United States – Michigan

US-MI schema world-payments-v1 trajectory: not yet assessed

Last updated · 14 modules · 61 sourced findings · 11 sources in the cumulative register

United States federal law that applies in United States – Michigan is covered once, on the United States page. This page covers United States – Michigan’s own layer: its own law, regulators and enforcement.

Jurisdiction brief

Latest update · 26 October 2026

Lead Signal

Michigan's payments-regulatory landscape is shaped by escalating litigation over sports-related event contracts and a licensing-scope gap for crypto-conversion kiosks that municipalities are filling ahead of the state. On October 7, 2026, Coinbase Financial Markets, Inc. agreed with the Michigan Gaming Control Board to stop offering new sports-related event contracts to Michigan customers and to close open positions by October 10, 2026, in exchange for the Board forbearing enforcement while Coinbase's Sixth Circuit appeal proceeds; Coinbase maintains that event contracts fall under federal commodities regulation and is continuing its legal challenge notwithstanding the stipulation. This follows a September 1, 2026 preliminary injunction against KalshiEX LLC, converted from a June 2026 temporary restraining order by an Ingham County Circuit Judge, barring that platform's Michigan sports contracts and imposing a $500,000-per-day penalty for non-compliance with geolocation and notice requirements.

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Michigan's money-transmission licensing framework (2006 PA 250, MCL 487.1001-487.1047) is being replaced by the Money Transmission Modernization Act (HB 5544 package, CSBS model law), pending Senate committee since July 1, 2026, with engrossed repeal date July 1, 2027.

Horizon · 2027-01-01 (± a quarter)Money Transmission Modernization Act takes effectAdopted · Tier 3 source
Horizon · 2027-07-01 (± a quarter)Current Money Transmission Services Act repealedAdopted · Tier 3 source
Horizon · 2027-01-01 (± a year)HB 5544 Money Transmission Modernization Act potential enactmentProposed · Tier 1 source
Horizon · 2027-07-01 (± a year)Michigan Money Transmission Modernization Act repeal/replace of 2006 PA 250Proposed · Tier 1 source
Horizon · 2027-07-01 (± a quarter)Money Transmission Modernization Act repeal of current MI MTL regimeProposed · Tier 1 source
Horizon · 2027-07-01 (± a year)Michigan Money Transmission Modernization Act (HB 5544) repeal/transition dateProposed · Tier 1 source
Standing sub-brief · as of 6 August 2026144 words · last cycle 2026-10-26

Licensing, Authorisation & Market Access

Michigan continues to license virtual-currency administrators and exchangers as ordinary money transmitters under the Michigan Money Transmission Services Act (MCL 487.1001 et seq.), with no dedicated virtual-currency licence in place; the Department of Insurance and Financial Services treats e-wallet and stored-value holding, and virtual-currency administration or exchange, as licensable money transmission. The state's licensing regime sets a minimum net worth requirement of $100,000, scaling toward $1,000,000 as licensees add locations or delegates. These requirements apply to non-bank money-service businesses and payment or e-money institutions, distinct from depository banks, which are licensed and supervised under separate bank-charter frameworks.

Periodic update · new data 2026-10-26

Licensing, Authorisation & Market Access

Michigan's market-access picture for payments-adjacent crypto businesses is defined this cycle by a gap between stalled state legislation and active municipal regulation of cash-conversion kiosks. House Bill 5544, the Money Transmission Modernization Act, passed the Michigan House 97-10 on June 25, 2026 and has been referred to the Senate Finance, Insurance, and Consumer Protection Committee since July 1, 2026, with no further Senate action recorded through October 25, 2026; under current engrossed text, the existing Money Transmission Services Act would not be repealed, and existing licensees would not face conflicting new provisions, until July 1, 2027.

Into that gap, Jackson, Michigan adopted an ordinance banning cryptocurrency kiosks outright, effective October 22, 2026 with a 90-day removal window for existing machines. Port Huron took a lighter-touch approach, adopting an annual kiosk-operator registration requirement due October 1, 2026. This produces a market-access patchwork at the municipal level: a would-be kiosk operator in Michigan currently faces a different access regime depending on which municipality it operates in, pending the outcome of state-level legislation (HB 5469 and HB 5470) that would bring kiosk operators under uniform money-transmitter licensing and preempt the current municipal approach.

Outlook

The key market-access variable is whether HB 5469/5470 advance out of House committee before further municipal ordinances multiply the patchwork; separately, whether HB 5544 moves in Senate committee will determine the pace of the broader money-transmission modernization and its eventual effect on licensing scope for the fiat leg of crypto conversion.

2 earlier distinct update(s)
Periodic update · new data 2026-10-18

Licensing, Authorisation & Market Access

Michigan's money-transmission licensing framework under the Money Transmission Services Act (MCL 487.1001-487.1047) is mid-transition. House Bill 5544, the Money Transmission Modernization Act, would repeal this current statute effective July 1, 2027 and replace it with the Conference of State Bank Supervisors model licensing regime. The bill passed the Michigan House by a vote of 97-10 on June 25, 2026 and has been pending in the Senate Finance, Insurance, and Consumer Protection Committee since July 1, 2026. The replacement regime would bring Michigan into alignment with the CSBS model law framework already adopted in some form by a large number of other states, a structural shift toward multistate-examination acceptance intended to reduce duplicative state-by-state licensing burden for money transmitters operating across multiple jurisdictions.

A distinguishing feature of the pending replacement is a like-kind virtual-currency reserve requirement: a licensee transmitting virtual currency would be required to hold like-kind virtual currency of the same volume obligated to consumers. This provision extends the licensing framework's reach into crypto-asset operators specifically, a market-access condition that does not exist under the current statute. For payment companies and crypto-asset operators either currently licensed in Michigan or considering market entry, the open question is the ultimate shape and timing of this replacement regime, since the bill remains in committee with no confirmed Senate timeline.

Outlook

Whether the Senate Finance, Insurance, and Consumer Protection Committee acts on HB 5544 before the legislative session recesses is the key near-term variable. If passed in its current form, the new licensing regime, including the virtual-currency reserve requirement, would take effect July 1, 2027, materially changing market-access conditions for payment companies and crypto-asset operators licensed to transmit money in Michigan.

Periodic update · new data 2026-08-25

Licensing, Authorisation & Market Access

Michigan's House Bill 5544, which adopts the Money Transmission Modernization Act (MTMA) as successor to 2006 PA 250, passed the Michigan House 97-10 on June 25, 2026, and was referred to the Senate Finance, Insurance, and Consumer Protection Committee on July 1, 2026. Its Senate companion, SB 0835, had been referred to the same committee on March 17, 2026, giving the reform two live legislative vehicles moving in parallel. As reported from committee, the MTMA's money-transmission definition expressly excludes the exchange, transfer, or custody of virtual currency that does not involve a transfer of legal tender, which functions as a scope carve-out for non-fiat crypto activity rather than a new licensing track for it. If enacted, the Act would take effect January 1, 2027, would repeal the current statute effective July 1, 2027, and would cut the surety-bond floor to $100,000, a materially lower fixed cost of market entry than the current regime imposes.

The reform bears specifically on the non-bank layer of Michigan's payments market. Money-transmission licensing in Michigan, as elsewhere in the United States, applies to non-bank payment institutions and e-money-equivalent licensees; depository institutions conducting equivalent activity are supervised separately under prudential bank regulation rather than through the money-transmission licensing regime the MTMA would replace. A lower surety-bond floor therefore reduces a fixed compliance cost specifically for smaller non-bank money-transmission applicants seeking to enter or remain in the Michigan market, while the virtual-currency carve-out narrows the population of crypto-custody and crypto-exchange activity that requires a Michigan money-transmission license at all.

Outlook

The procedural marker to watch is movement in the Senate Finance, Insurance, and Consumer Protection Committee, where both HB 5544 and SB 0835 currently sit. Michigan's regulatory horizon places the Act's effective date at January 1, 2027, carrying a half-year uncertainty band that reflects the bill's current committee-stage status rather than enactment. Passage and signature would move Michigan from the current 2006 PA 250 regime to the multistate MTMA model with a lower bond floor and an explicit virtual-currency carve-out; absent that, the current regime continues to apply unchanged.

Sources and findings (7)
  1. T1https://www.legislature.mi.gov/documents/mcl/pdf/mcl-Act-250-of-2006.pdf
  2. T1https://www.michigan.gov/difs/industry/licensing-cf/money-transmit
  3. T1https://origin-sl.michigan.gov/difs/0,5269,7-303-13648_60667_76248---,00.html
  4. T1https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission
  5. T1https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm
  6. T2https://legiscan.com/MI/text/SB0835/id/3396679
  7. T3https://fraxtional.co/feeds/blog/mi-money-transmitter-license

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Safeguarding rests on a permissible-investments requirement backed by surety bond, with DIFS examination/confidentiality powers under Section 26. The pending MTMA bill would introduce a statutory trust mechanism over permissible investments for customer benefit in insolvency, a stronger safeguarding model than current law but not yet in force.

Standing sub-brief · as of 6 August 2026143 words · last cycle 2026-08-05

Conduct, Safeguarding & Financial Promotions

Michigan House Bill 5544 would adopt the full CSBS Money Transmission Modernization Act template, including payroll processors, as part of a 31-state MTMA adoption wave. Companion Senate Bill 835 would adopt the same full MTMA template but with a payroll-processor exemption for agents of the payor. Both bills apply to non-bank money-service businesses and payment or e-money institutions rather than to depository banks, and neither introduces a dedicated virtual-currency licensing regime; Michigan would continue to license virtual-currency administrators and exchangers as ordinary money transmitters.

Periodic update · new data 2026-08-11

Conduct, Safeguarding & Financial Promotions

Michigan's non-bank payment-institution and e-money-issuer sector faces a modernizing conduct and licensing framework this cycle, driven by two companion bills moving through the state legislature. House Bill 5544 proposes full adoption of the Conference of State Bank Supervisors' Money Transmission Modernization Act template, including its treatment of payroll processors as licensable money transmitters, while Senate Bill 835 proposes the same core template with a payroll-processor exemption, treating such processors as agents of the payor rather than as entities requiring separate licensure. Both bills form part of a broader 31-state modernization wave coordinated through the CSBS template, under which participating states adopt harmonized net-worth, surety-bond, and permissible-investment standards for licensed money transmitters. This is a High-confidence, directly-sourced legislative development, evidenced by CSBS's own tracked legislative update, though neither bill has been enacted this cycle.

The conduct-and-safeguarding significance of this modernization effort lies less in any single provision than in the broader alignment it represents: Michigan's money-transmission licensing regime would move toward the more contemporary, harmonized standard that a majority of US states have now adopted or are adopting. For non-bank payment institutions and e-money issuers licensed in Michigan, this creates a forward-looking conduct expectation: capital, safeguarding, and permissible-investment standards are likely to converge toward the CSBS template's baseline, even though the precise terms remain unsettled pending enactment.

The payroll-processor question captured in the divergence between the House and Senate bills is itself a conduct-classification issue with direct financial-promotions and product-scope implications: whether a payroll processor is treated as an agent of the payor (exempt, per the Senate version) or as a licensable money transmitter in its own right (per the House version) determines whether that class of non-bank payment intermediary carries the full weight of Michigan's money-transmission conduct obligations, including bonding, net-worth, and associated safeguarding standards for customer funds. This is a bank-versus-non-bank-adjacent distinction in substance, since it determines which category of non-bank intermediary is drawn into the state's licensed-conduct perimeter and which remains outside it.

Outlook

The decisive near-term event for this domain is the legislative fate of House Bill 5544 and Senate Bill 835, expected to remain live through the fourth quarter of 2026; enactment of either bill, and in particular resolution of the payroll-processor exemption question between the House and Senate versions, would settle the conduct-classification question for that category of non-bank payment intermediary and would be the appropriate trigger to revisit this domain's signal level. Passage would also be the clearest evidence yet that Michigan intends to align fully with the 31-state CSBS modernization wave rather than retain its current, less harmonized standard.

Sources and findings (4)
  1. T1https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission
  2. T1https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission
  3. T1https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm
  4. T1https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification

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Michigan has no dedicated state-level stablecoin issuance statute; the operative framework is the federal GENIUS Act (signed 2025-07-18), being implemented through OCC, FDIC and joint FinCEN/OFAC rulemakings during 2026, applicable nationwide including to Michigan state-chartered banks.

Open gap — wpm-int-2No stablecoin/digital-money state-level rule for US-MI exists; not applicable in this regime.US state-level APP-fraud enforcement is a known under-indexed vector.
Horizon · 2026-06-09 (± a quarter)FinCEN/OFAC comment period closes on PPSI AML/CFT proposed ruleConsultation · Tier 1 source
Horizon · 2026-05-01 (± a quarter)OCC comment period closes on GENIUS Act implementing ruleConsultation · Tier 1 source
Horizon · 2026-06-09 (± a quarter)FinCEN/OFAC comment period closes on PPSI AML/CFT proposed ruleConsultation · Tier 1 source
Standing sub-brief · as of 7 July 2026206 words · last cycle 2026-07-05

Stablecoins & Digital Money

Michigan has no dedicated state-level stablecoin statute; the operative framework for both bank and non-bank issuers serving Michigan is the federal GENIUS Act, signed into law on 2025-07-18, which establishes a federal framework for payment-stablecoin issuance, operation and regulation applying nationwide. Three implementing rulemakings are proceeding in parallel through 2026. The OCC has proposed a rule governing stablecoin issuance and custody activities of national banks, federal savings associations, federal branches, and federal- or state-qualified payment stablecoin issuers, with comments due 2026-05-01 — a track that directly shapes the issuer pathway available to Michigan state-chartered banks. The FDIC proposed, on 2025-12-19, application requirements and procedures for FDIC-supervised institutions, including Michigan state nonmember banks, to issue payment stablecoins through a subsidiary. And FinCEN and OFAC jointly proposed a rule, with comments due 2026-06-09, treating permitted payment stablecoin issuers as Bank Secrecy Act financial institutions subject to AML and sanctions-compliance obligations.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.kslaw.com/news-and-insights/stablecoin-legislation-has-left-the-stable
  2. T1https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the
  3. T1https://www.federalregister.gov/documents/2025/12/19/2025-23510/approval-requirements-for-issuance-of-payment-stablecoins-by-subsidiaries-of-fdic-supervised-insured
  4. T1https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism

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Michigan's operational-resilience layer combines MCL 445.72 breach notification, DIFS cybersecurity event notification (Form FIS 2359), and PA 690 of 2018 for insurance licensees. A five-bill reform package (SB 360-364), passed by the Senate August 2025, would tighten the breach standard to a firm 45-day deadline with new civil penalties; pending in the House as of March 2026.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. Open its jurisdiction pages on Dataprotection.gi →

Standing sub-brief · as of 7 July 2026191 words · last cycle 2026-07-05

Operational Resilience & Critical Infrastructure

Michigan's operational-resilience layer combines general and sector-specific instruments. The Identity Theft Protection Act (MCL 445.72) requires notice to affected Michigan residents without unreasonable delay upon discovery of a security breach, unless substantial harm is unlikely, with a safe harbor for institutions compliant with federal interagency guidance. DIFS separately requires licensees to notify it within 10 business days of determining a cybersecurity event occurred (Form FIS 2359), under the Michigan Insurance Data Security Law (PA 690 of 2018), alongside an annual compliance-certification filing (Form FIS 2360) due February 15.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-445-72
  2. T1https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification
  3. T3https://www.recordinglaw.com/us-laws/data-privacy-laws/michigan-data-privacy-laws/data-breach-notification/
  4. T3https://www.perkinscoie.com/en/news-insights/security-breach-notification-chart-michigan.html

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Michigan permits credit-card surcharging (since a 2013 settlement lifted the Visa/Mastercard ban) but imposes state-specific disclosure duties, prohibits debit surcharging, and treats surcharge fees as part of the taxable sales price under the General Sales Tax Act per 2024 Treasury guidance.

Standing sub-brief · as of 7 July 202697 words · last cycle 2026-07-05

Scheme & Network Compliance

Michigan merchants have been permitted to surcharge credit-card transactions since a 2013 Visa/Mastercard/bank class-action settlement lifted the contractual surcharging ban; debit-card surcharging remains prohibited under card-network rules and federal law. The Michigan Department of Treasury has determined that credit-card surcharges form part of the taxable "gross proceeds" or "sales price" under the General Sales Tax Act, subjecting them to the state's 6% sales tax.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/shopping/credit-debit-card-surcharges
  2. T1https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-act-379-of-1984
  3. T2https://www.nfib.com/news/news/mi-department-of-treasury-to-small-business-credit-card-surcharge-fees-subject-to-sales-tax/
  4. T3https://www.getnickel.com/surcharge-laws/michigan
  5. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/michigan-credit-card-surcharge-laws/

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Michigan financial institutions participate in the national FedNow rail; MSUFCU is a documented Michigan participant operating receive-only with planned send-side expansion, reflecting national credit-union-led gradual FedNow adoption rather than Michigan-specific corridor infrastructure.

Standing sub-brief · as of 7 July 2026126 words · last cycle 2026-07-05

Payment Corridor Dynamics

Michigan State University Federal Credit Union (MSUFCU) participates in the FedNow Service on a receive-only basis, with planned send-side capability, citing gig-worker and student demand for instant access to funds. This sits within a national FedNow expansion in which the service reached more than 1,500 participating financial institutions across all 50 states by late 2025 — a 44% year-on-year increase — with the per-transaction limit raised from $1 million to $10 million effective November 2025. No Michigan-specific corridor infrastructure beyond this national-rail participation was identified this cycle.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T1https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union
  2. T1https://www.frbservices.org/news/fed360/issues/121625/general-2026-fees-payment-system-enhancements

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Michigan's payments-adjacent industry structure is being reshaped by Fifth Third's $10.9-12.7bn acquisition of Comerica, alongside a growing Detroit/Ann Arbor fintech and credit-union-fintech-partnership ecosystem (Rocket Companies, Bankjoy, InvestNext, Autobooks, MSUFCU-Zirtue).

Standing sub-brief · as of 7 July 2026163 words · last cycle 2026-07-05

Industry Structure & Commercial Dynamics

Michigan's payments-adjacent banking structure was reshaped in the review period by Fifth Third Bancorp's $12.7 billion all-stock acquisition of Comerica Incorporated, closed in February 2026. The combination creates the ninth-largest US bank by assets (approximately $288 billion) and makes Fifth Third the largest bank by Michigan and Detroit retail deposit share, with 227 combined Michigan branches remaining after 75 closures. Separately, MSUFCU partnered with fintech Zirtue, integrated with Plaid, to offer a friends-and-family lending platform. Detroit's broader fintech ecosystem includes Autobooks (embedded SMB banking, which raised a $50 million Series C in 2022 plus $40 million in further growth funding), InvestNext, and Y Combinator-backed digital-banking provider Bankjoy.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T2https://www.detroitnews.com/story/business/2026/06/01/fifth-third-comerica-bank-branch-closures-michigan/90360145007/
  2. T2https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/
  3. T2https://www.americanbanker.com/creditunions/news/michigan-credit-union-helps-members-borrow-from-friends-and-family
  4. T3https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026
  5. T3https://builtin.com/companies/location/na/usa/mi/type/fintech-companies

Michigan's enforcement campaign against prediction-market operators continued: Coinbase stipulated Oct 7, 2026 to halt new MI sports contracts and wind down by Oct 10, 2026; a CFTC interim final rule (eff. Oct 19, 2026) codified that licensed-sportsbook wagers are not CFTC swaps.

Key judgment — Probable · impact ELEVATEDMichigan's litigation posture against CFTC-registered sports-related event-contract platforms is producing sequential market exits (Robinhood, then Coinbase) while the underlying federal-preemption question remains unresolved on appeal.claims: wpm-2026-W43-002, wpm-2026-W43-003
Standing sub-brief · as of 7 July 2026137 words · last cycle 2026-10-26

Legal & Litigation

Michigan is at the center of the national prediction-markets legal battle. Attorney General Dana Nessel sued Kalshi in Ingham County Circuit Court on 2026-03-03, alleging unlicensed sports-related event contracts — including a Pistons-Wizards combined-point-total market — and seeking a permanent injunction. On 2026-06-17, U.S. District Judge Paul Maloney denied preliminary-injunction motions brought by Polymarket and Robinhood, finding sports-event contracts unlikely to qualify as Commodity Exchange Act "swaps" and holding that Michigan retains traditional gambling-regulation authority, citing Bond v. United States.

Periodic update · new data 2026-10-26

Legal & Litigation

Michigan's litigation posture against CFTC-registered sports-related event-contract platforms escalated further. On October 7, 2026, Coinbase Financial Markets, Inc. stipulated with the Michigan Gaming Control Board to stop offering new sports-related event contracts to Michigan customers and to close existing open positions by October 10, 2026; in exchange, the Board agreed to forbear enforcement while Coinbase's appeal to the Sixth Circuit proceeds on a stayed basis. Coinbase's own stated position, per its stipulation, is that event contracts fall under federal commodities regulation and that it is continuing its legal challenge notwithstanding the stipulation a negotiated practical withdrawal rather than a concession on the underlying legal question.

This follows a September 1, 2026 action in which an Ingham County Circuit Judge converted a June 2026 temporary restraining order into a preliminary injunction against KalshiEX LLC, barring that platform's Michigan sports contracts and imposing a $500,000-per-day penalty for non-compliance with geolocation and notice requirements. Taken together, the two actions show Michigan authorities pursuing both litigated injunctive relief and negotiated stipulation as parallel enforcement tracks against platforms operating sports-related event contracts without state gaming licensure, while the underlying federal-preemption question remains unresolved on appeal.

Outlook

The Sixth Circuit's eventual ruling on the stayed appeals is the determinative variable; until it issues, expect the current pattern of case-by-case injunctions and stipulated exits to continue, with litigation and negotiated withdrawal proceeding as parallel, not mutually exclusive, enforcement tools.

1 earlier distinct update(s)
Periodic update · new data 2026-10-18

Legal & Litigation

Coinbase Financial Markets, Inc. stipulated with the Michigan Gaming Control Board to stop offering new sports-related event contracts to Michigan customers and to close out open positions by 12:00 a.m. Eastern time on October 10, 2026. Under the stipulation, the MGCB agreed not to pursue enforcement against Coinbase pending resolution of a Sixth Circuit appeal. This settlement follows a similar agreement reached by Robinhood on September 9, 2026, leaving Kalshi as the remaining operator subject to an injunction in this contested Michigan product segment.

A Commodity Futures Trading Commission interim final rule, effective October 19, 2026, bears directly on this litigation: the rule excludes wagers placed with state- or tribal-licensed sportsbooks and casinos from the Commodity Exchange Act's swap definition. This federal action undercuts the federal-preemption defense that Coinbase, Kalshi, Robinhood and Polymarket have raised against Michigan Gaming Control Board enforcement in the pending Sixth Circuit appeal, strengthening the state's position that sports-related event contracts fall within its own gambling-licensing jurisdiction rather than under federal derivatives oversight.

Outlook

The Sixth Circuit's resolution of the federal-preemption question, now considered against the CFTC's new interim final rule, is the central variable to watch. A ruling against the preemption defense would likely confirm Michigan's gambling-licensing jurisdiction over sports-related event contracts, directly affecting Kalshi's ongoing injunction and any other platform contemplating a similar product in the state.

Sources and findings (4)
  1. T2https://michigangaming.com/michigans-fight-over-prediction-markets/
  2. T2https://www.gamblinginsider.com/news/115936/michigan-kalshi-lawsuit-polymarket-robinhood-prediction-markets
  3. T1https://www.gamblinginsider.com/news/167546/michigan-judge-denies-polymarket-robinhood-injunctions
  4. T3https://www.playmichigan.com/news/federal-judge-denies-polymarket-bid-to-block-michigan-enforcement/

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Michigan's merchant-acquiring risk framework is defined largely by consumer-facing surcharge disclosure rules rather than a distinct acquiring-license regime; merchants operate under the general bank-sponsorship/card-network model, with MI-specific obligations concentrated in surcharge signage/receipt/online disclosure.

Standing sub-brief · as of 7 July 2026102 words · last cycle 2026-07-05

Merchant Acquiring & Risk

Michigan does not operate a distinct merchant-acquiring license regime; fintechs and merchants instead access card networks, wires and ACH through the standard U.S. sponsor-bank model. The state's principal acquiring-adjacent obligations are consumer-facing surcharge rules: signage and disclosure requirements at the store entrance and point-of-sale terminal, and online disclosure at first mention of a credit-card payment option, with surcharges capped at processing cost and prohibited from varying by card brand.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T3https://www.getnickel.com/surcharge-laws/michigan
  2. T1https://www.legislature.mi.gov/documents/2013-2014/billanalysis/House/archive/2013-HLA-4255-74A48DFB.HTM
  3. T3https://www.lithic.com/blog/bank-partners

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Michigan's product-innovation layer is anchored in Detroit's growing embedded-fintech and credit-union-fintech ecosystem (Autobooks, InvestNext, Bankjoy, MSUFCU FedNow/Zirtue), supported by public seed-stage capital via the City of Detroit's Startup Fund.

Standing sub-brief · as of 7 July 2026106 words · last cycle 2026-07-05

Product Innovation & Market Development

The City of Detroit launched a $700,000 Startup Fund distributing seed grants of $15,000 and scale grants of $50,000 to Detroit-area startups, including fintechs; a second round in February 2026 awarded $300,000 across 13 startups. Separately, MSUFCU is exploring additional FedNow use cases beyond its current receive-only participation, including indirect auto-loan funding, student-loan refund disbursement, and insurance-payout disbursement.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union
  2. T2https://detroitmi.gov/news/detroit-launches-first-its-kind-700000-startup-fund-fuel-job-creation-and-talent-retention
  3. T2https://www.crainsdetroit.com/entrepreneurship/detroits-municipal-startup-fund-awards-its-first-300000
  4. T3https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026

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Michigan consumer protection for payments harms runs through the AG's Consumer Protection Team and DIFS, with active AG alerts targeting P2P payment-app scams and AI voice-cloning fraud; there is no dedicated state APP-fraud reimbursement mandate.

Standing sub-brief · as of 7 July 2026114 words · last cycle 2026-07-05

Consumer Protection & APP Fraud

The Michigan Attorney General's Consumer Protection Team maintains active alerts warning consumers about peer-to-peer payment-app scams, including "return the money" patterns exploiting stolen funds, directing victims to the app host, the FTC, or the CFPB. In April 2026, during Money Smart Week, Attorney General Dana Nessel reissued an AI Scams consumer alert warning of AI-generated deepfake voice-cloning fraud that impersonates loved ones to solicit payment-app transfers.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/scams/payment-apps-and-scams
  2. T1https://www.michigan.gov/ag/news/press-releases/2026/04/20/ag-nessel-reissues-ai-scams-consumer-alert-during-money-smart-week
  3. T1https://www.michigan.gov/ag/news/press-releases/2024/12/23/ag-nessel-warns-consumers-about-holiday-payment-apps-and-scams
  4. T1https://www.michigan.gov/ag/consumer-protection

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W11 carries the Sentinel.gi feed only; no jurisdiction-specific Sentinel.gi content for US-MI was retrievable this cycle. Standing federal BSA framework layers onto MTSA licensees; no original illicit-finance analysis performed (FIM territory).

Open gap — wpm-int-1No AML/CFT (W11) delta for US-MI was found this cycle.no under-indexing note recorded
Standing sub-brief · as of 7 July 2026133 words · last cycle 2026-07-05

AML/CFT & Financial Crime

This module is sourced from the Sentinel.gi feed; no Michigan-specific Sentinel.gi content was retrievable via open-web search this cycle. What can be carried is the standing statutory backdrop: Michigan MTSA licensees must maintain a documented AML/BSA compliance program as a continuing condition of licensure, alongside quarterly MSB Call Reports, and both the current MTSA and the pending MTMA incorporate the federal Bank Secrecy Act (Public Law 91-508) and its implementing regulations by reference into state licensing conditions. No original illicit-finance analysis has been performed here; readers seeking substantive AML/CFT intelligence should consult the Sentinel.gi feed directly.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T1https://www.legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm
  2. T?FIM (sentinel.gi) per-JID baseline profile — United States — Michigan — Michigan operates entirely within the federal BSA/AML, OFAC-sanctions and FinCEN CTA architecture; the state layer consists of Department of Licensing and Regulatory Affairs (LARA) corporate formation (no beneficial-ownership verification), DIFS licensing of money transmitters under the Uniform Money Services Act, and Attorney General consumer-protection alerts on crypto fraud. No independent state FIU exists; Michigan financial institutions rely wholly on federal supervisory and enforcement infrastructure.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness
  4. T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC licence-change
  5. T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: FinCEN — Financial institutions nationwide, including Michigan-based banks and MSBs
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure
  7. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap

#

No Michigan-specific correspondent-banking de-risking event or settlement-access initiative identified; Michigan institutions subject to the same national de-risking pressures, mitigated partly by scale gains from Fifth Third-Comerica.

Standing sub-brief · as of 6 August 2026212 words · last cycle 2026-08-05

Correspondent Banking, Settlement & Access

Michigan-licensed money-service businesses sit within a correspondent-banking and settlement overlay that applies across both bank and non-bank institutions rather than to one access tier alone. FinCEN's Corporate Transparency Act beneficial-ownership rule has narrowed reporting scope to foreign entities only, exempting domestic entities and their beneficial owners; the final rule is pending review at the Office of Management and Budget's Office of Information and Regulatory Affairs since 5 June 2026, a disposition that will determine whether the domestic-entity exemption becomes permanent. Separately, FinCEN's AML/CFT program-effectiveness proposal under 31 CFR Part 1021 would require board-level approval of AML/CFT programs, a documented risk-assessment methodology, and a US-located responsible officer for BSA-regulated institutions, including casinos; the comment period closed on 9 June 2026 and the final rule remains pending.

Periodic update · new data 2026-08-11

Correspondent Banking, Settlement & Access

Michigan-licensed payment and gaming-sector respondents face a widening federal overlay this cycle that bears directly on correspondent-banking settlement and access decisions, even though no Michigan-specific correspondent-banking instrument moved. Two federal developments define the picture. First, the Corporate Transparency Act's beneficial-ownership-information reporting rule now exempts domestic entities and their beneficial owners from reporting, limiting the mandatory disclosure regime to foreign entities only; this High-confidence finding is corroborated directly by FinCEN's own published guidance. Second, the Financial Crimes Enforcement Network's proposed overhaul of AML/CFT program-effectiveness standards under 31 CFR Part 1021 would require board-level governance approval, a documented risk-assessment methodology, and a US-located responsible officer for BSA-regulated institutions, including casinos; this Assessed-confidence proposal's comment period closed June 9, 2026, with the final rule still pending.

The analytical spine of correspondent-banking analysis is the asymmetry between bank and non-bank access: chartered banks generally carry direct, long-standing correspondent relationships and dedicated compliance infrastructure to satisfy a correspondent's due-diligence requirements, while non-bank payment institutions, e-money issuers, and money-services businesses typically access settlement rails indirectly, through a sponsoring bank or a thinner set of correspondent relationships that are more sensitive to shifts in the underlying compliance backdrop. Both federal developments this cycle widen that asymmetry rather than narrow it. The beneficial-ownership reporting narrowing reduces the ownership-transparency information a correspondent can obtain through federal registries when assessing a Michigan-registered non-bank respondent, shifting more of that verification burden onto the correspondent's own customer due-diligence program. The Part 1021 proposal, while nominally targeted at casinos and card clubs rather than non-bank payment institutions directly, raises the governance bar for an entire category of BSA-regulated institution that shares infrastructure and customer bases with Michigan's licensed payments ecosystem, and a correspondent assessing settlement risk for gaming-adjacent payment flows would reasonably read the proposal as raising the compliance standard its respondent must be able to evidence.

Neither development is Michigan-specific in its drafting, but both reach Michigan directly: Michigan's Detroit commercial casinos and tribal gaming operations are Part 1021-regulated institutions, and Michigan-registered payment and money-services entities are subject to the same federal beneficial-ownership reporting rule as any other US-registered entity. The correspondent-banking read for this cycle is accordingly one of federal-overlay tightening on the governance and transparency dimensions, layered onto a licensing framework that itself remains in a modernization-pending state.

Outlook

The Office of Management and Budget's review of the Corporate Transparency Act final rule, expected in the fourth quarter of 2026, and the FinCEN Part 1021 rule's anticipated finalization in the first quarter of 2027, are the two events that will determine whether this cycle's tightening trajectory continues, stabilizes, or reverses. A correspondent bank recalibrating its risk appetite for Michigan-licensed payment and gaming-sector respondents should treat both as live inputs; neither has reached a final, settled state this cycle.

Sources and findings (2)
  1. T1https://www.congress.gov/crs-product/IF10873
  2. T2https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/

#

Trailing 12 months (Jul 2025-Jul 2026) saw major MI-linked M&A: Fifth Third-Comerica, Acrisure-Heartland Payroll Solutions, Rocket Companies-Redfin/Mr. Cooper, and Supreme Lending-Michigan Mutual, alongside continued Detroit fintech seed activity.

Standing sub-brief · as of 7 July 2026221 words · last cycle 2026-10-26

Commercial Intelligence

The trailing twelve months produced a cluster of Michigan-linked commercial events. Fifth Third Bancorp's acquisition of Comerica Incorporated, valued at $10.9-12.7 billion all-stock, was announced 2025-10-06 and closed in February 2026. Acrisure LLC acquired Heartland Payroll Solutions from Global Payments Inc. for $1.1 billion, announced 2025-05-28 and closed 2025-10-01. Rocket Companies closed its $14.2 billion acquisition of Mr. Cooper Group on 2025-10-01, creating a combined mortgage-servicing portfolio of nearly 10 million homeowners, and separately integrated its earlier Redfin acquisition — a deal for which the amount was not publicly disclosed — generating a reported $140 million in cost savings within six months per CEO commentary on Q4 2025 earnings, with employee buyouts offered in March 2026 amid the Redfin/Mr. Cooper integration. Supreme Lending announced its acquisition of Port Huron-based Michigan Mutual around late May 2025; the deal value was not publicly disclosed. On the investment side, Benzinga Ventures invested in Detroit fintech startup Unlock Technologies at seed stage during 2025; the amount was not publicly disclosed.

Periodic update · new data 2026-10-26

Commercial Intelligence & Fintech

The notable commercial-intelligence event is Coinbase Financial Markets, Inc.'s regulatory-stipulation exit from the Michigan sports-related event-contract market, agreed October 7, 2026 and effective for position closure by October 10, 2026. No transaction value is disclosed for this event, as it is a regulatory stipulation rather than a disclosed commercial deal; amount is not applicable to this event type. The stipulation follows an earlier exit by Robinhood from the same Michigan sports-related event-contract product line, establishing a sequential pattern of platform withdrawals from this specific product in this specific state under regulatory pressure.

This is a discrete commercial event tied to a specific platform and a specific state market, distinct from any broader structural trend in the sports-related event-contract sector; no other commercial transaction, funding round, or product launch was identified for Michigan.

Outlook

Whether further CFTC-registered platforms follow the Robinhood/Coinbase pattern of negotiated exit from the Michigan market, or instead continue litigating to a Sixth Circuit resolution as Kalshi has done, is the development to watch for this specific commercial pattern.

1 earlier distinct update(s)
Periodic update · new data 2026-10-18

Commercial Intelligence & Fintech

Coinbase Financial Markets, Inc.'s Michigan sports-related event-contract product line was wound down under a stipulated agreement with the Michigan Gaming Control Board, effective October 10, 2026. No monetary amount was disclosed in connection with this restructuring. The regulatory review by the Michigan Gaming Control Board concluded with the arrangement cleared with conditions: Coinbase ceased offering new sports-related event contracts to Michigan customers and closed out open positions by the effective date, while the MGCB agreed to withhold enforcement pending the outcome of a Sixth Circuit appeal. This follows a similar product wind-down previously agreed by Robinhood for its own Michigan sports-related event-contract offering on September 9, 2026.

Outlook

Whether Kalshi, the remaining operator still offering sports-related event contracts in Michigan under an active injunction, reaches a similar negotiated wind-down or instead prevails on its federal-preemption argument before the Sixth Circuit will determine whether this product line sees a complete exit from the Michigan market or a partial survival contingent on the litigation's outcome.

Sources and findings (6)
  1. T2https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/
  2. T2https://www.crainsdetroit.com/mergers-acquisitions/these-were-largest-michigan-ma-deals-2025
  3. T1https://ir.rocketcompanies.com/news-and-events/press-releases/press-release-details/2025/Rocket-Companies-Closes-14-2-Billion-Acquisition-of-Mr--Cooper/default.aspx
  4. T2https://www.detroitnews.com/story/business/2026/03/20/rocket-companies-offers-buyouts-as-it-integrates-redfin-and-mr-cooper/89243158007/
  5. T3https://www.housingwire.com/articles/supreme-lending-to-acquire-michigan-mutual-sources/
  6. T3https://www.ellty.com/blog/detroit-investors
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Audit trail

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