title: United States – Vermont Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-vermont/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Vermont US-VT schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 59 sourced findings · 134 sources in the cumulative register 14 Modules baseline.modules[] 59 Findings modules[].findings[] 73 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 – Vermont is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Vermont’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 4 October 2026 #### Lead Signal Vermont enacted Act 142 in 2026, a licensing-perimeter development that touches both the virtual-currency segment and a previously unlicensed commercial-finance segment of the states payments and lending landscape. On the licensing and market-access side, Act 142 imposes a permanent statewide ban on virtual-currency kiosks, terminating all existing kiosk registrations effective July 1, 2026, and expands the statutory definition of money transmission under 8 V.S.A. chapter 79 to expressly include virtual-currency business activity. This is a tightening move at the market-access gate: a channel-type is removed entirely, and the licensing perimeter for virtual-currency business models is widened to close definitional ambiguity about whether exchange, transmission, or custodial-wallet services require a Vermont money-transmitter license. The same legislative act also creates a wholly new licensing track outside the money-transmission space: a lender license for funders and a loan-solicitation license for brokers, covering sales-based financing and factoring, effective July 1, 2027, with exemptions for depository institutions and transactions of one million dollars or more. This is a product-innovation and market-development item distinct from the virtual-currency provisions, extending a licensing perimeter to commercial-finance products that have not generally been treated as licensed lending to date. #### Other Developments **The kiosk ban closes a specific market-access channel rather than imposing a general restriction on virtual-currency activity.** Act 142 prohibits the location, operation, or availability of a virtual-currency kiosk anywhere in Vermont and terminates every existing kiosk registration as of the July 1, 2026 effective date. The prohibition is targeted at the kiosk channel specifically, leaving other licensed virtual-currency business models intact, which is a narrower market-access outcome than a blanket restriction on virtual-currency activity in the state would have produced. **The expanded money-transmission definition resolves a licensing-scope question for virtual-currency business models.** By expressly folding virtual-currency business activity into chapter 79s definition of money transmission, the act removes ambiguity about whether exchanges, transmission services, and similar models require Vermont money-transmitter licensure. This is the kind of definitional clarification that materially affects market access: firms that may have operated on the view that their activity sat outside the traditional money-transmission definition no longer have that position available. **The new commercial-financing licensing regime is a distinct product-innovation development with its own effective date and exemption structure.** The lender and loan-solicitation licenses created by Act 142 apply to sales-based financing and factoring providers from July 1, 2027, with depository institutions and transactions at or above one million dollars exempted from the new requirement. This extends licensing to a segment of commercial finance, merchant cash advance and factoring style products, that has not generally been treated as licensed lending, which has implications for how such products are structured and disclosed to Vermont-based commercial borrowers going forward. #### Cross-Monitor Connections The virtual-currency provisions of Act 142 intersect directly with first-party research produced by the Crypto monitor on this same jurisdiction, where the kiosk ban and the money-transmission definitional expansion are analysed from the digital-asset licensing perspective; this brief does not re-analyse that material. Similarly, the underlying fraud-and-scam-proceeds rationale documented by the Vermont Department of Financial Regulation that underpins the kiosk ban is a financial-crime finding more fully developed on the Financial Integrity monitor; illicit-finance use of the kiosk channel is a cross-monitor reference point here, not a conclusion this brief draws independently. #### Outlook The principal item to track on the licensing and market-access side is whether the Department of Financial Regulation issues implementing guidance applying the expanded money-transmission definition specifically to custodial-wallet or exchange business models; none had been located as of this cycle. On the commercial-financing side, the run-up to the July 1, 2027 effective date for the new lender and loan-solicitation licenses is the item to watch, given that industry participants have not generally treated sales-based financing and factoring products as licensed lending to date, creating a compliance gap ahead of that date that providers serving Vermont recipients will need to close. _5 earlier updates 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 Vermont's virtual-currency kiosk regime is this cycle's most consequential open item. Under 8 V.S.A. §2577, the moratorium on new virtual-currency kiosk operations was set to run only until July 1, 2026, having already been extended twice during 2025, with an exemption preserved for kiosks licensed or operational before June 30, 2024. A Senate proposal of amendment filed May 11, 2026 seeks to extend that moratorium a further year, to July 1, 2027, but as of this cycle it remains pending and unenacted. Because this research cycle's retrieval date of July 5, 2026 falls after the moratorium's stated expiry, whether the bar on new kiosk operators has lapsed or been further extended was not resolved this cycle and is flagged for confirmation next cycle. The kiosk statute also mandates a live screening call for any new customer over 60 before their first transaction, or for anyone attempting more than $5,000 in transactions over ten days. A 2025 addition separately requires kiosk operators to refund fraud victims who report within 90 days. #### Other Developments Vermont's licensing architecture remains a mature dual bank-charter/non-bank framework. The Department of Financial Regulation administers a single non-bank Money Transmitter License under 8 V.S.A. Chapter 79, processed through NMLS and covering money transmission, check cashing and currency exchange, authorized delegates, and, since Act 110 of 2024, virtual-currency business activity. Act 110 conformed Vermont's statute to the CSBS Model Money Transmission Modernization Act, while creating a bespoke virtual-currency business activity subchapter distinct from the model law. Licensed transmitters have held customer funds in a statutory trust over permissible investments since July 1, 2024, with trust assets shielded from attachment except by beneficiaries. On scheme and network compliance, Vermont permits merchants to set a disclosed minimum card-transaction amount of up to $10.00 and to offer cash or alternative-payment discounts, with card networks barred from restricting acceptance to only some merchant locations. A pending bill, S.316, would prohibit card networks from charging interchange on the portion of a transaction representing state or local sales, use, or excise tax or gratuity; it was read a first time and referred to committee on January 27, 2026 and remains unenacted. A predecessor bill, H.0317 of 2025, died in committee without advancing. On enforcement, the DFR's operative model is administrative stipulation-and-consent orders rather than contested litigation: Uphold HQ was penalized $6,500 in February 2019 for operating as an unlicensed money transmitter in Vermont since 2014, without admitting the violation. CSG Forte Payments was separately penalized $22,650 for unlicensed transmission dating to 2001, with its license deemed effective on execution and payment of the penalty. On settlement access, Vermont-chartered banks and credit unions reach the payment system through a Federal Reserve Master Account or, for smaller institutions, a pass-through correspondent arrangement. A December 2025 Federal Reserve request for information proposes a special-purpose Payment Account prototype tailored to payments-focused institutions, which would not permit acting as a correspondent for respondents; the proposal remains at the RFI stage. #### Cross-Monitor Connections Vermont's MTL regime requires applicants to register with FinCEN under the Bank Secrecy Act as a licensing precondition. Separately, 8 V.S.A. §2534 requires money-laundering reports alongside report-of-condition and audited-financials obligations for licensed transmitters. These items are carried here strictly as payments-context markers; underlying illicit-finance and de-risking analysis is routed to the Sentinel-fed FIM monitor rather than developed within this brief. The only commercial-intelligence item touching Vermont's market this cycle is national rather than state-specific: Capital One agreed in January 2026 to acquire Brex for $5.15 billion in cash and stock, expected to close mid-2026, noted here as bank-fintech consolidation context rather than a Vermont-headquartered event. #### Outlook Confirmation of the kiosk moratorium's post-July-2026 status, and the progress of S.316's proposed interchange restriction, are the two most immediate items on Vermont's regulatory calendar. The Federal Reserve's Payment Account prototype RFI is a slower-moving but structurally significant item to watch given its potential to open a new settlement-access route for payments-focused institutions. Vermont-specific corridor-volume data, correspondent-banking or de-risking events, and Vermont-headquartered commercial transactions were all absent from this cycle's findings and are priorities for future research. trust tier: ai_unverified ###### Latest update · 28 September 2026 #### Regulatory Status Vermont's nonbank money-services regulatory perimeter has tightened materially this cycle via Act 142, enacted 16 June 2026. The act permanently bans locating, operating, or otherwise making available a virtual-currency kiosk anywhere in the state, effective 1 July 2026, superseding a prior time-limited moratorium under 8 V.S.A. Section 2577(f). This closure follows a Department of Financial Regulation finding of a reduction of more than 94 percent in the number of cash-accepting virtual-currency kiosks operating in Vermont under the interim moratorium, and it removes an entire category of nonbank cash-to-crypto access point from the state market. The same instrument also establishes a new licensing and disclosure regime for commercial-financing providers under Title 8, effective 1 July 2027. This extends Vermont's state licensing perimeter to a category of nonbank commercial-financing provider not previously subject to dedicated state licensure, on a timeline one year behind the kiosk provisions. #### Outlook The commercial-financing licensing regime, adopted under Act 142, is scheduled to take effect 1 July 2027. No implementing guidance from the Vermont Department of Financial Regulation specifying application procedures or licensing thresholds for commercial-financing providers has been identified in the evidence available this cycle; this is the primary item to monitor ahead of the effective date. _2 earlier updates 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 Vermont's payments regulatory profile, established this cycle as a new baseline, sits at a MODERATE risk level with a stable-to-tightening trajectory, driven by conduct and safeguarding tightening set against continued administrative enforcement against unlicensed transmission. Licensing and market access rest on a mature dual bank-charter/non-bank Money Transmitter License architecture, most recently modernized by Act 110 (2024), which conformed the regime to the CSBS Model Money Transmission Modernization Act while preserving Vermont-specific virtual-currency provisions built on several years of prior regulatory experience. Conduct and safeguarding have strengthened materially since 2024, via the statutory trust over permissible investments and a 2025 kiosk fraud-refund mandate. The state's most dynamic policy front is its virtual-currency kiosk regime, amended at creation in 2024 and twice more in 2025, with a further one-year extension of the operating moratorium to July 2027 under active Senate consideration via H.648 as of this cycle. Enforcement follows an administrative, non-litigious posture: DFR resolves unlicensed-transmission cases through stipulation-and-consent orders with penalties calculated on relatively modest terms rather than pursuing contested litigation. On scheme economics, a legislative push to restrict card-network interchange fees on sales tax and gratuity, via S.316, following a failed 2025 predecessor, H.0317, signals growing legislative appetite to regulate interchange directly, though nothing has been enacted to date. No Vermont-specific merchant-acquiring, payment-corridor, or correspondent-banking regime exists distinct from the national card-network and Federal Reserve architecture; Vermont-licensed PSPs and banks operate within that national architecture without an additional state-level layer, and no Vermont-specific corridor or correspondent-banking event was identified this cycle. #### Outlook Two items on Vermont's regulatory horizon warrant close tracking: confirmation of the virtual-currency kiosk moratorium's status after its stated July 1, 2026 expiry against the pending H.648 extension to 2027, and the progress of S.316's proposed interchange restriction. Research gaps remain around Vermont-specific corridor flow data, correspondent-banking or de-risking events, and Vermont-headquartered commercial transactions, each flagged for prioritization in the next research cycle. 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 Vermont regulates money transmission (including virtual-currency exchange and custody) under the Vermont Money Transmitter Act, 8 V.S.A. chapter 79. Act 142 of 2026 (effective July 1, 2026) expanded the statutory definition of 'money transmission' to expressly include virtual-currency business activity and permanently banned virtual-currency kiosks, terminating existing kiosk registrations. Standing sub-brief · as of 5 July 2026 306 words · last cycle 2026-10-04 #### Licensing, Authorisation & Market Access Vermont's payments licensing architecture rests on a single non-bank Money Transmitter License administered by the Department of Financial Regulation under 8 V.S.A. Chapter 79, processed via NMLS and covering money transmission, check cashing and currency exchange, authorized delegates, and, since Act 110 of 2024, virtual-currency business activity. This preserves Vermont's baseline dual-track market-access model: bank-chartered payment service providers operate under separate state or federal bank charters, while non-bank providers must hold the MTL to transact in the state. Act 110, enacted in 2024, was the most significant recent legislative event in this module. Its Sections 29 through 49 conformed Vermont's money-transmission statute to the Conference of State Bank Supervisors' Model Money Transmission Modernization Act, while Section 48 created a new Chapter 79 subchapter setting bespoke virtual-currency business activity requirements distinct from the model law itself. This dual move — harmonizing with the multistate model law on one hand while retaining Vermont-specific virtual-currency provisions on the other — reflects a state that has been regulating virtual-currency business activity for several years and was not starting from a blank slate. On the compliance-cost side of licensing, a licensing-guide source indicates that Vermont MTL applicants must maintain a minimum tangible net worth of $100,000, post a surety bond of the same minimum amount, register with FinCEN under the Bank Secrecy Act, and expect a licensing process of approximately three months. This figure comes from a single secondary licensing-guide source rather than a primary statutory citation checked this cycle, and should be treated as indicative rather than confirmed pending direct statutory cross-check. #### Outlook With Act 110's CSBS-model conformance now in force, Vermont's licensing architecture is unlikely to see further structural change in the near term; the module's live edges are downstream in the virtual-currency subchapter it created rather than in the core MTL framework itself. Periodic update · new data 2026-10-04 #### Licensing, Authorisation & Market Access Vermonts market-access perimeter for virtual-currency activity changed materially with the enactment of Act 142 in 2026. Two distinct mechanisms are at work. First, the act imposes a permanent, statewide ban on virtual-currency kiosks: no person may locate, operate, or make available a virtual-currency kiosk anywhere in Vermont, and every existing kiosk registration was terminated effective July 1, 2026. This is a market-access closure in the strict sense, a channel-type that was previously a licensed or registered activity is now categorically unavailable, with no transition path or grandfathering provision identified in the available evidence. Second, and separately, Act 142 expands the statutory definition of money transmission under 8 V.S.A. chapter 79 to expressly include virtual-currency business activity. This is a definitional expansion of the licensing gate itself rather than a closure: it does not prohibit virtual-currency exchange, transmission, or custodial-wallet activity, but it does resolve any question about whether such activity requires a Vermont money-transmitter license. Firms operating virtual-currency business models that touch Vermont consumers or counterparties, and that may previously have taken the position that their activity fell outside the traditional scope of money transmission, no longer have that position available following this definitional change. The practical market-access consequence of the two changes together is a narrowing of the channels through which virtual-currency activity can lawfully reach Vermont consumers, combined with a widening of the licensing obligations attached to the channels that remain. A firm seeking to serve the Vermont market in virtual-currency exchange, transmission, or custodial-wallet services needs to hold money-transmitter licensure covering virtual-currency business activity specifically, while a firm that might have previously relied on kiosk deployment as a market-entry or distribution channel no longer has that option available in Vermont under any licensing structure, since the prohibition is a categorical ban rather than a licensing condition. The nonbank dimension is the more relevant frame here rather than a bank-versus-nonbank split: both the kiosk ban and the money-transmission definitional expansion bear principally on nonbank virtual-currency business models, since depository institutions are not the typical operators of virtual-currency kiosks or the typical providers of the virtual-currency exchange and custodial-wallet services the definitional expansion targets. The licensing perimeter change is therefore best read as reshaping market access for the nonbank virtual-asset service provider segment specifically, rather than as altering the comparative position of banks and nonbanks relative to each other. A gap in the current evidence base is directly relevant to assessing the practical market-access impact of the definitional expansion: no Department of Financial Regulation implementing guidance interpreting the expanded money-transmission definition specifically as applied to custodial-wallet or exchange activity has been located as of this cycle. Firms seeking to determine the precise licensing, examination, and compliance-program expectations attached to the expanded definition therefore have the statutory text to work from but not yet a documented regulatory interpretation of how it will be applied in practice to particular business models. The kiosk-ban rationale also bears on the market-access analysis, even though the underlying fraud-and-scam-proceeds finding itself is a financial-crime matter outside this modules scope. The Department of Financial Regulations own report identifying kiosks as a vehicle for routing fraud proceeds is the documented policy basis for the prohibition, which means the market-access closure here was a targeted response to an identified risk in a specific channel rather than a generalized restriction on virtual-currency market access in Vermont. Firms assessing their own Vermont market-access strategy should read the kiosk ban as channel-specific rather than as a signal of a broader restrictive posture toward virtual-currency business generally, given that the money-transmission definitional expansion simultaneously confirms a licensed pathway for other virtual-currency business models. #### Outlook The item most likely to affect market-access planning going forward is whether the Department of Financial Regulation issues implementing guidance on how the expanded money-transmission definition applies specifically to custodial-wallet and exchange business models; none has been located as of this cycle, leaving firms to work from the statutory text pending any such guidance. A second item to track is whether any licensing applications or supervisory actions involving virtual-currency business activity under the expanded definition become publicly visible following the July 1, 2026 effective date, which would provide the first practical indication of how actively the expanded perimeter is being applied and enforced. **5 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Vermont's Act 142, enacted 16 June 2026, permanently bans locating, operating, or otherwise making available a virtual-currency kiosk anywhere in the state, effective 1 July 2026. This supersedes the prior time-limited moratorium under 8 V.S.A. Section 2577(f) and closes off market access to this category of nonbank money-services activity entirely, rather than tightening the conditions under which a kiosk licence might be issued or maintained. For nonbank payment institutions and e-money-style operators considering physical cash-acceptance infrastructure in Vermont, the licensing pathway for kiosk-based virtual-currency conversion no longer exists as a matter of state law. The same instrument also creates a new licensing and disclosure regime specifically for commercial-financing providers, effective 1 July 2027, a full year after the kiosk provisions take hold. This is a separate market-access development within the same enacted act: nonbank commercial-financing providers operating in or serving Vermont will need to secure state licensure and meet new disclosure requirements from that date. Both provisions sit within Vermont's broader Chapter 79 money-services and financial-regulation framework, but they address distinct categories of nonbank provider — virtual-currency kiosk operators on one hand, and commercial-financing providers on the other — and should not be conflated as a single licensing change. The kiosk provision's effective date has already passed as of this cycle's evidence base; the change is in force, not prospective. The commercial-financing licensing regime, by contrast, remains a forward horizon item: it was adopted as part of Act 142 but does not take effect until 1 July 2027, and no implementing guidance from the Vermont Department of Financial Regulation specifying application procedures, disclosure content, or licensing thresholds for commercial-financing providers has been identified in the available evidence this cycle. For nonbank payment institutions and e-money issuers more broadly, the practical takeaway is a narrowing of Vermont's market-access landscape for cash-based virtual-currency conversion infrastructure, paired with an expansion of Vermont's licensing perimeter to capture a previously less-supervised category of commercial finance provider. Bank-affiliated payment channels are not directly implicated by either provision, which are targeted at nonbank money-services and commercial-financing activity specifically. #### Outlook The commercial-financing licensing regime is scheduled to take effect 1 July 2027, as adopted under Act 142. Whether the Vermont Department of Financial Regulation will publish implementing rules, application forms, or licensing-fee schedules ahead of that date is not established in the evidence available this cycle, and should be monitored as the effective date approaches. Periodic update · new data 2026-09-22 #### Licensing, Authorisation & Market Access Vermont's payments licensing framework tightened this cycle on two distinct fronts under Act 142 (H.648), signed 16 June 2026. First, the moratorium on new virtual-currency kiosks operating in Vermont was extended from its previous 1 July 2026 expiry to 1 July 2027, the third consecutive annual amendment to 8 V.S.A. Chapter 79 following prior tightening in 2024 and 2025. This extends the closed door to new kiosk-based market entrants by a further year, while leaving the underlying money-transmission licensing requirement for existing virtual-currency businesses unchanged. Second, and structurally more significant for market access generally, Act 142 creates an entirely new licensing and disclosure regime for commercial-financing providers and brokers, specifically covering sales-based-financing and factoring transactions. This regime takes effect 1 July 2027 and requires covered providers and brokers to obtain Department of Financial Regulation licensure and to provide standardized disclosures — a market-access requirement that did not previously exist for this class of commercial-financing activity in Vermont. This is a nonbank-payment-institution-relevant development: the new regime reaches commercial-financing providers and brokers as a category distinct from the bank-versus-nonbank money-transmission distinction that governs virtual-currency and traditional payment-institution licensing under Chapter 79. Separately, and unchanged this cycle, Vermont's money-transmitter licensing fee schedule continues to require a $2,100 total fee alongside a minimum surety bond of $100,000, scaling to $500,000, with the Commissioner retaining discretion to require bonding up to $2,000,000. This standing cost structure applies uniformly to money-transmission licensees regardless of whether they operate as bank-affiliated or nonbank payment institutions or e-money issuers. #### Outlook Both the kiosk-moratorium expiry and the new commercial-financing licensing regime's effective date fall on 1 July 2027, making that date the key structural milestone for Vermont's payments-licensing perimeter. Given the three-consecutive-year extension pattern for the kiosk moratorium, a further extension in the 2027 session is a plausible but unconfirmed trajectory. Whether DFR issues implementing rules for the new commercial-financing regime ahead of its effective date remains an open item. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access Vermont's Act 142 (H.648), signed June 16, 2026, extends the moratorium on new virtual-currency-kiosk operations under 8 V.S.A. Section 2577(f) from July 1, 2026 to July 1, 2027. Kiosks operational on or before June 30, 2024 are grandfathered and may continue operating; the restriction applies only to new deployment. This is the third consecutive annual amendment to Chapter 79's virtual-currency provisions, following prior amendments in 2024 and 2025, and represents a sustained tightening of market access specific to the kiosk channel. Outside the kiosk-specific restriction, Vermont's general money-transmitter licensing regime remains structurally stable and CSBS Model Act-aligned. A money transmitter licence costs two thousand one hundred dollars in total fees (one thousand dollars licensing, one thousand dollars investigation, one hundred dollars NMLS processing), requires a surety bond starting at one hundred thousand dollars and scaling to a Commissioner-set cap of two million dollars, and requires tangible net worth of the greater of one hundred thousand dollars or three percent of the first one hundred million dollars in total assets. Act 110 of 2024 rebuilt this framework onto the CSBS Model Act and codified virtual currency as a permissible investment only to the extent it matches outstanding transmission obligations in identical denomination — a reserve-matching mechanic rather than a dedicated stablecoin regime. No separate crypto-specific licence class exists; virtual-currency businesses, including exchanges and custodians, operate under the same general money transmitter licence as other payment companies. #### Outlook The kiosk moratorium is due to expire July 1, 2027 absent further legislative extension. Given three consecutive years of annual extension, continued tightening into the 2027 legislative session is plausible, though not certain from the statute itself. This is the principal near-term item determining whether new kiosk-channel market access becomes available in Vermont for the first time since the restriction was imposed. Periodic update · new data 2026-08-25 #### Licensing, Authorisation & Market Access Vermont Act 142, an omnibus statute signed by Governor Scott on June 16, 2026, makes three distinct changes to the state's payments and money-transmission licensing perimeter. First, it imposes a permanent, statewide prohibition on virtual-currency kiosks; kiosk operators' existing registrations expire and terminate on July 1, 2026, closing what had been a licensed or registered activity outright rather than tightening its conditions. Second, it creates an entirely new commercial-financing-provider licensing and disclosure regime, which becomes operative on July 1, 2027, a substantially longer runway than the kiosk and money-transmission provisions already in force. Third, it amends the money-transmitter licence application provisions, the check-casher and currency-exchange activity provisions, and the virtual-currency conditions-precedent provisions of Title 8, Chapter 79, formalising that control of virtual currency, including control exercised through a private key, is dispositive of money-transmission activity. Each of these three changes is High confidence and rests on the enacted statutory text itself, a Tier 1 primary source. Read together, they describe a licensing perimeter that is tightening unevenly: the kiosk channel faces an immediate and permanent bar with no cure path, the money-transmission definition is broadened to capture private-key custodial control that might otherwise have sat in a definitional gray area, and an entirely new nonbank licence class is introduced on a delayed, multi-year timeline. All three changes affect nonbank market participants specifically; none of the claims here bears on bank-chartered payment activity, which is licensed and supervised through a separate federal and state banking framework untouched by Act 142. For market-access purposes, the practical effect is a net narrowing for cash-to-crypto conversion operators and a net broadening of scope for virtual-currency custodians whose arrangements rely on private-key control without falling within a traditional money-transmission structure. The commercial-financing-provider licence class introduces an entirely new category of regulated activity into Vermont's nonbank licensing perimeter, with the eighteen-month gap before its 2027 commencement leaving providers in that sector without a dedicated state licensing or disclosure obligation in the interim. #### Outlook The principal item to track is the eighteen-month gap between the July 2026 kiosk-ban and money-transmission-scope changes and the July 2027 commercial-financing-provider licensing commencement, including whether the Department of Financial Regulation issues interim guidance for commercial financing providers ahead of the statutory effective date. A second item is whether the Department publishes interpretive guidance narrowing or clarifying the newly formalised private-key control test as it might apply to staking, custodial, or other emerging virtual-currency arrangements not contemplated by the kiosk-focused drafting record. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Vermont enacted Act 142 on June 16, 2026, an omnibus payments and financial-services law that takes effect July 1, 2026, with one component, the commercial-financing licensing and disclosure regime, deferred to July 1, 2027. Three of the law's provisions amend the state's existing money transmitter licence statute directly, and a fourth creates an entirely new non-bank licensing category. All four provisions apply to non-bank money-services businesses; Vermont's money transmitter licence is, and remains, a non-bank authorisation distinct from any bank-chartered payments activity, and Act 142 does not alter that boundary. The first amendment, to 8 V.S.A. Section 2107, changes the state's change-of-control review process. Persons or groups acting in concert who seek to acquire control of a licensed money transmitter must now submit a request to the Commissioner in advance of the transaction. This formalises a pre-transaction review gate over ownership changes at Vermont-licensed non-bank payments entities, giving the state visibility into, and a checkpoint over, acquisitions and control changes affecting the licensed population. The second amendment, to 8 V.S.A. Section 2110, updates the Commissioner's authority to suspend, revoke, or issue cease-and-desist orders against money transmitter licensees. Read alongside the change-of-control amendment, this pairs a stronger entry-side control, who may acquire a licensee, with a stronger exit-side control, how the state can act against one, a combination consistent with the broader pattern of states adopting elements of the Conference of State Bank Supervisors' Model Money Transmission Modernization Act to standardise and strengthen non-bank payments supervision. Third, a new automatic-expiration rule provides that a licence lapses on December 31 if the annual renewal fee has not been paid by December 1. This converts licence renewal from what may have been a more forgiving administrative process into a hard annual deadline with an automatic, not discretionary, consequence for non-payment, adding a compliance-calendar item for every Vermont money transmitter licensee. Fourth, and structurally distinct from the money-transmission amendments, Act 142 creates a new licensing and disclosure regime for commercial financing providers, a category of non-bank finance that did not previously require state authorisation in Vermont. This new regime becomes effective July 1, 2027, a year after the rest of the Act, giving affected firms a defined runway to prepare for licensing. Taken as a whole, the four provisions move in the same direction: tighter entry-side and exit-side controls over the existing non-bank licensee population, plus an entirely new category of non-bank finance brought inside Vermont's licensing perimeter for the first time. #### Outlook The commercial-financing licensing and disclosure regime is the next dated event on Vermont's non-bank market-access calendar: it becomes effective July 1, 2027, and firms currently operating without Vermont authorisation in that category should expect to need one from that date. In the nearer term, the change-of-control and enforcement-authority amendments are already in force, meaning any pending or contemplated ownership change at a Vermont-licensed money transmitter is now subject to the Commissioner's advance-review requirement, and any licensee facing a compliance issue is now subject to an updated suspension, revocation, or cease-and-desist framework. Vermont's move fits a broader pattern of states adopting stronger non-bank supervisory tools, and the next material development to watch is any implementing guidance the Department of Financial Regulation issues ahead of the 2027 commercial-financing effective date, as well as whether change-of-control filings under the new Section 2107 process begin appearing in licensee-population data. **Sources and findings (5)** 1. T1 [https://legislature.vermont.gov/statutes/chapter/08/079](https://legislature.vermont.gov/statutes/chapter/08/079) retrieved 2026-07-05 2. T1 [https://dfr.vermont.gov/industry/banking/financial-services/money-services](https://dfr.vermont.gov/industry/banking/financial-services/money-services) retrieved 2026-07-05 3. T1 [https://legislature.vermont.gov/Documents/2024/Docs/ACTS/ACT110/ACT110%20Act%20Summary.pdf](https://legislature.vermont.gov/Documents/2024/Docs/ACTS/ACT110/ACT110%20Act%20Summary.pdf) retrieved 2026-07-05 4. T3 [https://faisalkhan.com/solutions/licensing/money-transmitter-license-mtl/vermont-money-transmitter-license/](https://faisalkhan.com/solutions/licensing/money-transmitter-license-mtl/vermont-money-transmitter-license/) retrieved 2026-07-05 5. T1 [https://dfr.vermont.gov/industry/banking/financial-institutions](https://dfr.vermont.gov/industry/banking/financial-institutions) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Vermont safeguards customer funds via statutory trust over permissible investments (eff. July 2024), mandatory surety bond, and prudential net-worth standards, plus new 2025 kiosk fraud-refund obligations. Standing sub-brief · as of 5 July 2026 232 words · last cycle 2026-09-21 #### Conduct, Safeguarding & Financial Promotions Vermont-licensed money transmitters have safeguarded customer funds through a statutory trust since July 1, 2024, when Act 110 §44 took effect. The trust holds permissible investments for the benefit of money-transmission-obligation holders, and trust assets are shielded from attachment by creditors except by the trust's own beneficiaries. This statutory-trust model sits alongside a surety-bond requirement that scales with a licensee's footprint: a base bond of $100,000 plus $10,000 for each additional authorized delegate location, capped by statute at $500,000, though the Commissioner retains discretion to require a bond as high as $2,000,000 under 8 V.S.A. §2507. This bond-scaling detail is drawn from a secondary licensing-guide source summarizing the statute rather than from the primary statutory text itself this cycle. The conduct layer was extended in 2025 with a new consumer-protection obligation specific to virtual-currency kiosks: operators must now refund fraud victims who report the crime within 90 days, layered onto the existing kiosk licensing and conduct regime. Taken together, the statutory trust, the scaling bond requirement, and the new kiosk fraud-refund duty represent a conduct/safeguarding layer that has strengthened materially since 2024 rather than remaining static. #### Outlook Having added a kiosk-specific consumer remedy in 2025 on top of the 2024 trust reform, Vermont's safeguarding regime appears likely to continue evolving incrementally around the virtual-currency kiosk channel specifically, rather than through broad revision of the core trust/bond framework. Periodic update · new data 2026-09-22 #### Conduct, Safeguarding & Financial Promotions Act 142 (H.648) broadens the scope of Vermont's customer-financial-record confidentiality provisions this cycle, extending coverage from "financial institutions" specifically to "regulated entities" generally. This is a conduct-and-safeguarding-side expansion rather than a licensing change: it widens the population of firms bound by confidentiality duties over customer financial records beyond the traditional banking and money-transmission core to whatever broader set of entities now falls within the state's definition of a regulated entity. The practical effect is to extend a safeguarding obligation that previously applied narrowly to a wider set of payment and financial-services firms operating in Vermont, without necessarily changing what conduct is prohibited — only who is bound by the confidentiality duty. This development sits alongside, but is analytically distinct from, the licensing-side changes made by the same act (the kiosk-moratorium extension and the new commercial-financing licensing regime): the confidentiality-scope broadening is a conduct obligation applicable to the wider regulated-entity population, whereas the licensing changes govern market entry and authorisation specifically. Both bank and nonbank payment institutions operating in Vermont fall within the broadened confidentiality scope, as the provision applies across the bank/nonbank distinction rather than singling out one category. #### Outlook The practical reach of the broadened "regulated entities" confidentiality scope — specifically which entity types beyond traditional financial institutions now fall within it — is worth tracking as Vermont's Department of Financial Regulation clarifies implementation; no implementing guidance beyond the statutory text was located this cycle. **1 earlier distinct update(s)** Periodic update · new data 2026-08-25 #### Conduct, Safeguarding & Financial Promotions Act 142 is understood to broaden Vermont's financial-privacy protections to cover non-bank regulated entities, extending beyond a protection previously limited to depository institutions. This reading rests on a single Tier 4 commentary source without independent Tier 1 through Tier 3 corroboration, and is treated as Assessed rather than High confidence accordingly. #### Outlook Independent corroboration of the financial-privacy-extension reading against Vermont's primary statutory text is the item to track before this finding is upgraded in confidence. **Sources and findings (5)** 1. T1 [https://legislature.vermont.gov/statutes/fullchapter/08/079](https://legislature.vermont.gov/statutes/fullchapter/08/079) retrieved 2026-07-05 2. T3 [https://www.bondexchange.com/vermont-money-transmitter-bond-a-comprehensive-guide/](https://www.bondexchange.com/vermont-money-transmitter-bond-a-comprehensive-guide/) retrieved 2026-07-05 3. T3 [https://states.aarp.org/vermont/new-guardrails-on-crypto-atm-fraud](https://states.aarp.org/vermont/new-guardrails-on-crypto-atm-fraud) retrieved 2026-07-05 4. T3 [https://moneywiki.app/regulators/department-of-financial-regulation](https://moneywiki.app/regulators/department-of-financial-regulation) retrieved 2026-07-05 5. T1 [https://ago.vermont.gov/attorney-generals-office-divisions-and-unit/consumer-protection](https://ago.vermont.gov/attorney-generals-office-divisions-and-unit/consumer-protection) retrieved 2026-07-05 ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-05 Vermont regulates virtual currency as money transmission under Chapter 79 Subchapter 10, with a distinct, actively-evolving kiosk regime under §2577 including a moratorium extended to July 1, 2026. Horizon · 2026-07-01 (±quarter) Virtual-currency kiosk moratorium expiry (8 V.S.A. §2577)_in_force · TT1_ Horizon · 2027-07-01 (±year) H.648 proposed extension of VT kiosk moratorium to July 1, 2027_proposed · TT1_ Standing sub-brief · as of 5 July 2026 228 words · last cycle 2026-07-05 #### Stablecoins & Digital Money Vermont regulates virtual currency as a form of money-transmission activity rather than through a dedicated stablecoin framework. Virtual-currency business activity is governed by 8 V.S.A. Chapter 79 Subchapter 10, added by Act 110 in 2024, and no separate stablecoin-issuer authorisation regime exists in the state. The most active element of this module is the virtual-currency kiosk moratorium under 8 V.S.A. §2577, which bars the operation of new kiosks until July 1, 2026 — a deadline itself twice extended during 2025 — while exempting kiosks that were already licensed or operational before June 30, 2024. Because the moratorium's stated end date falls before this cycle's July 5, 2026 retrieval date, whether the bar on new kiosk entrants has lapsed or been further extended was not resolved by primary research this cycle and is carried forward as an open item. That open item is itself the subject of pending legislation: a Senate proposal of amendment to H.648, dated May 11, 2026, would extend the moratorium under §2577(f) by a further year, to July 1, 2027. As of this cycle the proposal remains pending and has not been enacted. #### Outlook Confirmation of the kiosk moratorium's post-July-2026 status — lapsed, or extended to 2027 via H.648 — is the single highest-priority item for next cycle's Vermont research, given the direct operational consequence for any prospective new kiosk operator. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://law.justia.com/codes/vermont/title-8/chapter-79/section-2503/](https://law.justia.com/codes/vermont/title-8/chapter-79/section-2503/) retrieved 2026-07-05 2. T1 [https://legislature.vermont.gov/statutes/section/08/079/02577](https://legislature.vermont.gov/statutes/section/08/079/02577) retrieved 2026-07-05 3. T3 [https://www.billtrack50.com/billdetail/1873698](https://www.billtrack50.com/billdetail/1873698) retrieved 2026-07-05 4. T1 [https://legislature.vermont.gov/assets/Legislative-Reports/Virtual-Currency-Kiosk-Report-Pursuant-to-8-V.S.A.-2577g.pdf](https://legislature.vermont.gov/assets/Legislative-Reports/Virtual-Currency-Kiosk-Report-Pursuant-to-8-V.S.A.-2577g.pdf) retrieved 2026-07-05 5. T3 [https://www.fintechlawblog.com/2024/08/14/vermont-enters-a-new-age-of-virtual-currency-money-transmission/](https://www.fintechlawblog.com/2024/08/14/vermont-enters-a-new-age-of-virtual-currency-money-transmission/) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Confirmed confirmed 2026-07-05 Vermont's operational-resilience layer is anchored in the Security Breach Notice Act (9 V.S.A. §§2430, 2435), dual-track DFR/AG notification, most recently amended by Act 89 (2020). 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 145 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Vermont's operational-resilience framework for payments is anchored in its data-breach notification regime rather than a dedicated operational-resilience statute. DFR-regulated entities must notify the Department within 14 business days of knowing, or reasonably believing, that even a single Vermont resident was impacted by a security breach, with consumer notice required within 45 days under 9 V.S.A. §§2430, 2435. This framework was substantially amended by Act 89 in 2020, which expanded the definition of personally identifiable information to capture government ID numbers and biometric, genetic, and health data, created a distinct notification process specific to login-credential breaches, and revised the cost threshold for substitute notice to $10,000. #### Outlook No Vermont-specific DORA-equivalent operational-resilience regime was identified this cycle; the Security Breach Notice Act framework, as amended by Act 89, remains the operative standard and no further legislative activity in this module was found. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://dfr.vermont.gov/about-us/legal-general-counsel/data-breach-notifications](https://dfr.vermont.gov/about-us/legal-general-counsel/data-breach-notifications) retrieved 2026-07-05 2. T1 [https://legislature.vermont.gov/statutes/section/09/062/02435](https://legislature.vermont.gov/statutes/section/09/062/02435) retrieved 2026-07-05 3. T1 [https://dfr.vermont.gov/doc/reg-bul-ord/security-breach-notice-act-bulletin](https://dfr.vermont.gov/doc/reg-bul-ord/security-breach-notice-act-bulletin) retrieved 2026-07-05 4. T3 [https://www.dwt.com/gcp/states/vermont](https://www.dwt.com/gcp/states/vermont) retrieved 2026-07-05 5. T1 [https://dfr.vermont.gov/banking](https://dfr.vermont.gov/banking) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Vermont permits surcharging without a state cap, allows a $10 minimum-purchase disclosure rule under §2480p, and has a pending (not enacted) S.316 bill on tax/gratuity interchange. Horizon · 2026-Q3 (±half_year) VT S.316 interchange-fee-on-tax/gratuity bill pending committee review_proposed · TT1_ Horizon · 2026-Q3 (±half_year) VT S.316 interchange-fee-on-tax/gratuity bill pending committee review_proposed · TT1_ Standing sub-brief · as of 5 July 2026 189 words · last cycle 2026-07-05 #### Scheme & Network Compliance Vermont's card-network merchant rules, codified at 9 V.S.A. §2480p, permit merchants to set a disclosed minimum card-transaction amount of up to $10.00, provided the minimum is disclosed in 16-point boldface type, and to offer discounts for cash or other alternative payment methods; card networks are barred from restricting merchant acceptance to only some of a merchant's locations. A pending bill, S.316, would go further by prohibiting card networks from charging interchange fees on the portion of a transaction representing state or local sales, use, or excise tax, or gratuity, and would bar networks from raising fees elsewhere to compensate. The bill was read a first time and referred to committee on January 27, 2026 and has not been enacted. It follows a predecessor bill, H.0317, introduced in February 2025, which died in committee without advancing — a pattern suggesting continued but so-far unsuccessful legislative interest in regulating interchange economics directly. #### Outlook S.316's committee status through mid-2026, set against H.0317's 2025 failure, suggests Vermont's interchange-restriction push remains a live but uncertain legislative front; its progress (or renewed failure) is a forward marker for the scheme-compliance module. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://legislature.vermont.gov/statutes/section/09/063/02480p](https://legislature.vermont.gov/statutes/section/09/063/02480p) retrieved 2026-07-05 2. T3 [https://www.getflexpoint.com/credit-card-surcharging-us-states/vermont](https://www.getflexpoint.com/credit-card-surcharging-us-states/vermont) retrieved 2026-07-05 3. T3 [https://www.billtrack50.com/billdetail/1950018](https://www.billtrack50.com/billdetail/1950018) retrieved 2026-07-05 4. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/vermont-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/vermont-surcharge-laws/) retrieved 2026-07-05 5. T3 [https://www.nickel.com/surcharge-laws/vermont](https://www.nickel.com/surcharge-laws/vermont) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 No Vermont-specific cross-border payment corridor regime identified; VT MTL licensees operate under the general national money-transmission/correspondent-banking architecture. Standing sub-brief · as of 5 July 2026 137 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Vermont-licensed money transmitters operate within the general national money-transmitter-license and correspondent-banking architecture for cross-border transmission; no Vermont-specific corridor regulatory layer — such as a state-level remittance-corridor rule or bilateral arrangement — was identified this cycle. The absence of a dedicated state corridor regime is itself the finding: Vermont-licensed transmitters rely on the same national architecture as transmitters licensed in other states, without an additional state-level layer specific to particular payment corridors. No Vermont-specific corridor volume or flow data was located this cycle; this is consistent with a broader pattern in which corridor-specific data is comparatively under-indexed for small-state MTL populations. #### Outlook Absent a dedicated Vermont corridor regime, this module's near-term trajectory tracks the national money-transmission and correspondent-banking architecture rather than any state-specific development; closing the corridor-data gap is a candidate focus for future cycles. no periodic updates on record for this sub-brief ** Sources and findings (2)** 1. T1 [https://dfr.vermont.gov/industry/banking/financial-services/money-services](https://dfr.vermont.gov/industry/banking/financial-services/money-services) retrieved 2026-07-05 2. T1 [https://www.fsb.org/work-of-the-fsb/financial-innovation-and-structural-change/cross-border-payments/](https://www.fsb.org/work-of-the-fsb/financial-innovation-and-structural-change/cross-border-payments/) retrieved 2026-07-05 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-05 Vermont's payments-adjacent industry structure is dominated by community banks and a dense credit union sector (17+ CUs), with limited national fintech physical presence. Standing sub-brief · as of 5 July 2026 138 words · last cycle 2026-09-28 #### Industry Structure & Commercial Dynamics Vermont's payments-adjacent financial sector is notably credit-union-dense. Market data cites 17 or more state- and federally chartered credit unions serving approximately 428,711 members across 80 branch locations, with combined assets exceeding $6.73 billion, based on 2025 NCUA data reported by a market-data aggregator. This figure comes from a single secondary market-data source rather than direct NCUA primary-source verification this cycle. Institutional oversight follows the standard dual-charter US pattern: the DFR Banking Division charters and regulates state-chartered banks, credit unions, and trust companies, while federally chartered institutions instead fall under the OCC for national banks or the NCUA for federal credit unions. #### Outlook Vermont's credit-union-dense structure, combined with the dual state/federal charter split, is a stable feature of the market unlikely to shift materially in the near term absent a broader sector consolidation wave. Periodic update · new data 2026-09-28 #### Industry Structure & Commercial Dynamics The permanent ban on virtual-currency kiosks under Vermont's Act 142 removes an entire category of nonbank cash-to-crypto access point from the state's payments market structure. This is a market-structure event, not merely a compliance-cost change for surviving operators: there is no continued kiosk business in Vermont to speak of following the ban's 1 July 2026 effective date, whereas a tightened-but-continued licensing regime would have left some residual operators serving the market under stricter conditions. The structural context for this closure is that the market had already been substantially hollowed out before the permanent ban took legal effect. A Department of Financial Regulation report found a reduction of more than 94 percent in the number of cash-accepting virtual-currency kiosks operating in Vermont under the prior time-limited moratorium, meaning the permanent ban formalizes and locks in a market contraction that had, in practical commercial terms, already occurred. Any operators still active at the point the moratorium was in place were operating a shrinking and increasingly marginal channel; the permanent ban removes any prospect of a rebound in kiosk deployment once a moratorium period might otherwise have lapsed, which is the commercial-dynamics significance of converting a temporary measure into permanent law. For the broader nonbank payments industry operating in or observing Vermont, this closure is illustrative of a jurisdiction electing to eliminate a specific higher-risk retail channel entirely rather than pursue continued regulation of it through enhanced licensing conditions, transaction limits, or disclosure requirements. This is a meaningfully different commercial-dynamics posture than the tightening-but-preserving approach seen in some other state and national kiosk-regulation frameworks, and industry participants operating similar cash-acceptance infrastructure in other jurisdictions with active virtual-currency-kiosk legislative activity should treat Vermont's approach as a data point on the more restrictive end of the available regulatory spectrum. The commercial-financing licensing regime created by the same Act 142, effective 1 July 2027, represents a structurally different kind of market development: an expansion of Vermont's licensing perimeter to capture a category of nonbank finance provider previously operating with lighter state-level oversight, rather than a market-closure event. Its commercial-dynamics implications for existing Vermont-active commercial-financing providers cannot yet be assessed pending Department of Financial Regulation implementing guidance, which had not been published as of this cycle. #### Outlook No further commercial contraction in the Vermont virtual-currency-kiosk channel is expected, since the market has been closed by permanent statute rather than left to attrite under continuing moratorium conditions. The commercial-financing licensing regime taking effect 1 July 2027 is the item to monitor for its market-structure impact on nonbank commercial-financing providers active in Vermont, pending implementing guidance not yet published. **Sources and findings (4)** 1. T3 [https://www.creditunionsonline.com/vermont-credit-unions.html](https://www.creditunionsonline.com/vermont-credit-unions.html) retrieved 2026-07-05 2. T1 [https://dfr.vermont.gov/industry/banking/financial-institutions](https://dfr.vermont.gov/industry/banking/financial-institutions) retrieved 2026-07-05 3. T3 [https://www.ccua.org/fintechconnect](https://www.ccua.org/fintechconnect) retrieved 2026-07-05 4. T4 [https://jooble.org/jobs-fintech/Vermont](https://jooble.org/jobs-fintech/Vermont) retrieved 2026-07-05 ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 DFR resolves unlicensed money-transmission cases via stipulation-and-consent orders (Uphold HQ, CSG Forte, Internet Escrow Services); VCPA provides a treble-damages private right of action. Standing sub-brief · as of 5 July 2026 193 words · last cycle 2026-07-05 #### Legal & Litigation Vermont's Department of Financial Regulation has an established track record of resolving unlicensed money-transmission activity through administrative stipulation-and-consent orders rather than contested litigation. In February 2019, Uphold HQ entered such an order after operating in Vermont since 2014 without a Money Transmitter License, agreeing to a $6,500 administrative penalty without admitting the violation. CSG Forte Payments, Inc. followed a similar path: found to have engaged in unlicensed money transmission since 2001, it applied for an MTL in June 2020 and was assessed a $22,650 administrative penalty under 8 V.S.A. §2500(11), with its license deemed effective upon execution and payment of the order. Beyond DFR's administrative track, the Vermont Consumer Protection Act (9 V.S.A. §2451 et seq.) gives private parties a right of action, including treble damages for willful or knowing violations plus attorney's fees, with a three-year statute of limitations running from discovery of the unfair or deceptive act. #### Outlook The consistency of DFR's stipulation-and-consent approach across at least two distinct enforcement actions suggests contested litigation is not the state's preferred enforcement posture for unlicensed transmission; the VCPA private right of action remains the more consequential avenue for aggrieved consumers. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://dfr.vermont.gov/reg-bul-ord/uphold-hq-stipulation-and-consent](https://dfr.vermont.gov/reg-bul-ord/uphold-hq-stipulation-and-consent) retrieved 2026-07-05 2. T1 [https://dfr.vermont.gov/reg-bul-ord/csg-forte-payments-inc-stipulation-and-consent-order](https://dfr.vermont.gov/reg-bul-ord/csg-forte-payments-inc-stipulation-and-consent-order) retrieved 2026-07-05 3. T1 [https://dfr.vermont.gov/reg-bul-ord/internet-escrow-services-inc](https://dfr.vermont.gov/reg-bul-ord/internet-escrow-services-inc) retrieved 2026-07-05 4. T3 [https://www.gavelinsight.com/2025/09/victim-of-fraud-in-vermont-know-your.html](https://www.gavelinsight.com/2025/09/victim-of-fraud-in-vermont-know-your.html) retrieved 2026-07-05 5. T1 [https://ago.vermont.gov/attorney-generals-office-divisions-and-unit/consumer-protection/business-business-fraud](https://ago.vermont.gov/attorney-generals-office-divisions-and-unit/consumer-protection/business-business-fraud) retrieved 2026-07-05 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Vermont has no bespoke merchant-acquiring statute; acquiring/chargeback dynamics run through national card-network rules and federal law, overlaid with VT's Chapter 63 and §2480p. Standing sub-brief · as of 5 July 2026 86 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk Vermont has no bespoke state acquiring statute. Merchant acquiring and chargeback risk are instead governed by the national card-network rulebooks — Visa's Dispute Monitoring Program (0.9% dispute-rate / 100-dispute thresholds) and Mastercard's Excessive Chargeback Program (1.5% / 100 disputes), with a five-year MATCH-list exclusion for terminated merchants — layered with federal TILA/FCBA protections and Vermont's own Chapter 63 dispute statute and §2480p. #### Outlook Absent a state-specific acquiring framework, this module tracks national scheme-rule and federal-law developments rather than any distinct Vermont dynamic. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://legislature.vermont.gov/statutes/fullchapter/09/063](https://legislature.vermont.gov/statutes/fullchapter/09/063) retrieved 2026-07-05 2. T1 [https://legislature.vermont.gov/statutes/section/09/063/02480p](https://legislature.vermont.gov/statutes/section/09/063/02480p) retrieved 2026-07-05 3. T3 [https://www.gavelinsight.com/2025/09/victim-of-fraud-in-vermont-know-your.html](https://www.gavelinsight.com/2025/09/victim-of-fraud-in-vermont-know-your.html) retrieved 2026-07-05 4. T4 [https://terms.law/FAQ/payment-processors/chargeback-disputes-faq.html](https://terms.law/FAQ/payment-processors/chargeback-disputes-faq.html) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Act 142 creates a new commercial-financing licensing and disclosure regime (sales-based financing and factoring) effective July 1, 2027, requiring a lender licence for funders and a loan-solicitation licence for brokers, with exemptions for depository institutions and transactions of $1 million or more. Standing sub-brief · as of 5 July 2026 118 words · last cycle 2026-10-04 #### Product Innovation & Market Development Vermont has no formal fintech sandbox or open-banking mandate. The state's most concrete innovation-policy step to date is the Vermont Legislature's Financial Technology Report, prepared by the Vermont Law School Center for Legal Innovation in consultation with DFR, the Agency of Commerce and Community Development, and the Attorney General's Office, which recommended enabling provisions for fintech and blockchain applications, including consideration of an OCC-style fintech charter. #### Outlook With no sandbox or open-banking mandate in place, and the Financial Technology Report's recommendations not yet translated into enacted law, product-innovation policy in Vermont remains at the recommendation stage; private-company and product-innovation signal for a state of Vermont's size is structurally thinner than for larger jurisdictions. Periodic update · new data 2026-10-04 #### Product Innovation & Market Development Act 142 of 2026 creates a new licensing track in Vermont specifically for sales-based financing and factoring products, a segment of commercial finance that has developed and scaled in recent years largely without being treated as licensed lending in most states. The new regime establishes a lender license for funders providing the financing and a separate loan-solicitation license for brokers who arrange it, with an effective date of July 1, 2027. The regime carries TILA-style disclosure obligations and an estimated-APR requirement, bringing a cost-of-credit transparency standard to products that have not historically been required to disclose financing costs in annualized-rate terms. Depository institutions are exempt from the new licensing requirement, as are transactions of one million dollars or more, which focuses the regimes practical effect on nonbank funders and brokers serving small and mid-sized commercial borrowers below that transaction-size threshold. This is a product-innovation and market-development development in the specific sense that it targets a product category, sales-based financing and factoring arrangements structured as purchases of future receivables rather than as traditional loans, that grew in part because that structuring avoided state lending-license requirements in many jurisdictions. Vermonts new licensing track responds directly to that product-structuring dynamic by extending licensing coverage to the activity regardless of how the underlying transaction is characterized, provided it falls within the sales-based-financing or factoring definition the act establishes and above the one-million-dollar exemption threshold. The disclosure dimension of the new regime is a meaningful market-development signal in its own right. Requiring TILA-style disclosures and an estimated APR for products that were not previously required to present a standardized cost-of-credit figure changes how these products can be marketed and compared by commercial borrowers in Vermont. Providers that have built commercial propositions around factor-rate or discount-rate pricing presentations, rather than annualized-rate presentations, will need to adapt their disclosure practices for Vermont-facing transactions ahead of the July 1, 2027 effective date. The one-million-dollar transaction exemption is a notable design choice worth flagging for market participants: it suggests the licensing regime is targeted at the small-and-mid-market segment of commercial finance rather than at larger, more sophisticated commercial borrowers presumed to have greater capacity to evaluate financing terms without the same disclosure protections. Firms serving a mixed portfolio of transaction sizes will need to determine, on a transaction-by-transaction basis, whether a given Vermont-facing deal falls above or below that threshold for licensing and disclosure purposes. A gap in the current evidence base worth flagging for market participants assessing their own product strategy: industry has not generally treated sales-based financing and factoring products as licensed lending, which the available evidence characterizes as creating a compliance gap ahead of the July 1, 2027 effective date. No Department of Financial Regulation implementing guidance or rulemaking elaborating the practical licensing-application process, examination standards, or disclosure-format requirements under the new regime has been located as of this cycle, leaving the one-year-plus run-up period as the window in which such guidance would need to be developed and published for the market to adapt in an orderly way. #### Outlook The principal development to track between now and the July 1, 2027 effective date is whether the Department of Financial Regulation publishes implementing guidance or rulemaking clarifying the licensing-application process, examination expectations, and disclosure-format standards for the new lender and loan-solicitation licenses; none has been located as of this cycle. A second item worth watching is whether providers of sales-based financing and factoring products serving the Vermont market begin adapting their disclosure practices toward TILA-style, estimated-APR presentation ahead of the effective date, which would be an early market-adaptation signal independent of any formal guidance. **1 earlier distinct update(s)** Periodic update · new data 2026-08-11 #### Product Innovation & Market Development Act 142 converts what had been a temporary moratorium into a permanent, statewide ban on virtual-currency kiosks effective July 1, 2026, terminating all existing kiosk registrations. The prior moratorium under 8 V.S.A. Section 2577(f), which ran through July 1, 2026 and carried a grandfather exception for kiosks operational on or before June 30, 2024, is repealed and replaced by this permanent prohibition rather than simply allowed to lapse. For a product category that had previously operated in Vermont under a time-limited registration framework with a defined sunset date, this is a qualitatively different regulatory posture: the category is now closed to non-bank operators outright, not merely paused pending further legislative review. The distinction between a moratorium and a permanent ban matters for market-development purposes. Under the prior moratorium structure, an operator with a grandfathered registration retained a path to continued operation, and the broader question of whether kiosks would eventually be re-permitted remained open pending the moratorium's expiration. Act 142 forecloses that path definitively: every existing registration terminates, and the statute does not create a renewed registration mechanism. This places virtual-currency kiosks in Vermont in the same category as a product that has been legislated out of the non-bank market entirely, rather than one that is simply unregulated or under a temporary hold. #### Outlook With the permanent ban now in force, the product-innovation question for this specific instrument in Vermont is closed rather than open: no rulemaking, licensing pathway, or grandfathering mechanism remains available to bring virtual-currency kiosks back into the non-bank market absent new legislation reversing Act 142. The more relevant forward-looking question is whether Vermont's action is followed by comparable permanent bans in other states that have so far maintained only temporary moratoria on the same product category, continuing the pattern this statute represents. **Sources and findings (4)** 1. T3 [https://vtdigger.org/2024/05/06/lawmakers-send-new-bitcoin-atms-regulation-to-gov-phil-scotts-desk/](https://vtdigger.org/2024/05/06/lawmakers-send-new-bitcoin-atms-regulation-to-gov-phil-scotts-desk/) retrieved 2026-07-05 2. T1 [https://legislature.vermont.gov/assets/Legislative-Reports/Vermont-Report-Final-Version-December-7.pdf](https://legislature.vermont.gov/assets/Legislative-Reports/Vermont-Report-Final-Version-December-7.pdf) retrieved 2026-07-05 3. T3 [https://www.billtrack50.com/billdetail/1873698](https://www.billtrack50.com/billdetail/1873698) retrieved 2026-07-05 4. T4 [https://www.launchvt.com/](https://www.launchvt.com/) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud limited signal Confirmed confirmed 2026-07-05 Vermont's consumer-protection layer runs through the VCPA, AG Consumer Assistance Program, and a new 2025 mandatory-refund obligation for virtual-currency kiosk fraud victims. Standing sub-brief · as of 5 July 2026 169 words · last cycle 2026-09-05 #### Consumer Protection & APP Fraud Vermont has embedded specific anti-fraud conduct requirements directly into its virtual-currency kiosk statute. Under 8 V.S.A. §2577, kiosk operators must arrange a live screening call for any new customer over the age of 60 before that customer's first kiosk transaction, and for any customer attempting more than $5,000 in transactions over a ten-day period. This sits alongside a 2025 legislative addition requiring kiosk operators to refund new-customer fraud victims who report the crime within 90 days. That requirement responds to a documented pattern: nationally, crypto-ATM fraud losses rose nearly tenfold between 2020 and 2023 and exceeded $65 million in the first half of 2024 alone, with adults aged 60 and over more than three times as likely to report a loss. #### Outlook The combination of the age/threshold-triggered screening call and the 90-day refund right makes Vermont's kiosk-specific consumer-protection regime one of the more prescriptive state-level APP-fraud interventions built directly into a payments product; further tightening around kiosks appears the most likely direction of travel. Periodic update · new data 2026-09-08 #### Consumer Protection & APP Fraud A new kiosk-specific consumer-protection obligation took effect under 8 V.S.A. Section 2577(g): virtual-currency kiosk operators in Vermont must verify the identity of the customer prior to accepting payment for every transaction, and are prohibited from processing a transaction under any name, account, or identity other than the customer's own. This is a targeted anti-fraud control aimed at the cash-to-crypto conversion channel, where identity-substitution and third-party-facilitated transactions are a recognised fraud vector. The obligation applies specifically to the kiosk channel and does not extend to other virtual-currency business models operating under Vermont's general money transmitter licence. This identity-verification requirement sits within the same statutory provision, Section 2577, that carries the kiosk moratorium extension under Act 142, meaning the consumer-protection tightening and the market-access tightening arrived via the same legislative vehicle. The requirement is confirmed at Tier 1 sourcing directly from Vermont's own statutory text, giving it high evidentiary confidence. #### Outlook The identity-verification requirement is now in force and is not tied to the moratorium's July 2027 expiration; it will continue to apply to kiosk operators regardless of how the moratorium question resolves. Any future kiosk-specific consumer-protection rulemaking in Vermont is likely to build on this identity-verification template. **Sources and findings (5)** 1. T3 [https://www.gavelinsight.com/2025/09/victim-of-fraud-in-vermont-know-your.html](https://www.gavelinsight.com/2025/09/victim-of-fraud-in-vermont-know-your.html) retrieved 2026-07-05 2. T1 [https://ago.vermont.gov/attorney-generals-office-divisions-and-unit/consumer-protection](https://ago.vermont.gov/attorney-generals-office-divisions-and-unit/consumer-protection) retrieved 2026-07-05 3. T3 [https://states.aarp.org/vermont/new-guardrails-on-crypto-atm-fraud](https://states.aarp.org/vermont/new-guardrails-on-crypto-atm-fraud) retrieved 2026-07-05 4. T1 [https://legislature.vermont.gov/statutes/section/08/079/02577](https://legislature.vermont.gov/statutes/section/08/079/02577) retrieved 2026-07-05 5. T1 [https://dfr.vermont.gov/home-page](https://dfr.vermont.gov/home-page) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-vermont/#sec-dom-D7) Probable confirmed 2026-07-05 SENTINEL-FED: Vermont's AML/CFT payments-context position rests on FinCEN BSA registration as an MTL precondition, §2534 ML reporting, and new 2025 kiosk EDD/blockchain-analytics obligations. Standing sub-brief · as of 5 July 2026 118 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime This module is sourced from the Sentinel.gi feed and is carried here for payments-context only; underlying illicit-finance and de-risking analysis belongs to the FIM monitor rather than to this brief. Vermont's Money Transmitter License applicants must register with FinCEN under the Bank Secrecy Act as a precondition of eligibility, linking the state's licensing gate directly to the federal AML/CFT registration regime. Separately, 8 V.S.A. Chapter 79 Subchapter 5, §2534, requires money-laundering reports alongside report-of-condition and audited-financial-statement requirements, embedding AML reporting duties into the core MTL licensing framework itself. #### Outlook For further analysis of illicit-finance implications arising from these Vermont AML/CFT touchpoints, see the Sentinel-fed FIM monitor; this brief does not develop that analysis independently. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 sentinel.home.treasury.gov/system/files/136/Treasury_AMLA_23_508.pdf 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Vermont — Vermont operates under the federal U.S. BSA/AML framework (FinCEN, OFAC) with no independent state AML statute; the Vermont Department of Financial Regulation (DFR) licenses and supervises the state's captive insurance sector and money-transmitter/MSB activity primarily for solvency and conduct, not dedicated AML typology. No state-level beneficial-ownership registry exists; federal CTA reporting now largely inapplicable to domestic entities. 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-002) — Gap: capacity-deficit 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-05 No VT-specific correspondent-banking rule exists; VT institutions access settlement via the standard Fed Master Account/correspondent architecture, with a Dec-2025 Payment Account prototype RFI signalling a potential new tailored route. Standing sub-brief · as of 5 July 2026 188 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access Vermont-chartered banks and credit unions access payment-system settlement through the standard Federal Reserve architecture: a Federal Reserve Master Account, one per separately chartered institution, or, for smaller institutions that do not hold a Master Account directly, a pass-through correspondent arrangement with another institution that does. No Vermont-specific correspondent-banking or de-risking event was identified this cycle; the national Federal Reserve framework applies without an additional state-level layer. A potential structural shift is under consideration at the federal level: in December 2025 the Federal Reserve Board issued a request for information on a special-purpose "Payment Account" prototype tailored to payments-focused institutions. As proposed, this account type would not permit its holder to act as a correspondent for other respondents, distinguishing it from a full Master Account; the proposal remains at the RFI stage and is not yet in force. #### Outlook The Fed's Payment Account prototype, if it proceeds beyond the RFI stage, would be the most consequential near-term development for how Vermont-based payments-focused institutions — as distinct from full-service banks — might access settlement directly; its progress is a priority watch item for next cycle. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.federalreserve.gov/monetarypolicy/reserve-maintenance-manual-account-structure.htm](https://www.federalreserve.gov/monetarypolicy/reserve-maintenance-manual-account-structure.htm) retrieved 2026-07-05 2. T1 [https://www.frbservices.org/financial-services/accounting/service-setup/respondent-correspondent.html](https://www.frbservices.org/financial-services/accounting/service-setup/respondent-correspondent.html) retrieved 2026-07-05 3. T1 [https://www.federalregister.gov/documents/2025/12/23/2025-23712/request-for-information-and-comment-on-reserve-bank-payment-account-prototype](https://www.federalregister.gov/documents/2025/12/23/2025-23712/request-for-information-and-comment-on-reserve-bank-payment-account-prototype) retrieved 2026-07-05 4. T1 [https://home.treasury.gov/system/files/136/Treasury_AMLA_23_508.pdf](https://home.treasury.gov/system/files/136/Treasury_AMLA_23_508.pdf) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) Uncertain confirmed 2026-07-05 No Vermont-headquartered payments-sector M&A, funding round, or product launch within the trailing 12 months identified; national Capital One-Brex deal noted as context only. Standing sub-brief · as of 5 July 2026 126 words · last cycle 2026-07-05 #### Commercial Intelligence No Vermont-headquartered M&A transaction, investment/funding round, or product launch was identified this cycle despite dedicated search. The only commercial event captured in this module is national in scope: Capital One agreed in January 2026 to acquire Brex for $5.15 billion in cash and stock, with the deal expected to close in mid-2026. The transaction's value was publicly disclosed. It is included here as trend context for the national bank-fintech consolidation dynamic relevant to Vermont's own bank-fintech partnership landscape, rather than as a Vermont-specific event. #### Outlook Absent a Vermont-headquartered deal this cycle, this module's Vermont-specific content remains a research gap to prioritize closing in future cycles; national consolidation context, as with Capital One-Brex, will continue to be noted where directly relevant to Vermont market structure. no periodic updates on record for this sub-brief ** Sources and findings (1)** 1. T3 [https://www.paymentsdive.com/news/capital-one-acquire-brex-5-billion-fintech/810319/](https://www.paymentsdive.com/news/capital-one-acquire-brex-5-billion-fintech/810319/) 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 – Vermont| 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": {"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:** 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), 59 finding(s), 134 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).