Michigan-chartered bank or qualified issuer seeking to enter stablecoin issuance ahead of, or absent, any Michigan-specific statute. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.kslaw.com/news-and-insights/stablecoin-legislation-has-left-the-stable](https://www.kslaw.com/news-and-insights/stablecoin-legislation-has-left-the-stable) 2. T1 [https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the](https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the) 3. T1 [https://www.federalregister.gov/documents/2025/12/19/2025-23510/approval-requirements-for-issuance-of-payment-stablecoins-by-subsidiaries-of-fdic-supervised-insured](https://www.federalregister.gov/documents/2025/12/19/2025-23510/approval-requirements-for-issuance-of-payment-stablecoins-by-subsidiaries-of-fdic-supervised-insured) 4. T1 [https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism](https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism) ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-05 Michigan's operational-resilience layer combines MCL 445.72 breach notification, DIFS cybersecurity event notification (Form FIS 2359), and PA 690 of 2018 for insurance licensees. A five-bill reform package (SB 360-364), passed by the Senate August 2025, would tighten the breach standard to a firm 45-day deadline with new civil penalties; pending in the House as of March 2026. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 7 July 2026 191 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Michigan's operational-resilience layer combines general and sector-specific instruments. The Identity Theft Protection Act (MCL 445.72) requires notice to affected Michigan residents without unreasonable delay upon discovery of a security breach, unless substantial harm is unlikely, with a safe harbor for institutions compliant with federal interagency guidance. DIFS separately requires licensees to notify it within 10 business days of determining a cybersecurity event occurred (Form FIS 2359), under the Michigan Insurance Data Security Law (PA 690 of 2018), alongside an annual compliance-certification filing (Form FIS 2360) due February 15. A five-bill reform package, Senate Bills 360-364, would tighten this standard considerably: a firm 45-day breach-notification deadline, civil fines of up to $2,000, and alignment with NIST CSF 2.0. The package passed the Senate 19-15 on 2025-08-26 and remained pending in the House Committee on Government Operations as of March 2026. #### Outlook Enactment of SB 360-364 would convert Michigan's current "without unreasonable delay" standard into a hard deadline with attached financial penalties, raising both the compliance bar and the enforcement exposure for payments firms operating in the state; its progress through the House is the item to track. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-445-72](https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-445-72) 2. T1 [https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification](https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification) 3. T3 [https://www.recordinglaw.com/us-laws/data-privacy-laws/michigan-data-privacy-laws/data-breach-notification/](https://www.recordinglaw.com/us-laws/data-privacy-laws/michigan-data-privacy-laws/data-breach-notification/) 4. T3 [https://www.perkinscoie.com/en/news-insights/security-breach-notification-chart-michigan.html](https://www.perkinscoie.com/en/news-insights/security-breach-notification-chart-michigan.html) ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Michigan permits credit-card surcharging (since a 2013 settlement lifted the Visa/Mastercard ban) but imposes state-specific disclosure duties, prohibits debit surcharging, and treats surcharge fees as part of the taxable sales price under the General Sales Tax Act per 2024 Treasury guidance. Standing sub-brief · as of 7 July 2026 97 words · last cycle 2026-07-05 #### Scheme & Network Compliance Michigan merchants have been permitted to surcharge credit-card transactions since a 2013 Visa/Mastercard/bank class-action settlement lifted the contractual surcharging ban; debit-card surcharging remains prohibited under card-network rules and federal law. The Michigan Department of Treasury has determined that credit-card surcharges form part of the taxable "gross proceeds" or "sales price" under the General Sales Tax Act, subjecting them to the state's 6% sales tax. #### Outlook The sales-tax treatment of surcharges adds a distinct compliance layer for Michigan merchants beyond card-network disclosure rules, and is a state-specific wrinkle on an otherwise federally-settled surcharging landscape. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/shopping/credit-debit-card-surcharges](https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/shopping/credit-debit-card-surcharges) 2. T1 [https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-act-379-of-1984](https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-act-379-of-1984) 3. T2 [https://www.nfib.com/news/news/mi-department-of-treasury-to-small-business-credit-card-surcharge-fees-subject-to-sales-tax/](https://www.nfib.com/news/news/mi-department-of-treasury-to-small-business-credit-card-surcharge-fees-subject-to-sales-tax/) 4. T3 [https://www.getnickel.com/surcharge-laws/michigan](https://www.getnickel.com/surcharge-laws/michigan) 5. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/michigan-credit-card-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/michigan-credit-card-surcharge-laws/) ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Michigan financial institutions participate in the national FedNow rail; MSUFCU is a documented Michigan participant operating receive-only with planned send-side expansion, reflecting national credit-union-led gradual FedNow adoption rather than Michigan-specific corridor infrastructure. Standing sub-brief · as of 7 July 2026 126 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Michigan State University Federal Credit Union (MSUFCU) participates in the FedNow Service on a receive-only basis, with planned send-side capability, citing gig-worker and student demand for instant access to funds. This sits within a national FedNow expansion in which the service reached more than 1,500 participating financial institutions across all 50 states by late 2025 — a 44% year-on-year increase — with the per-transaction limit raised from $1 million to $10 million effective November 2025. No Michigan-specific corridor infrastructure beyond this national-rail participation was identified this cycle. #### Outlook MSUFCU's stated intent to add send-side capability, and its exploration of further FedNow use cases (see W9), positions it as a bellwether for credit-union-led instant-payments adoption in Michigan rather than evidence of state-specific corridor build-out. no periodic updates on record for this sub-brief ** Sources and findings (2)** 1. T1 [https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union](https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union) 2. T1 [https://www.frbservices.org/news/fed360/issues/121625/general-2026-fees-payment-system-enhancements](https://www.frbservices.org/news/fed360/issues/121625/general-2026-fees-payment-system-enhancements) ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 Michigan's payments-adjacent industry structure is being reshaped by Fifth Third's $10.9-12.7bn acquisition of Comerica, alongside a growing Detroit/Ann Arbor fintech and credit-union-fintech-partnership ecosystem (Rocket Companies, Bankjoy, InvestNext, Autobooks, MSUFCU-Zirtue). Standing sub-brief · as of 7 July 2026 163 words · last cycle 2026-07-05 #### Industry Structure & Commercial Dynamics Michigan's payments-adjacent banking structure was reshaped in the review period by Fifth Third Bancorp's $12.7 billion all-stock acquisition of Comerica Incorporated, closed in February 2026. The combination creates the ninth-largest US bank by assets (approximately $288 billion) and makes Fifth Third the largest bank by Michigan and Detroit retail deposit share, with 227 combined Michigan branches remaining after 75 closures. Separately, MSUFCU partnered with fintech Zirtue, integrated with Plaid, to offer a friends-and-family lending platform. Detroit's broader fintech ecosystem includes Autobooks (embedded SMB banking, which raised a $50 million Series C in 2022 plus $40 million in further growth funding), InvestNext, and Y Combinator-backed digital-banking provider Bankjoy. #### Outlook The Fifth Third-Comerica combination is the dominant structural fact shaping Michigan's payments-adjacent banking landscape and will condition deposit concentration, branch access and settlement scale for the state for years to come; the smaller credit-union-fintech partnership activity (MSUFCU-Zirtue) and the Detroit embedded-fintech cluster represent the complementary, lower-scale layer of market development. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://www.detroitnews.com/story/business/2026/06/01/fifth-third-comerica-bank-branch-closures-michigan/90360145007/](https://www.detroitnews.com/story/business/2026/06/01/fifth-third-comerica-bank-branch-closures-michigan/90360145007/) 2. T2 [https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/](https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/) 3. T2 [https://www.americanbanker.com/creditunions/news/michigan-credit-union-helps-members-borrow-from-friends-and-family](https://www.americanbanker.com/creditunions/news/michigan-credit-union-helps-members-borrow-from-friends-and-family) 4. T3 [https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026](https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026) 5. T3 [https://builtin.com/companies/location/na/usa/mi/type/fintech-companies](https://builtin.com/companies/location/na/usa/mi/type/fintech-companies) ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 Michigan's enforcement campaign against prediction-market operators continued: Coinbase stipulated Oct 7, 2026 to halt new MI sports contracts and wind down by Oct 10, 2026; a CFTC interim final rule (eff. Oct 19, 2026) codified that licensed-sportsbook wagers are not CFTC swaps. Standing sub-brief · as of 7 July 2026 137 words · last cycle 2026-10-18 #### Legal & Litigation Michigan is at the center of the national prediction-markets legal battle. Attorney General Dana Nessel sued Kalshi in Ingham County Circuit Court on 2026-03-03, alleging unlicensed sports-related event contracts — including a Pistons-Wizards combined-point-total market — and seeking a permanent injunction. On 2026-06-17, U.S. District Judge Paul Maloney denied preliminary-injunction motions brought by Polymarket and Robinhood, finding sports-event contracts unlikely to qualify as Commodity Exchange Act "swaps" and holding that Michigan retains traditional gambling-regulation authority, citing Bond v. United States. #### Outlook The ruling leaves Michigan's state enforcement track intact in the near term, but the underlying federal preemption questions raised by Polymarket, Robinhood and related litigants remain unresolved; further appellate activity is the item to watch, and the outcome will have implications well beyond Michigan for the state-versus-federal division of authority over event-contract markets. Periodic update · new data 2026-10-18 #### Legal & Litigation Coinbase Financial Markets, Inc. stipulated with the Michigan Gaming Control Board to stop offering new sports-related event contracts to Michigan customers and to close out open positions by 12:00 a.m. Eastern time on October 10, 2026. Under the stipulation, the MGCB agreed not to pursue enforcement against Coinbase pending resolution of a Sixth Circuit appeal. This settlement follows a similar agreement reached by Robinhood on September 9, 2026, leaving Kalshi as the remaining operator subject to an injunction in this contested Michigan product segment. A Commodity Futures Trading Commission interim final rule, effective October 19, 2026, bears directly on this litigation: the rule excludes wagers placed with state- or tribal-licensed sportsbooks and casinos from the Commodity Exchange Act's swap definition. This federal action undercuts the federal-preemption defense that Coinbase, Kalshi, Robinhood and Polymarket have raised against Michigan Gaming Control Board enforcement in the pending Sixth Circuit appeal, strengthening the state's position that sports-related event contracts fall within its own gambling-licensing jurisdiction rather than under federal derivatives oversight. #### Outlook The Sixth Circuit's resolution of the federal-preemption question, now considered against the CFTC's new interim final rule, is the central variable to watch. A ruling against the preemption defense would likely confirm Michigan's gambling-licensing jurisdiction over sports-related event contracts, directly affecting Kalshi's ongoing injunction and any other platform contemplating a similar product in the state. **Sources and findings (4)** 1. T2 [https://michigangaming.com/michigans-fight-over-prediction-markets/](https://michigangaming.com/michigans-fight-over-prediction-markets/) 2. T2 [https://www.gamblinginsider.com/news/115936/michigan-kalshi-lawsuit-polymarket-robinhood-prediction-markets](https://www.gamblinginsider.com/news/115936/michigan-kalshi-lawsuit-polymarket-robinhood-prediction-markets) 3. T1 [https://www.gamblinginsider.com/news/167546/michigan-judge-denies-polymarket-robinhood-injunctions](https://www.gamblinginsider.com/news/167546/michigan-judge-denies-polymarket-robinhood-injunctions) 4. T3 [https://www.playmichigan.com/news/federal-judge-denies-polymarket-bid-to-block-michigan-enforcement/](https://www.playmichigan.com/news/federal-judge-denies-polymarket-bid-to-block-michigan-enforcement/) ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Michigan's merchant-acquiring risk framework is defined largely by consumer-facing surcharge disclosure rules rather than a distinct acquiring-license regime; merchants operate under the general bank-sponsorship/card-network model, with MI-specific obligations concentrated in surcharge signage/receipt/online disclosure. Standing sub-brief · as of 7 July 2026 102 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk Michigan does not operate a distinct merchant-acquiring license regime; fintechs and merchants instead access card networks, wires and ACH through the standard U.S. sponsor-bank model. The state's principal acquiring-adjacent obligations are consumer-facing surcharge rules: signage and disclosure requirements at the store entrance and point-of-sale terminal, and online disclosure at first mention of a credit-card payment option, with surcharges capped at processing cost and prohibited from varying by card brand. #### Outlook Michigan's acquiring-risk framework remains thin relative to a dedicated licensing regime, with surcharge disclosure compliance the primary state-specific obligation layered on top of the national sponsor-bank access model. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [https://www.getnickel.com/surcharge-laws/michigan](https://www.getnickel.com/surcharge-laws/michigan) 2. T1 [https://www.legislature.mi.gov/documents/2013-2014/billanalysis/House/archive/2013-HLA-4255-74A48DFB.HTM](https://www.legislature.mi.gov/documents/2013-2014/billanalysis/House/archive/2013-HLA-4255-74A48DFB.HTM) 3. T3 [https://www.lithic.com/blog/bank-partners](https://www.lithic.com/blog/bank-partners) ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Michigan's product-innovation layer is anchored in Detroit's growing embedded-fintech and credit-union-fintech ecosystem (Autobooks, InvestNext, Bankjoy, MSUFCU FedNow/Zirtue), supported by public seed-stage capital via the City of Detroit's Startup Fund. Standing sub-brief · as of 7 July 2026 106 words · last cycle 2026-07-05 #### Product Innovation & Market Development The City of Detroit launched a $700,000 Startup Fund distributing seed grants of $15,000 and scale grants of $50,000 to Detroit-area startups, including fintechs; a second round in February 2026 awarded $300,000 across 13 startups. Separately, MSUFCU is exploring additional FedNow use cases beyond its current receive-only participation, including indirect auto-loan funding, student-loan refund disbursement, and insurance-payout disbursement. #### Outlook Both threads point to Michigan's product-innovation layer being anchored in public seed capital and credit-union-led instant-payments experimentation rather than a distinct state regulatory sandbox; MSUFCU's use-case expansion is the item most likely to generate further FedNow-linked product activity in the next cycle. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union](https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union) 2. T2 [https://detroitmi.gov/news/detroit-launches-first-its-kind-700000-startup-fund-fuel-job-creation-and-talent-retention](https://detroitmi.gov/news/detroit-launches-first-its-kind-700000-startup-fund-fuel-job-creation-and-talent-retention) 3. T2 [https://www.crainsdetroit.com/entrepreneurship/detroits-municipal-startup-fund-awards-its-first-300000](https://www.crainsdetroit.com/entrepreneurship/detroits-municipal-startup-fund-awards-its-first-300000) 4. T3 [https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026](https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026) ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-05 Michigan consumer protection for payments harms runs through the AG's Consumer Protection Team and DIFS, with active AG alerts targeting P2P payment-app scams and AI voice-cloning fraud; there is no dedicated state APP-fraud reimbursement mandate. Standing sub-brief · as of 7 July 2026 114 words · last cycle 2026-07-05 #### Consumer Protection & APP Fraud The Michigan Attorney General's Consumer Protection Team maintains active alerts warning consumers about peer-to-peer payment-app scams, including "return the money" patterns exploiting stolen funds, directing victims to the app host, the FTC, or the CFPB. In April 2026, during Money Smart Week, Attorney General Dana Nessel reissued an AI Scams consumer alert warning of AI-generated deepfake voice-cloning fraud that impersonates loved ones to solicit payment-app transfers. #### Outlook Michigan has no dedicated state APP-fraud reimbursement mandate; consumer redress for payment-app fraud continues to depend on federal complaint channels (FTC, CFPB) and informal AG-level alerting rather than a statutory liability-shifting regime, leaving a policy gap relative to reimbursement models developed elsewhere. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/scams/payment-apps-and-scams](https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/scams/payment-apps-and-scams) 2. T1 [https://www.michigan.gov/ag/news/press-releases/2026/04/20/ag-nessel-reissues-ai-scams-consumer-alert-during-money-smart-week](https://www.michigan.gov/ag/news/press-releases/2026/04/20/ag-nessel-reissues-ai-scams-consumer-alert-during-money-smart-week) 3. T1 [https://www.michigan.gov/ag/news/press-releases/2024/12/23/ag-nessel-warns-consumers-about-holiday-payment-apps-and-scams](https://www.michigan.gov/ag/news/press-releases/2024/12/23/ag-nessel-warns-consumers-about-holiday-payment-apps-and-scams) 4. T1 [https://www.michigan.gov/ag/consumer-protection](https://www.michigan.gov/ag/consumer-protection) ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-michigan/#sec-dom-D7) Probable confirmed 2026-07-05 W11 carries the Sentinel.gi feed only; no jurisdiction-specific Sentinel.gi content for US-MI was retrievable this cycle. Standing federal BSA framework layers onto MTSA licensees; no original illicit-finance analysis performed (FIM territory). Standing sub-brief · as of 7 July 2026 133 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime This module is sourced from the Sentinel.gi feed; no Michigan-specific Sentinel.gi content was retrievable via open-web search this cycle. What can be carried is the standing statutory backdrop: Michigan MTSA licensees must maintain a documented AML/BSA compliance program as a continuing condition of licensure, alongside quarterly MSB Call Reports, and both the current MTSA and the pending MTMA incorporate the federal Bank Secrecy Act (Public Law 91-508) and its implementing regulations by reference into state licensing conditions. No original illicit-finance analysis has been performed here; readers seeking substantive AML/CFT intelligence should consult the Sentinel.gi feed directly. #### Outlook Sentinel-fed W11 coverage for Michigan is thin relative to Anglosphere and EU jurisdictions in this feed; this is a known under-indexing pattern rather than a signal that Michigan-specific illicit-finance activity is absent. no periodic updates on record for this sub-brief ** Sources and findings (7)** 1. T1 [https://www.legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm](https://www.legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm) 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Michigan — Michigan operates entirely within the federal BSA/AML, OFAC-sanctions and FinCEN CTA architecture; the state layer consists of Department of Licensing and Regulatory Affairs (LARA) corporate formation (no beneficial-ownership verification), DIFS licensing of money transmitters under the Uniform Money Services Act, and Attorney General consumer-protection alerts on crypto fraud. No independent state FIU exists; Michigan financial institutions rely wholly on federal supervisory and enforcement infrastructure. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC licence-change 5. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: FinCEN — Financial institutions nationwide, including Michigan-based banks and MSBs 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure 7. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap ### W12 Correspondent Banking, Settlement & Access Uncertain confirmed 2026-07-05 No Michigan-specific correspondent-banking de-risking event or settlement-access initiative identified; Michigan institutions subject to the same national de-risking pressures, mitigated partly by scale gains from Fifth Third-Comerica. Standing sub-brief · as of 6 August 2026 212 words · last cycle 2026-08-05 #### Correspondent Banking, Settlement & Access Michigan-licensed money-service businesses sit within a correspondent-banking and settlement overlay that applies across both bank and non-bank institutions rather than to one access tier alone. FinCEN's Corporate Transparency Act beneficial-ownership rule has narrowed reporting scope to foreign entities only, exempting domestic entities and their beneficial owners; the final rule is pending review at the Office of Management and Budget's Office of Information and Regulatory Affairs since 5 June 2026, a disposition that will determine whether the domestic-entity exemption becomes permanent. Separately, FinCEN's AML/CFT program-effectiveness proposal under 31 CFR Part 1021 would require board-level approval of AML/CFT programs, a documented risk-assessment methodology, and a US-located responsible officer for BSA-regulated institutions, including casinos; the comment period closed on 9 June 2026 and the final rule remains pending. #### Outlook The CTA beneficial-ownership final rule's OMB disposition is expected around 2026-Q4 on a half-year uncertainty band. FinCEN's Part 1021 final rule is expected around 2027-Q1 on a half-year uncertainty band. The narrowed CTA scope reduces the beneficial-ownership transparency backdrop for Michigan-registered entities, and the Part 1021 governance standard, if finalized as proposed, would raise compliance costs for Michigan's Detroit commercial and tribal casino payment operations; both developments are flagged as illicit-finance relevant, with original analysis belonging to the Financial Integrity Monitor. Periodic update · new data 2026-08-11 #### Correspondent Banking, Settlement & Access Michigan-licensed payment and gaming-sector respondents face a widening federal overlay this cycle that bears directly on correspondent-banking settlement and access decisions, even though no Michigan-specific correspondent-banking instrument moved. Two federal developments define the picture. First, the Corporate Transparency Act's beneficial-ownership-information reporting rule now exempts domestic entities and their beneficial owners from reporting, limiting the mandatory disclosure regime to foreign entities only; this High-confidence finding is corroborated directly by FinCEN's own published guidance. Second, the Financial Crimes Enforcement Network's proposed overhaul of AML/CFT program-effectiveness standards under 31 CFR Part 1021 would require board-level governance approval, a documented risk-assessment methodology, and a US-located responsible officer for BSA-regulated institutions, including casinos; this Assessed-confidence proposal's comment period closed June 9, 2026, with the final rule still pending. The analytical spine of correspondent-banking analysis is the asymmetry between bank and non-bank access: chartered banks generally carry direct, long-standing correspondent relationships and dedicated compliance infrastructure to satisfy a correspondent's due-diligence requirements, while non-bank payment institutions, e-money issuers, and money-services businesses typically access settlement rails indirectly, through a sponsoring bank or a thinner set of correspondent relationships that are more sensitive to shifts in the underlying compliance backdrop. Both federal developments this cycle widen that asymmetry rather than narrow it. The beneficial-ownership reporting narrowing reduces the ownership-transparency information a correspondent can obtain through federal registries when assessing a Michigan-registered non-bank respondent, shifting more of that verification burden onto the correspondent's own customer due-diligence program. The Part 1021 proposal, while nominally targeted at casinos and card clubs rather than non-bank payment institutions directly, raises the governance bar for an entire category of BSA-regulated institution that shares infrastructure and customer bases with Michigan's licensed payments ecosystem, and a correspondent assessing settlement risk for gaming-adjacent payment flows would reasonably read the proposal as raising the compliance standard its respondent must be able to evidence. Neither development is Michigan-specific in its drafting, but both reach Michigan directly: Michigan's Detroit commercial casinos and tribal gaming operations are Part 1021-regulated institutions, and Michigan-registered payment and money-services entities are subject to the same federal beneficial-ownership reporting rule as any other US-registered entity. The correspondent-banking read for this cycle is accordingly one of federal-overlay tightening on the governance and transparency dimensions, layered onto a licensing framework that itself remains in a modernization-pending state. #### Outlook The Office of Management and Budget's review of the Corporate Transparency Act final rule, expected in the fourth quarter of 2026, and the FinCEN Part 1021 rule's anticipated finalization in the first quarter of 2027, are the two events that will determine whether this cycle's tightening trajectory continues, stabilizes, or reverses. A correspondent bank recalibrating its risk appetite for Michigan-licensed payment and gaming-sector respondents should treat both as live inputs; neither has reached a final, settled state this cycle. **Sources and findings (2)** 1. T1 [https://www.congress.gov/crs-product/IF10873](https://www.congress.gov/crs-product/IF10873) 2. T2 [https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/](https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/) ### W13 Commercial Intelligence (M&A, Investment & Product) limited signal Probable confirmed 2026-07-05 Trailing 12 months (Jul 2025-Jul 2026) saw major MI-linked M&A: Fifth Third-Comerica, Acrisure-Heartland Payroll Solutions, Rocket Companies-Redfin/Mr. Cooper, and Supreme Lending-Michigan Mutual, alongside continued Detroit fintech seed activity. Standing sub-brief · as of 7 July 2026 221 words · last cycle 2026-10-18 #### Commercial Intelligence The trailing twelve months produced a cluster of Michigan-linked commercial events. Fifth Third Bancorp's acquisition of Comerica Incorporated, valued at $10.9-12.7 billion all-stock, was announced 2025-10-06 and closed in February 2026. Acrisure LLC acquired Heartland Payroll Solutions from Global Payments Inc. for $1.1 billion, announced 2025-05-28 and closed 2025-10-01. Rocket Companies closed its $14.2 billion acquisition of Mr. Cooper Group on 2025-10-01, creating a combined mortgage-servicing portfolio of nearly 10 million homeowners, and separately integrated its earlier Redfin acquisition — a deal for which the amount was not publicly disclosed — generating a reported $140 million in cost savings within six months per CEO commentary on Q4 2025 earnings, with employee buyouts offered in March 2026 amid the Redfin/Mr. Cooper integration. Supreme Lending announced its acquisition of Port Huron-based Michigan Mutual around late May 2025; the deal value was not publicly disclosed. On the investment side, Benzinga Ventures invested in Detroit fintech startup Unlock Technologies at seed stage during 2025; the amount was not publicly disclosed. #### Outlook The concentration of large, completed M&A around Fifth Third-Comerica and Rocket's mortgage-servicing consolidation marks the highest level of Michigan-linked payments-adjacent deal activity captured this cycle; further integration milestones (Rocket's Redfin/Mr. Cooper buyout program) and any update on the undisclosed-value Supreme Lending-Michigan Mutual and Benzinga-Unlock transactions are the items to track next cycle. Periodic update · new data 2026-10-18 #### Commercial Intelligence & Fintech Coinbase Financial Markets, Inc.'s Michigan sports-related event-contract product line was wound down under a stipulated agreement with the Michigan Gaming Control Board, effective October 10, 2026. No monetary amount was disclosed in connection with this restructuring. The regulatory review by the Michigan Gaming Control Board concluded with the arrangement cleared with conditions: Coinbase ceased offering new sports-related event contracts to Michigan customers and closed out open positions by the effective date, while the MGCB agreed to withhold enforcement pending the outcome of a Sixth Circuit appeal. This follows a similar product wind-down previously agreed by Robinhood for its own Michigan sports-related event-contract offering on September 9, 2026. #### Outlook Whether Kalshi, the remaining operator still offering sports-related event contracts in Michigan under an active injunction, reaches a similar negotiated wind-down or instead prevails on its federal-preemption argument before the Sixth Circuit will determine whether this product line sees a complete exit from the Michigan market or a partial survival contingent on the litigation's outcome. **Sources and findings (6)** 1. T2 [https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/](https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/) 2. T2 [https://www.crainsdetroit.com/mergers-acquisitions/these-were-largest-michigan-ma-deals-2025](https://www.crainsdetroit.com/mergers-acquisitions/these-were-largest-michigan-ma-deals-2025) 3. T1 [https://ir.rocketcompanies.com/news-and-events/press-releases/press-release-details/2025/Rocket-Companies-Closes-14-2-Billion-Acquisition-of-Mr--Cooper/default.aspx](https://ir.rocketcompanies.com/news-and-events/press-releases/press-release-details/2025/Rocket-Companies-Closes-14-2-Billion-Acquisition-of-Mr--Cooper/default.aspx) 4. T2 [https://www.detroitnews.com/story/business/2026/03/20/rocket-companies-offers-buyouts-as-it-integrates-redfin-and-mr-cooper/89243158007/](https://www.detroitnews.com/story/business/2026/03/20/rocket-companies-offers-buyouts-as-it-integrates-redfin-and-mr-cooper/89243158007/) 5. T3 [https://www.housingwire.com/articles/supreme-lending-to-acquire-michigan-mutual-sources/](https://www.housingwire.com/articles/supreme-lending-to-acquire-michigan-mutual-sources/) 6. T3 [https://www.ellty.com/blog/detroit-investors](https://www.ellty.com/blog/detroit-investors) ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for United States – Michigan| Field | Value | |---|---| | `trust.lawyer_review.status` | unavailable | | ` trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 2 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 61 finding(s), 8 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).