title: United States – Montana Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-montana/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Montana US-MT schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 64 sourced findings · 131 sources in the cumulative register 14 Modules baseline.modules[] 64 Findings modules[].findings[] 37 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 – Montana is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Montana’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 4 October 2026 #### Lead Signal The Kalshi-Montana prediction-market dispute moved decisively toward resolution of its procedural posture this period, without resolving the underlying market-access question. On August 27, 2026, the U.S. District Court for the District of Montana, under Judge Donald W. Molloy, denied Kalshi's motion for a preliminary injunction against Montana officials, finding no irreparable harm and lifting the prior case stay, with the court ordering Montana to respond within 21 days. Three weeks later, on September 17, 2026, Kalshi and Montana officials filed a joint stipulation dismissing the suit, with prejudice as to members of the Lottery and Sports Wagering Commission and without prejudice as to the Attorney General and the Gambling Control Division. Under the stipulation, Montana agreed not to pursue enforcement against Kalshi's event contracts until Ninth Circuit en banc review concludes, with the pause running until the Ninth Circuit either denies further review or issues an en banc decision. For payments and market-access infrastructure built around event-contract products, this is a live-wire development: it establishes, by negotiated settlement rather than adjudication, that a state can credibly assert jurisdiction over event-contract market access while simultaneously agreeing to stand down pending a federal appellate outcome it does not control. #### Other Developments No other Montana-specific payments development met the bar for inclusion this period. The state's long-standing non-regulation of money transmitters persists without a licensing-framework change, and no new evidence was found across the remaining domain modules tracked for this jurisdiction. #### Cross-Monitor Connections The Kalshi dismissal is a litigation event with direct relevance to market-access questions for event-contract and prediction-market products operating in, or adjacent to, regulated payments and gaming-adjacent rails; firms processing settlement or acquiring flows for such products in states within the Ninth Circuit's jurisdiction should track the pending en banc review as a determinative variable for market-access risk, independent of any state's existing money-transmission posture. #### Outlook The operative date to watch is whatever the Ninth Circuit sets for en banc disposition of KalshiEX v. Assad; Montana's enforcement pause against Kalshi's event contracts is explicitly tied to that outcome, with a further 30-day notice period built in before any enforcement resumption. No primary appellate docket confirming an en banc review timeline was identified this period, so the resolution date remains unknown. _1 earlier update not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Montana's first full-cycle baseline mapping surfaces a jurisdiction defined by a structural anomaly: it is the sole US state that does not operate a state-level money transmitter licensing regime, leaving transmitters to rely solely on federal FinCEN MSB registration while Montana's Division of Banking and Financial Institutions (DBFI) licenses only adjacent activities — escrow, consumer finance, retail sales finance, and mortgage lending — under Title 32 of the Montana Code Annotated. A March 2023 informal DBFI letter seeking business-plan and flow-of-funds data from transmitters was withdrawn shortly after issuance, and no renewed attempt has followed. That licensing vacuum sits alongside a second, newer signal: the October 2025 enactment of the Financial Freedom and Innovation Act (SB 265), which creates Montana's first regulatory framework for "network tokens" under the State Auditor's authority, pairs it with an explicit CBDC prohibition, and extends self-custody and staking protections building on the 2023 "Right to Mine" Act. Together the two findings describe a state that is simultaneously the most permissive in the country on core money-transmission licensing and newly assertive on crypto-specific market structure — a combination that positions Montana as a distinct outlier jurisdiction for payments and digital-asset firms scoping US state-by-state entry strategies. #### Other Developments Montana's conduct and safeguarding layer runs through activity-specific bonding rather than a unified code: escrow licensees post a $100,000 surety bond and debt-management licensees a $50,000 bond, backstopped by the state's general UDAP statute (MUTPCPA, Title 30 chapter 14), which was strengthened by SB488 in 2025 to reach deceptive reviews and testimonials. Operational resilience is anchored by a breach-notification regime requiring immediate Attorney General notification upon discovery — ahead of consumer notice — under both the general-business and insurance-licensee statutes, with simultaneous electronic filing to the AG's Office of Consumer Protection. On card-scheme compliance, a reviewer challenge this cycle corrected an earlier attribution: Senate Bill 528, previously understood as the enacting statute for Montana's roughly 3% private-merchant surcharge cap, in fact died in standing committee on 23 May 2025 and was never enacted. The legal basis for general private-merchant surcharging beyond the two government-payment fee-passthrough statutes (MCA 61-3-117 for state agencies and MCA 7-6-617 for local government) is now flagged as an open question rather than settled law. Consolidation continues in the state-chartered banking sector — 33 banks with 682 branches and 8 loan-production offices as of May 2026 — highlighted by Frontier Credit Union's completed acquisition of First Citizens Bank of Butte on 1 February 2026, the first full credit-union acquisition of a Montana bank, adding $75 million in assets and one branch on undisclosed terms. Separately, a reviewer challenge flagged a source-citation mismatch on Eagle Bancorp Montana's reported Q4/full-year 2025 earnings: the figures ($4.7 million Q4 net income, +30.3% year-on-year; $14.8 million full-year, +51.7%) are independently corroborated by GlobeNewswire, but the SEC filing URL originally cited corresponded to the prior year's results, and confidence has been downgraded pending clean reconciliation. On consumer protection, crypto-ATM fraud caused roughly $2 million in Montana losses in 2025 alone; the state maintains a legislature-authorized restitution fund (one of six states to do so), but crypto ATMs remain unregulated at both state and federal level, and a state legislator is drafting a bill for the 2027 session. The State Auditor's office is meanwhile prosecuting multiple crypto-fraud cases, including an Idaho resident charged in October 2025 for defrauding elderly Montana residents and a Missoula County Ponzi-style case, against a backdrop of digital-asset fraud complaints rising from 9 cases worth over $1 million in 2024 to 20 cases worth $3.1 million through September 2025. On corridor infrastructure, Montana's payment rails run through the Federal Reserve Bank of Minneapolis's Helena Branch, with growing FedNow instant-payments participation among community banks and credit unions, though the Federal Reserve has flagged a persistent rural and tribal credit-access gap affecting institutions serving the Flathead and Blackfeet reservations. #### Cross-Monitor Connections Several findings from this cycle carry illicit-finance significance that sits outside WPM's market-structure remit but is directly relevant to Sentinel.gi's asset-recovery and AML/CFT tracking: the State Auditor's active crypto-fraud prosecutions, the rising crypto-ATM fraud caseload, and the fact that federal FinCEN BSA/MSB registration remains the sole AML compliance layer for money-transmission-adjacent activity in Montana in the absence of any state MTL or AML overlay. These have been flagged for the FIM monitor for fraud-typology and illicit-finance analysis; WPM's own treatment is confined to the regulatory-access and market-structure dimensions of these developments, not the underlying illicit use of the instruments involved. #### Outlook The most consequential forward marker is the 2027 Montana Legislature, where a crypto-ATM regulatory bill is being drafted by Representative Sprunger in coordination with the Commissioner of Securities and Insurance, aimed at closing the current state and federal regulatory gap around crypto kiosks. Also worth tracking is the trajectory of the Blockchain and Digital Innovation Task Force established alongside SB 265, whose follow-on findings and recommendations could shape the next phase of Montana's network-token framework, and whether DBFI makes any renewed attempt to informally solicit MTL-style business-plan or flow-of-funds data from transmitters, following the withdrawn 2023 approach. Absent a change to Montana's baseline posture as the only state without an MTL regime, market entrants should expect the federal-registration-only pathway to remain the operative compliance route for the foreseeable future. trust tier: ai_unverified ###### Latest update · 4 October 2026 #### Regulatory Status Montana's payments-adjacent regulatory posture this period is shaped entirely by the Kalshi prediction-market dispute rather than by any change to its payments or money-transmission framework. Following the district court's August 27, 2026 denial of Kalshi's preliminary-injunction motion, finding no irreparable harm shown, Kalshi and Montana officials filed a joint stipulation on September 17, 2026, dismissing the suit, with prejudice as to the Lottery and Sports Wagering Commission members and without prejudice as to the Attorney General and the Gambling Control Division. Montana agreed under that stipulation not to pursue enforcement against Kalshi's event contracts while Ninth Circuit en banc review of a controlling Nevada ruling remains pending, with 30 days' notice required before any enforcement resumption. Montana's underlying treatment of money transmitters is unchanged: the state does not maintain a money-transmitter licensing regime, a longstanding structural feature rather than a new development. #### Outlook The Ninth Circuit's en banc review outcome is the determinative event for whether Montana resumes enforcement against prediction-market event contracts; no confirmed timeline for that review was identified this period, and the 30-day notice term remains the operative buffer once a ruling issues. _1 earlier update not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Montana presents a distinctive dual profile: it is the only US state without a state-level money transmitter licensing regime, relying solely on federal FinCEN MSB registration for transmitters (W1a), while conduct and safeguarding for adjacent non-bank activity runs through activity-specific bonding and a UDAP backstop strengthened by SB488 (W1b). The state's most consequential recent regulatory action is the October 2025 enactment of the Financial Freedom and Innovation Act (SB265), establishing Montana's first network-token framework, a CBDC prohibition, and self-custody protections (W2). Operational resilience is governed by an unusually strict immediate-AG-notification breach regime (W3). On scheme compliance, this cycle corrected an earlier attribution regarding the state's private-merchant surcharge legal basis after SB528 was found to have died in committee, leaving that basis an open legal question (W4). Payment-corridor and correspondent-banking access run through the Federal Reserve Bank of Minneapolis's Helena Branch and expanding FedNow participation, against a Federal Reserve-flagged rural/tribal access gap (W5, W12). The state-chartered banking sector totals 33 banks and 682 branches amid active consolidation, most notably Frontier Credit Union's acquisition of First Citizens Bank of Butte, the first credit-union acquisition of a Montana bank (W6, W13). Legal and consumer-protection activity is dominated by rising crypto-fraud enforcement by the State Auditor's office and a sharply growing crypto-ATM fraud problem that remains unregulated at both state and federal level (W7, W10). Merchant acquiring and AML/CFT compliance (the latter Sentinel-sourced) both operate without a distinct Montana-specific overlay, resting instead on general federal frameworks (W8, W11). #### Outlook The single most concrete forward marker for Montana is the crypto-ATM regulatory bill being drafted for the 2027 Legislature by Representative Sprunger in coordination with the Commissioner of Securities and Insurance. Also worth tracking are the Blockchain and Digital Innovation Task Force's implementation findings under SB265, and whether DBFI renews its 2023 informal approach toward MTL-style data collection from transmitters. Barring a change to the state's baseline licensing posture, Montana's combination of permissive digital-asset market structure and a persistent MTL gap is likely to remain its defining regulatory characteristic through the next several cycles. 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 Montana is the sole US state that does not operate a state-level money transmitter licensing regime; DBFI licenses adjacent activities under Title 32 MCA; a brief 2023 informal solicitation attempt was withdrawn. Standing sub-brief · as of 5 July 2026 222 words · last cycle 2026-08-05 #### Licensing, Authorisation & Market Access Montana holds a singular position in the US regulatory map for payments: it is the only state that does not operate a state-level money transmitter licensing regime. The Division of Banking and Financial Institutions (DBFI) licenses only adjacent activities under Title 32 of the Montana Code Annotated - escrow businesses, consumer finance companies, retail sales finance, and mortgage lenders - leaving transmitters themselves to operate under federal FinCEN Money Services Business registration alone. This is not an oversight so much as a persistent policy choice: a March 2023 informal DBFI letter seeking business-plan and flow-of-funds information from transmitters, which industry observers read as an early step toward MTL-style oversight, was withdrawn shortly after issuance and has not been revisited. The posture makes Montana a genuine outlier following the 2023-2025 wave of Money Transmission Modernization Act adoption across most other states, a divergence corroborated by comparative industry tracking. #### Outlook Absent a new legislative initiative, Montana's licensing gap is unlikely to close in the near term; the operative market-access question for entrants is not licensing burden but regulatory ambiguity, since firms must rely on federal registration with no state-level safe harbor or supervisory relationship. Any renewed DBFI solicitation of MTL-style data, flagged explicitly as a lead signal to watch, would mark the first concrete step toward change since 2023. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Montana confirmed this cycle, through a primary statement from its own Division of Banking and Financial Institutions, that it remains the only US state without a money-transmitter licensing statute. Money-services businesses operating in Montana register only with the Secretary of State and rely on federal Bank Secrecy Act and money-services-business registration status in place of a state money-transmitter licence, an exemption structure with no equivalent among Montana's peer states. This finding carries a bank-versus-nonbank distinction worth stating explicitly: bank-provided payment services in Montana continue to operate under federal and state banking-charter supervision regardless of this gap, since the absence of a state MTL statute affects nonbank payment-institution and e-money-style money-transmission activity specifically, not bank-charter-based payment provision. Montana's position is further set apart by its total non-adoption of the Conference of State Bank Supervisors' Money Transmission Modernization Act, which thirty-one states have now enacted in full or in part. Montana has no base licensing regime to modernize in the first place, which places it outside the multistate harmonization trend entirely rather than merely lagging behind it in implementation. Separately, and materially, Kalshi filed a federal lawsuit against Montana asserting that the Commodity Futures Trading Commission holds exclusive jurisdiction over its event-contract products, directly testing whether Montana's state-level jurisdiction, whether framed as gambling law or financial-activity regulation, can reach a CFTC-regulated product operating in the state. The suit follows a 2025 state cease-and-desist letter. This is a live market-access dispute with direct relevance to any nonbank entity offering CFTC-regulated or CFTC-adjacent products in Montana, since its outcome will help define the boundary of state authority over such products. #### Outlook Watch for whether Montana's legislature or banking regulator moves toward a state money-transmitter licensing framework, a track not currently evidenced as active. Watch also for developments in Kalshi v. Montana, since a ruling would clarify the state's authority over CFTC-regulated products operating within its borders, a question with direct market-access implications for any similarly structured nonbank product. **Sources and findings (7)** 1. T1 [https://banking.mt.gov/moneytransmitters](https://banking.mt.gov/moneytransmitters) 2. T1 [https://archive.legmt.gov/bills/mca/title_0320/chapter_0010/part_0020/section_0110/0320-0010-0020-0110.html](https://archive.legmt.gov/bills/mca/title_0320/chapter_0010/part_0020/section_0110/0320-0010-0020-0110.html) retrieved 2026-07-05 3. T1 [https://archive.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0090/0320-0070-0010-0090.html](https://archive.legmt.gov/bills/mca/title_0320/chapter_0070/part_0010/section_0090/0320-0070-0010-0090.html) retrieved 2026-07-05 4. T1 [https://banking.mt.gov/MortgageConsumerFinance/FAQs](https://banking.mt.gov/MortgageConsumerFinance/FAQs) retrieved 2026-07-05 5. T1 [https://doa.mt.gov/BFID/mortgage-consumer-finance/](https://doa.mt.gov/BFID/mortgage-consumer-finance/) retrieved 2026-07-05 6. T3 [https://www.mwe.com/insights/montana-pump-fakes-a-requirement-for-money-transmitters/](https://www.mwe.com/insights/montana-pump-fakes-a-requirement-for-money-transmitters/) retrieved 2026-07-05 7. T3 [https://www.cooley.com/news/insight/2023/2023-09-12-model-money-transmission-modernization-act-12-states-take-action](https://www.cooley.com/news/insight/2023/2023-09-12-model-money-transmission-modernization-act-12-states-take-action) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Conduct/safeguarding runs through activity-specific bonding (escrow $100k; debt management $50k) with MUTPCPA as UDAP backstop, strengthened by SB488 (2025). Standing sub-brief · as of 5 July 2026 191 words · last cycle 2026-07-05 #### Conduct, Safeguarding & Financial Promotions Montana's conduct and safeguarding regime for non-bank payment-adjacent activity operates through activity-specific bonding rather than a single unified code. Escrow licensees must post a $100,000 surety bond and debt-management licensees a $50,000 bond, with the Montana Unfair Trade Practices and Consumer Protection Act (MUTPCPA, Title 30 chapter 14) serving as the general UDAP backstop across all activities. That backstop was strengthened in 2025 by SB488, which expanded its reach to deceptive online reviews and testimonials - a modernization responsive to the growth of digital marketing among licensed consumer-finance and escrow businesses. The bonding-based model contrasts with the unified conduct codes found in most Money Transmission Modernization Act states, reinforcing the bank-PSP vs non-bank-PI/EMI distinction that runs through Montana's broader regulatory architecture: banks operate under federal/state prudential supervision, while non-bank payment-adjacent licensees are governed by narrower, activity-specific bonding and UDAP enforcement rather than a payments-specific conduct regime. #### Outlook Watch for further UDAP modernization in subsequent legislative sessions, particularly as digital marketing and AI-generated reviews continue to expand the surface area SB488 was designed to address; no additional safeguarding legislation is currently signaled for Montana beyond this baseline. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://www.bondexchange.com/montana-escrow-business-license-bond/](https://www.bondexchange.com/montana-escrow-business-license-bond/) retrieved 2026-07-05 2. T1 [https://law.justia.com/codes/montana/title-30/chapter-14/part-1/section-30-14-103/](https://law.justia.com/codes/montana/title-30/chapter-14/part-1/section-30-14-103/) retrieved 2026-07-05 3. T3 [https://infobytes.orrick.com/2025-04-25/montana-enacts-consumer-protection-amendments-to-include-deception/](https://infobytes.orrick.com/2025-04-25/montana-enacts-consumer-protection-amendments-to-include-deception/) retrieved 2026-07-05 4. T1 [https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/](https://dojmt.gov/office-of-consumer-protection/debt-management-and-debt-settlement-businesses/) retrieved 2026-07-05 5. T1 [https://dojmt.gov/office-of-consumer-protection/](https://dojmt.gov/office-of-consumer-protection/) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-05 Montana enacted the Financial Freedom and Innovation Act (SB 265) in October 2025, creating a network-token regulatory framework, CBDC prohibition, and self-custody protections, building on SB 178 (2023). Standing sub-brief · as of 5 July 2026 188 words · last cycle 2026-07-05 #### Stablecoins & Digital Money Montana enacted the Financial Freedom and Innovation Act (SB 265) in October 2025, creating the state's first regulatory framework for "network tokens" under the authority of the State Auditor (Commissioner of Securities and Insurance), alongside an explicit prohibition on central bank digital currency and statutory protections for self-custody and staking. The Act builds directly on the 2023 "Right to Mine" Act (SB 178), which had already established baseline protections for crypto-mining activity, extending Montana's crypto-friendly legislative trajectory into token issuance and custody. The combination - permissive network-token framework, CBDC ban, self-custody protection - positions Montana as a comparatively liberal outlier among US states on digital-asset market structure, a framing with direct commercial relevance for payments-token issuers scouting lighter-touch state oversight environments. A Blockchain and Digital Innovation Task Force has been formed alongside the Act's passage to guide implementation. #### Outlook The Task Force's follow-on findings and recommendations are an explicit lead signal for the next cycle, as is the practical question of how the State Auditor's office operationalizes network-token oversight given its office is simultaneously prosecuting a rising volume of crypto-fraud cases (see W7, W10). no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://csimt.gov/2025/10/07/montana-opens-the-door-to-digital-asset-innovation-with-financial-freedom-and-innovation-act/](https://csimt.gov/2025/10/07/montana-opens-the-door-to-digital-asset-innovation-with-financial-freedom-and-innovation-act/) 2. T2 [https://dailymontanan.com/2025/10/08/montana-moves-forward-on-regulatory-framework-for-blockchain-digital-assets/](https://dailymontanan.com/2025/10/08/montana-moves-forward-on-regulatory-framework-for-blockchain-digital-assets/) retrieved 2026-07-05 3. T3 [https://www.montanasmarketplace.com/montana-living/crypto-in-montana](https://www.montanasmarketplace.com/montana-living/crypto-in-montana) retrieved 2026-07-05 4. T3 [https://cointelegraph.com/news/montana-governor-signs-pro-cryptocurrency-mining-bill-into-law](https://cointelegraph.com/news/montana-governor-signs-pro-cryptocurrency-mining-bill-into-law) retrieved 2026-07-05 5. T2 [https://www.kpax.com/news/montana-news/montana-moves-forward-on-regulatory-framework-for-blockchain-digital-assets](https://www.kpax.com/news/montana-news/montana-moves-forward-on-regulatory-framework-for-blockchain-digital-assets) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Confirmed confirmed 2026-07-05 Montana's operational-resilience posture rests on breach-notification statutes requiring immediate AG notification ahead of consumer notice. 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 5 July 2026 127 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Montana's operational-resilience posture centers on an unusually strict breach-notification regime. Under MCA 30-14-1701 through -1705 (general businesses) and MCA 33-19-321 (insurance licensees), Montana uniquely requires immediate Attorney General notification upon discovery of a computer security breach - ahead of consumer notification - together with simultaneous electronic submission of a copy to the AG's Office of Consumer Protection. This "regulator-first" sequencing is distinctive relative to the more common consumer-first or simultaneous-notice models found in most other states, and applies across both general commercial entities and insurance-licensed financial institutions operating in Montana. #### Outlook No legislative change to the breach-notification sequencing is currently signaled; the regime should be treated as a stable, distinctive baseline feature for any payments or financial-services entity operating in the state. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0040/0300-0140-0170-0040.html](https://mca.legmt.gov/bills/mca/title_0300/chapter_0140/part_0170/section_0040/0300-0140-0170-0040.html) retrieved 2026-07-05 2. T1 [https://dojmt.gov/office-of-consumer-protection/reporting-requirements-for-data-breaches/](https://dojmt.gov/office-of-consumer-protection/reporting-requirements-for-data-breaches/) retrieved 2026-07-05 3. T3 [https://pivitstrategy.com/what-to-do-after-a-cyberattack-in-montana-2026/](https://pivitstrategy.com/what-to-do-after-a-cyberattack-in-montana-2026/) retrieved 2026-07-05 4. T1 [https://mca.legmt.gov/bills/mca/title_0330/chapter_0190/part_0030/section_0210/0330-0190-0030-0210.html](https://mca.legmt.gov/bills/mca/title_0330/chapter_0190/part_0030/section_0210/0330-0190-0030-0210.html) retrieved 2026-07-05 5. T1 [https://sitsd.mt.gov/cybersecurity/](https://sitsd.mt.gov/cybersecurity/) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Montana permits credit card surcharging up to ~3% in market practice; MCA 61-3-117 (state agencies) and MCA 7-6-617 (local government) expressly authorize fee pass-through for government payments. SB 528 (2025), previously cited as the enacting private-merchant surcharge statute, died in standing committee 2025-05-23 and was never enacted; the statutory basis for general private-merchant surcharging remains an open question. Standing sub-brief · as of 5 July 2026 183 words · last cycle 2026-07-05 #### Scheme & Network Compliance Montana permits credit-card surcharging in market practice at rates up to approximately 3%, with pre-transaction disclosure norms observed by merchants. Government-payment fee pass-through is on clearer statutory footing: MCA 61-3-117 expressly authorizes state agencies to pass through card-processing fees on tax and fee payments, and MCA 7-6-617 does the same for local government. This cycle's research corrected a prior attribution: Senate Bill 528 (2025), previously understood as the enacting statute for the general private-merchant 3% surcharge cap, in fact died in standing committee on 23 May 2025 and was never enacted. As a result, the statutory basis for general private-merchant surcharging beyond the two government-specific fee-passthrough provisions is now an open question rather than settled law; merchants and PSPs relying on an assumed settled legal basis for the 3% cap should treat that basis as unresolved pending a future legislative session. #### Outlook A future Montana Legislature may need to codify private-merchant surcharge authority explicitly, given SB528's failure; this is a gap worth monitoring for statutory movement, alongside the state's continuing lack of an interchange-fee cap or card-scheme rulebook variance. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T2 [https://www.billtrack50.com/billdetail/1758739](https://www.billtrack50.com/billdetail/1758739) retrieved 2026-07-05 2. T1 [https://law.justia.com/codes/montana/title-61/chapter-3/part-1/section-61-3-117/](https://law.justia.com/codes/montana/title-61/chapter-3/part-1/section-61-3-117/) retrieved 2026-07-05 3. T3 [https://www.getnickel.com/surcharge-laws/montana](https://www.getnickel.com/surcharge-laws/montana) retrieved 2026-07-05 4. T3 [https://paymentcloudinc.com/blog/credit-card-surcharge-laws-by-state/](https://paymentcloudinc.com/blog/credit-card-surcharge-laws-by-state/) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Montana's payment-corridor infrastructure runs through the Fed Minneapolis Helena Branch and growing FedNow participation; no distinct MT-specific cross-border corridor regulation identified. Standing sub-brief · as of 5 July 2026 107 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Montana's payment-corridor infrastructure runs through the Federal Reserve Bank of Minneapolis's Helena Branch, which provides cash and coin distribution and economic liaison functions for the state, alongside growing FedNow instant-payments participation among Montana community banks and credit unions. No distinct Montana-specific cross-border or remittance-corridor regulation was identified separate from the federal framework; the state's corridor exposure is functionally a subset of the broader federal payment-rail architecture rather than a distinct state-level regime. #### Outlook FedNow adoption among Montana institutions is on an expanding trajectory and is a tracked signal for the jurisdiction; continued growth would further integrate Montana's community-bank and credit-union sector into instant-payments rails. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.minneapolisfed.org/about-us/our-helena-branch](https://www.minneapolisfed.org/about-us/our-helena-branch) retrieved 2026-07-05 2. T2 [https://www.csiweb.com/what-to-know/content-hub/blog/exploring-the-fednow-service-and-instant-payments/](https://www.csiweb.com/what-to-know/content-hub/blog/exploring-the-fednow-service-and-instant-payments/) retrieved 2026-07-05 3. T1 [https://www.federalreserve.gov/newsevents/speech/barr20260414a.htm](https://www.federalreserve.gov/newsevents/speech/barr20260414a.htm) retrieved 2026-07-05 4. T1 [https://www.frbservices.org/financial-services/fednow/organizations](https://www.frbservices.org/financial-services/fednow/organizations) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 33 state-chartered banks with 682 branches (May 2026) amid active consolidation, including Frontier Credit Union's acquisition of First Citizens Bank of Butte, plus a niche Bozeman fintech cluster. Standing sub-brief · as of 5 July 2026 178 words · last cycle 2026-07-05 #### Industry Structure & Commercial Dynamics Montana's state-chartered banking sector comprises 33 banks operating 682 branches and 8 loan-production offices as of May 2026, amid active consolidation. The most significant structural event is Frontier Credit Union's completed acquisition of First Citizens Bank of Butte, the first full credit-union acquisition of a bank in Montana history (detailed further at W13). Separately, a dated data point on Eagle Bancorp Montana, Inc. (NASDAQ: EBMT) requires a caution flag: independent reporting (GlobeNewswire, 27 January 2026) confirms Q4 2025 net income of $4.7 million (+30.3% year-on-year) and full-year 2025 net income of $14.8 million (+51.7%), but the SEC filing URL originally cited for these figures in this cycle's research corresponds to the January 2025 filing reporting Q4/FY2024 results ($3.4 million / $9.8 million) rather than FY2025 - a source-citation mismatch identified by reviewer challenge. #### Outlook The credit-union-acquires-bank precedent set by the Frontier/First Citizens deal signals continued cross-charter-type consolidation pressure on Montana's small state-chartered bank population; the Eagle Bancorp citation should be re-verified against the correct FY2025 SEC 8-K before being restored to Confirmed status. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://doa.mt.gov/BFID/banks/](https://doa.mt.gov/BFID/banks/) retrieved 2026-07-05 2. T3 [https://www.bankingdive.com/news/idaho-frontier-credit-union-buy-montana-first-citizens-bank-butte-icba/747027/](https://www.bankingdive.com/news/idaho-frontier-credit-union-buy-montana-first-citizens-bank-butte-icba/747027/) retrieved 2026-07-05 3. T3 [https://frontiercreditunion.com/blog/its-official-were-in-butte/](https://frontiercreditunion.com/blog/its-official-were-in-butte/) 4. T3 [https://www.mthightech.org/news/great-places-for-tech-in-montana-bozeman](https://www.mthightech.org/news/great-places-for-tech-in-montana-bozeman) retrieved 2026-07-05 5. T1 [https://www.sec.gov/Archives/edgar/data/0001478454/000117184326000431/exh_991.htm](https://www.sec.gov/Archives/edgar/data/0001478454/000117184326000431/exh_991.htm) retrieved 2026-07-05 ### W7 Legal & Litigation Probable confirmed 2026-07-05 Legal/enforcement activity concentrated in State Auditor crypto-fraud prosecutions and DBFI's enforcement register; complaints grew sharply through 2024-2025. Standing sub-brief · as of 5 July 2026 141 words · last cycle 2026-10-04 #### Legal & Litigation Legal and enforcement activity in Montana's payments-adjacent space is concentrated in the State Auditor's office (Commissioner of Securities and Insurance), which is prosecuting multiple crypto-fraud cases, including an Idaho resident charged in October 2025 for defrauding elderly Montana residents and a Missoula County Ponzi-style crypto case. Digital-asset fraud complaints have grown sharply, from 9 cases totaling over $1 million in 2024 to 20 cases totaling $3.1 million through September 2025 - more than doubling in dollar terms in under a year. This enforcement trajectory sits alongside, and is partly driven by, the state's newly liberalized network-token framework under SB265 (W2) and the unregulated crypto-ATM channel (W10). #### Outlook Expect continued escalation in State Auditor crypto-fraud prosecutions as digital-asset adoption grows under Montana's permissive framework; this trajectory is a direct input into the 2027 crypto-ATM legislative push tracked at W10. Periodic update · new data 2026-10-04 #### Legal & Litigation Montana's dispute with prediction-market platform Kalshi over the regulatory status of event contracts moved through two decisive procedural steps this period. On August 27, 2026, the U.S. District Court for the District of Montana, under Judge Donald W. Molloy, denied Kalshi's motion for a preliminary injunction against Montana gambling officials, finding Kalshi had not shown irreparable harm and specifically noting that Kalshi's repeated agreement to stay the matter for months at a time undermined its ability to make such a showing. That order lifted the existing case stay and set a 21-day response clock for Montana. On September 17, 2026, the parties filed a joint stipulation dismissing Kalshi's suit entirely, with prejudice as to the five members of the Montana Lottery and Sports Wagering Commission and without prejudice as to the Montana Attorney General and the Gambling Control Division. Under the stipulation's terms, Montana agreed not to pursue enforcement against Kalshi's event contracts for as long as Ninth Circuit en banc review of a controlling Nevada ruling remains pending; the pause runs until the Ninth Circuit either denies Kalshi's request for further review or issues an en banc decision, at which point Montana would still owe Kalshi 30 days' notice before resuming enforcement. This sequence matters beyond Montana: it shows a state regulator choosing stipulated forbearance over continued litigation once a federal appellate ruling on preemption became the operative variable, and it establishes a notice-period template (30 days post-ruling) that other states facing similar event-contract disputes may be watched against. #### Outlook The controlling event is Ninth Circuit en banc disposition of the underlying Nevada preemption question; no primary appellate docket confirmation of a review timeline was located this period. Until that ruling issues, Montana's stipulated enforcement pause holds, and the 30-day notice term governs how quickly enforcement exposure could re-emerge for event-contract providers. **1 earlier distinct update(s)** Periodic update · new data 2026-08-11 #### Legal & Litigation Kalshi v. Montana is this cycle's sole legal and litigation development for the jurisdiction. Kalshi's federal suit against Montana tests whether CFTC-regulated event contracts fall outside state gambling and financial-activity jurisdiction altogether, with the litigation reportedly citing Ninth Circuit and Arizona precedent in support of that position, per secondary press coverage; no primary court filing or docket record was independently retrieved this cycle, so this framing sits at Assessed rather than confirmed confidence. The suit follows a 2025 cease-and-desist letter from Montana's state gambling regulator, after which Kalshi's product remained operational without further enforcement action prior to the federal filing. The precedent risk here extends beyond the immediate dispute: if Kalshi prevails on federal preemption grounds, the resulting precedent could extend beyond gambling-adjacent event contracts to broader state authority over CFTC-regulated payment and settlement products operating in Montana, a Low-confidence but High-impact judgment given the novelty of the legal theory and the absence of a comparable precedent already having been tested to conclusion in this jurisdiction. #### Outlook No primary court filing or docket schedule was identified this cycle, so no forward ruling date can be set. The litigation's progression toward any substantive ruling, whether on a motion to dismiss, preliminary injunction, or eventual merits decision, is the clearest single marker to watch for this jurisdiction's legal and litigation profile. **Sources and findings (4)** 1. T3 [https://www.thebulldog.law/montana-s-financial-freedom-and-innovation-act-legal-guide-for-digital-asset-companies](https://www.thebulldog.law/montana-s-financial-freedom-and-innovation-act-legal-guide-for-digital-asset-companies) 2. T3 [https://www.thebulldog.law/montana-s-financial-freedom-and-innovation-act-legal-guide-for-digital-asset-companies](https://www.thebulldog.law/montana-s-financial-freedom-and-innovation-act-legal-guide-for-digital-asset-companies) 3. T1 [https://banking.mt.gov/Enforcement_Actions/Division_Enforcement_Actions](https://banking.mt.gov/Enforcement_Actions/Division_Enforcement_Actions) retrieved 2026-07-05 4. T2 [https://nbcmontana.com/news/local/montana-state-auditor-warns-of-uptick-in-crypto-atm-scams](https://nbcmontana.com/news/local/montana-state-auditor-warns-of-uptick-in-crypto-atm-scams) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Montana merchant acquiring operates under the general federal card-network framework, with the state's own footprint limited to the surcharge disclosure practice; no distinct MCC/chargeback statute identified. Standing sub-brief · as of 5 July 2026 97 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk Montana merchant acquiring operates under the general federal card-network framework, without a distinct state-specific regime for high-risk merchants, MCC-based classification, or chargeback handling. The state's own regulatory footprint in this space is effectively limited to the surcharge-disclosure practice addressed at W4; no Montana-specific statute governing merchant-category-code risk tiers or chargeback procedures was identified in this cycle's research. #### Outlook This is treated as a stable baseline absence rather than an active gap requiring near-term monitoring; any future Montana legislative activity on merchant acquiring would most likely arrive bundled with surcharge or card-scheme legislation (W4). no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/montana-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/montana-surcharge-laws/) retrieved 2026-07-05 2. T1 [https://law.justia.com/codes/montana/title-61/chapter-3/part-1/section-61-3-117/](https://law.justia.com/codes/montana/title-61/chapter-3/part-1/section-61-3-117/) retrieved 2026-07-05 3. T4 [https://963theblaze.com/why-am-i-being-charged-a-fee-to-use-my-card-at-montana-merchants/](https://963theblaze.com/why-am-i-being-charged-a-fee-to-use-my-card-at-montana-merchants/) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Montana's product-innovation frontier centers on SB265's network-token framework and the Blockchain and Digital Innovation Task Force, layered on FedNow adoption. Standing sub-brief · as of 5 July 2026 111 words · last cycle 2026-07-05 #### Product Innovation & Market Development Montana's product-innovation frontier is currently defined by two converging developments: the 2025 network-token regulatory framework under SB265, together with the newly formed Blockchain and Digital Innovation Task Force, and growing FedNow instant-payments adoption among the state's banks and credit unions. Together these represent the two active vectors of product-level change in the state's payments landscape - crypto/token market structure on one hand, instant account-to-account settlement rails on the other - with no other distinct state-level product-innovation initiative identified this cycle. #### Outlook The FedNow adoption trajectory and the SB265 Task Force's implementation work are the two threads most likely to generate product-relevant developments in the coming cycles. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T2 [https://dailymontanan.com/2025/04/03/legislators-propose-bills-to-back-data-centers-legislate-blockchain-technology/](https://dailymontanan.com/2025/04/03/legislators-propose-bills-to-back-data-centers-legislate-blockchain-technology/) retrieved 2026-07-05 2. T1 [https://www.frbservices.org/financial-services/fednow/about.html](https://www.frbservices.org/financial-services/fednow/about.html) retrieved 2026-07-05 3. T2 [https://www.kpax.com/news/montana-news/montana-moves-forward-on-regulatory-framework-for-blockchain-digital-assets](https://www.kpax.com/news/montana-news/montana-moves-forward-on-regulatory-framework-for-blockchain-digital-assets) retrieved 2026-07-05 4. T3 [https://www.montanasmarketplace.com/montana-living/crypto-in-montana](https://www.montanasmarketplace.com/montana-living/crypto-in-montana) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-05 Fastest-growing consumer-protection concern is crypto/ATM-enabled fraud against elderly residents; MT has a restitution fund and is drafting crypto-ATM legislation for 2027. Horizon · 2027-Q1 (±year) Montana crypto-ATM regulation expected at 2027 Legislature_proposed · TT3_ Horizon · 2027-Q1 (±year) Montana crypto-ATM regulation expected at 2027 Legislature_proposed · TT3_ Standing sub-brief · as of 5 July 2026 128 words · last cycle 2026-07-05 #### Consumer Protection & APP Fraud Crypto-ATM fraud has emerged as Montana's fastest-growing consumer-protection concern, with approximately $2 million in losses reported in 2025 alone. Montana is one of six US states with a legislature-authorized restitution fund for such losses, but crypto ATMs remain unregulated at both the state and federal level. State Representative Sprunger is drafting legislation for the 2027 Montana Legislature to close this gap, working alongside the Commissioner of Securities and Insurance. The fraud pattern disproportionately affects elderly Montana residents and overlaps with the State Auditor's broader crypto-fraud enforcement docket (W7). #### Outlook The 2027 legislative session is the single most concrete forward marker in this cycle's Montana baseline; the shape of any resulting crypto-ATM licensing regime would be a material change to Montana's currently unregulated-kiosk posture. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T2 [https://nbcmontana.com/news/local/montana-state-auditor-warns-of-uptick-in-crypto-atm-scams](https://nbcmontana.com/news/local/montana-state-auditor-warns-of-uptick-in-crypto-atm-scams) retrieved 2026-07-05 2. T2 [https://flatheadbeacon.com/2025/10/22/crypto-atm-fraud-on-the-rise-nationally-prompting-montana-regulatory-push/](https://flatheadbeacon.com/2025/10/22/crypto-atm-fraud-on-the-rise-nationally-prompting-montana-regulatory-push/) retrieved 2026-07-05 3. T2 [https://www.ktvq.com/news/local-news/montana-state-auditor-warns-of-rise-in-cryptocurrency-atm-scams](https://www.ktvq.com/news/local-news/montana-state-auditor-warns-of-rise-in-cryptocurrency-atm-scams) 4. T3 [https://www.agrusslawfirm.com/unfair-deceptive-or-abusive-acts-or-practices-udaap/montana/](https://www.agrusslawfirm.com/unfair-deceptive-or-abusive-acts-or-practices-udaap/montana/) retrieved 2026-07-05 5. T3 [https://stateline.org/2025/07/28/citing-potential-for-fraud-blue-and-red-states-pass-new-crypto-atm-laws/](https://stateline.org/2025/07/28/citing-potential-for-fraud-blue-and-red-states-pass-new-crypto-atm-laws/) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-montana/#sec-dom-D7) Probable confirmed 2026-07-05 Absence of a state MTL/AML overlay leaves federal FinCEN BSA/MSB registration as the sole compliance layer for money-transmission-adjacent activity in Montana. Standing sub-brief · as of 5 July 2026 131 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime This module is sourced from the Sentinel.gi feed. Per that feed, absent a Montana state MTL or AML licensing overlay, federal FinCEN Bank Secrecy Act and Money Services Business registration and program obligations remain the sole compliance layer for money-transmission-adjacent activity in the state; DBFI uses the FinCEN MSB definition as its own operative reference in the absence of a Montana statutory definition. WPM does not perform independent illicit-finance analysis of this finding; readers seeking AML/CFT typology or enforcement detail should consult the Sentinel.gi feed directly. #### Outlook No independent WPM outlook is offered for this module; changes to Montana's federal-only AML compliance layer would be expected to surface first through the Sentinel.gi feed and, if material to market access, would be reflected in a future W1a/W11 update. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T3 sentinel.faisalkhan.com/solutions/licensing/money-transmitter-license-mtl/money-transmitter-license-in-the-state-of-montana-the-abridged-version/ 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Montana — Montana's AML/CTF framework is almost entirely federally-mediated via the Bank Secrecy Act, FinCEN registration, and OFAC sanctions screening. State-level oversight runs through the Montana Division of Banking & Financial Institutions (MSB/bank licensing) and the Commissioner of Securities and Insurance (securities/crypto-fraud enforcement). Montana has no state beneficial-ownership registry, and the March 2025 federal CTA rollback removed the sole remaining BOI backstop for domestically-formed LLCs. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: capacity-deficit 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: political-constraint 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-05 Correspondent-banking/settlement access runs through Fed Minneapolis Helena Branch and FedNow, against documented rural/tribal credit-access constraints flagged by the Federal Reserve. Standing sub-brief · as of 5 July 2026 138 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access Correspondent-banking and settlement access for Montana financial institutions runs through the Federal Reserve Bank of Minneapolis's Helena Branch and the FedNow rail, against a backdrop of documented rural and tribal credit-access constraints. Federal Reserve leadership, including in a Governor Barr speech, has flagged persistent access gaps affecting institutions and communities connected to the Flathead and Blackfeet reservations, framing this as a structural feature of the state's access landscape rather than an isolated incident. This access asymmetry - full correspondent and settlement access for mainstream bank-PSP institutions against constrained access in rural and tribal contexts - is the analytical spine of Montana's correspondent-banking picture. #### Outlook The rural/tribal access gap is a structural, persistent feature rather than an actively resolving one; watch for any Federal Reserve community-development or access-focused initiative specifically targeting Montana's tribal-adjacent institutions. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.minneapolisfed.org/about-us/our-helena-branch](https://www.minneapolisfed.org/about-us/our-helena-branch) retrieved 2026-07-05 2. T1 [https://www.federalreserve.gov/newsevents/speech/barr20260414a.htm](https://www.federalreserve.gov/newsevents/speech/barr20260414a.htm) retrieved 2026-07-05 3. T1 [https://www.federalreserve.gov/newsevents/speech/bowman20250227a.htm](https://www.federalreserve.gov/newsevents/speech/bowman20250227a.htm) retrieved 2026-07-05 4. T2 [https://mibonline.org/privacy-resolutions/](https://mibonline.org/privacy-resolutions/) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-05 Dominant trailing-12-month commercial event is Frontier Credit Union's acquisition of First Citizens Bank of Butte (closed 2026-02-01), the first whole-bank credit-union acquisition in Montana; deal value undisclosed. Standing sub-brief · as of 5 July 2026 131 words · last cycle 2026-07-05 #### Commercial Intelligence (M&A, Investment & Product) Frontier Credit Union, based in Idaho Falls, completed its acquisition of First Citizens Bank of Butte on 1 February 2026 - its first expansion into Montana and the first full acquisition of a bank by a credit union in the state's history. The deal added $75 million in assets and one branch to Frontier's footprint, bringing its combined locations to 16; deal value was not publicly disclosed by either party. The transaction is a discrete commercial event distinct from the broader structural consolidation trend tracked at W6, and signals continued cross-charter-type consolidation pressure on Montana's population of 33 state-chartered banks. #### Outlook This precedent-setting transaction may encourage further credit-union-acquires-bank activity in Montana and neighboring states; no additional Montana commercial events were identified in this cycle's research. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [https://www.bankingdive.com/news/idaho-frontier-credit-union-buy-montana-first-citizens-bank-butte-icba/747027/](https://www.bankingdive.com/news/idaho-frontier-credit-union-buy-montana-first-citizens-bank-butte-icba/747027/) retrieved 2026-07-05 2. T3 [https://frontiercreditunion.com/blog/its-official-were-in-butte/](https://frontiercreditunion.com/blog/its-official-were-in-butte/) 3. T1 [https://www.sec.gov/Archives/edgar/data/0001478454/000117184326000431/exh_991.htm](https://www.sec.gov/Archives/edgar/data/0001478454/000117184326000431/exh_991.htm) retrieved 2026-07-05 ** 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 – Montana| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `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"}}}`. **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:** 1 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), 64 finding(s), 131 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).