--- title: "United States – Michigan Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/united-states-michigan/ source_html: /jurisdictions/united-states-michigan/index.html description: "United States – Michigan payments and e-money regulation: 14 modules, 61 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT." generated_at: 2026-10-26T19:20:26Z content_sha256: 01ca505842bf9fe6d998d46de41557b5af3556364deff11375c5ec872c8d0a41 generator: "fe-fleet/md-twin@1.0" --- # United States – Michigan US-MI schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-26 · 14 modules · 61 sourced findings · 11 sources in the cumulative register Download report (PDF) Expand all 14 Modules 0 Moved this cycle 1 Key judgments 2 Open gaps 61 Findings 3 Tier-1 sources Confidence mix 2 confirmed 12 unpopulated (sums to 14 rendered modules; click to filter) No modules moved this cycle. United States federal law that applies in United States – Michigan is covered once, on the [United States](/jurisdictions/united-states/) page. This page covers United States – Michigan’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief Jurisdiction lead brief 1,260 Full executive summary 319 ###### 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. #### Other Developments Municipal kiosk patchwork emerges pending state legislation. Jackson, Michigan banned cryptocurrency kiosks outright under an ordinance effective October 22, 2026, with a 90-day removal window for existing machines, while Port Huron instead adopted an annual kiosk-operator registration requirement due October 1, 2026. This is market-access fragmentation at the municipal level occurring while House Bill 5544 (the Money Transmission Modernization Act) remains pending in Senate committee, having passed the House 97-10 on June 25, 2026 with no further Senate action recorded through October 25, 2026; existing licensees would not be subject to conflicting provisions until July 1, 2027 under the current engrossed text. Sequential market exits from the event-contract product line. Coinbase's stipulated exit follows an earlier exit by Robinhood from the same Michigan sports-related event-contract market, indicating a pattern of CFTC-registered platforms withdrawing the product from Michigan customers under regulatory pressure rather than litigating to a final resolution. #### Cross-Monitor Connections The event-contract litigation sits at the intersection of payments regulation and gambling regulation, since the Michigan Gaming Control Board's enforcement theory treats sports-related event contracts as unauthorized sports wagering regardless of a platform's separate federal commodities registration; this is tracked here as a licensing and market-access matter rather than a gambling-product assessment. The crypto-kiosk licensing gap is a Compliance Technology and Active Defence-adjacent development insofar as HB 5469 would impose blockchain-analytics screening duties on kiosk operators, a financial-crime-control question tracked in parallel by financial-integrity-focused monitoring. #### Outlook The determinative variable for the event-contract litigation track is the Sixth Circuit's eventual ruling on the stayed appeals, which would resolve the federal-preemption question that Coinbase, Kalshi, and other platforms have raised; until then, expect the current pattern of negotiated market exits and injunctions to continue on a platform-by-platform basis. For market access generally, whether House Bills 5469 and 5470 move out of the House Regulatory Reform Committee will determine whether the current municipal kiosk patchwork is preempted by uniform state licensing, and whether HB 5544 advances in Senate committee will determine the pace of the broader money-transmission modernization. 3 earlier updates not shown here. ###### Standing brief · as of 6 August 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal FinCEN's April 2026 notice of proposed rulemaking would overhaul Bank Secrecy Act AML/CFT program-effectiveness standards for institutions regulated under 31 CFR Part 1021, extending to Michigan's casino payment operations. The proposal would require board-level approval of AML/CFT programs, a documented risk-assessment methodology, and a US-located responsible officer for Part 1021 institutions, including casinos. The public comment period closed on 9 June 2026, and the final rule remains pending. If finalized as proposed, this governance-driven, risk-assessment-anchored standard would raise compliance costs for Michigan's Detroit commercial and tribal casino payment operations. This lead signal carries a preliminary confidence rating of probable, reflecting third-tier legal-commentary sourcing pending confirmation of the final rule text. #### Other Developments Michigan continues to license virtual-currency administrators and exchangers as ordinary money transmitters under the Michigan Money Transmission Services Act (MCL 487.1001 et seq.), with no dedicated virtual-currency licence in place. The state's licensing regime sets a minimum net worth requirement of $100,000, scaling toward $1,000,000 as licensees add locations or delegates. This licensing baseline sits alongside a live legislative track: Michigan House Bill 5544 and Senate Bill 835 would adopt the CSBS Money Transmission Modernization Act template, part of a 31-state modernization wave. HB 5544 extends the template to payroll processors, while SB 835 carves out a payroll-processor exemption for agents of the payor. Adoption would align Michigan with the broader MTMA wave while leaving virtual-currency activity licensed as ordinary money transmission rather than under a dedicated crypto framework. These licensing and conduct provisions apply to non-bank money-service businesses and payment or e-money institutions rather than to depository banks. The standing Payments Regulation and Conduct tracker records this MTMA modernization push as a watch item, and the jurisdiction risk tracker for Michigan currently reads stable, with primary-domain coverage spanning licensing, conduct, and correspondent-banking access. Separately, two federal developments overlay Michigan-licensed money-service businesses. FinCEN's Corporate Transparency Act beneficial-ownership rule has narrowed reporting scope to foreign entities only, exempting domestic entities and their beneficial owners; this reduces the beneficial-ownership transparency backdrop against which Michigan-registered payment and gaming-adjacent entities operate. The CTA beneficial-ownership final rule is pending review at the Office of Management and Budget's Office of Information and Regulatory Affairs since 5 June 2026, a disposition that will determine whether the domestic-entity exemption becomes permanent. These federal obligations apply across both bank and non-bank correspondent and settlement relationships touching Michigan-licensed entities. Two coverage gaps remain flagged for this jurisdiction: the full text of a Michigan Gaming Control Board technical bulletin on geolocation compliance has not been retrieved, and the CSBS legislative tracker underlying the MTMA bills is itself classified as a volatile, legislative-cycle source subject to revision. #### Cross-Monitor Connections The FinCEN AML/CFT program-effectiveness NPRM and the CTA beneficial-ownership scope narrowing are both flagged as illicit-finance relevant; original analysis of their financial-crime implications belongs to the Financial Integrity Monitor rather than this brief. This flag reflects high-confidence assessment that both federal developments carry illicit-finance salience beyond the payments-regulation lens applied here. No Sentinel-fed AML/CFT finding surfaced for US-MI this cycle, and coverage gaps were also noted for Michigan-specific merchant-acquiring enforcement and fintech M&A or funding activity. Michigan-specific merchant-acquiring enforcement and any Michigan fintech M&A or funding event remain under-indexed relative to the headline federal coverage captured this cycle. #### Outlook Three forward-dated milestones anchor the Michigan horizon. The MTMA modernization bills, HB 5544 and SB 835, carry an expected disposition around 2026-Q4, on a year-wide uncertainty band reflecting their proposed stage. FinCEN's Part 1021 AML/CFT final rule is expected around 2027-Q1, on a half-year uncertainty band, following the close of its consultation stage. The CTA beneficial-ownership final rule remains pending OMB review, with disposition expected around 2026-Q4 on a half-year uncertainty band; that disposition will determine whether the domestic-entity exemption becomes permanent. Michigan's pending MTMA adoption would align the state with the 31-state CSBS modernization wave, assessed at high confidence, though virtual-currency activity would remain licensed as ordinary money transmission rather than under a dedicated crypto framework. The narrowed CTA beneficial-ownership scope, assessed at high confidence, is judged to reduce the beneficial-ownership transparency backdrop against which Michigan-registered payment and gaming-adjacent entities operate, while the FinCEN Part 1021 governance standard, assessed as an elevated-impact development, is judged likely to raise compliance costs for Michigan's Detroit commercial and tribal casino payment operations if finalized as proposed. Taken together, these three milestones indicate a Michigan payments environment that remains under active reshaping at both the state licensing layer and the federal correspondent-banking overlay, warranting continued monitoring through year-end 2026 and into early 2027. Read full brief · 1260 words ###### Latest update · 26 October 2026 #### Regulatory Status Michigan's payments-regulatory environment is shaped by two parallel developments: escalating litigation against sports-related event-contract platforms, and municipal-level regulation of crypto-conversion kiosks filling a gap left by stalled state legislation. Coinbase Financial Markets, Inc. stipulated with the Michigan Gaming Control Board on October 7, 2026 to stop offering new sports-related event contracts to Michigan customers and close open positions by October 10, 2026, following a September 1, 2026 preliminary injunction against KalshiEX LLC carrying a $500,000-per-day penalty for geolocation/notice non-compliance. Separately, Jackson and Port Huron have adopted differing municipal rules for cryptocurrency kiosks (an outright ban and a registration requirement, respectively) pending state legislation (HB 5469/5470) that would bring kiosk operators under uniform money-transmitter licensing, and House Bill 5544 remains pending in Senate committee as the vehicle for broader money-transmission modernization. #### Outlook The Sixth Circuit's ruling on the stayed event-contract appeals and the progress of HB 5469/5470/5544 through their respective committees are the variables that will determine whether Michigan's current fragmented and litigation-driven posture consolidates into a more uniform state-level framework. 2 earlier updates not shown here. ###### Standing brief · as of 6 August 2026 Written before the update above. Where they differ, the update is the more recent position. #### Regulatory Status Michigan's payments regulatory posture is assessed as stable overall, anchored by ordinary money-transmission licensing of virtual-currency administrators and exchangers under the Michigan Money Transmission Services Act, a pending MTMA modernization track (HB 5544/SB 835), and a federal correspondent-banking and AML/CTA overlay that is evolving independently of state action. The jurisdiction has no dedicated virtual-currency licensing regime. Primary domains of activity this cycle are licensing and market access, conduct and safeguarding, and correspondent banking, settlement and access. #### Outlook Michigan's regulatory direction is assessed as stable, with the MTMA bills' enactment disposition expected around 2026-Q4 and the federal CTA and FinCEN Part 1021 overlays resolving on their own separate timelines through 2027-Q1. Read full brief · 319 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market AccessConfirmedconfirmed 2026-07-05▾# Michigan's money-transmission licensing framework (2006 PA 250, MCL 487.1001-487.1047) is being replaced by the Money Transmission Modernization Act (HB 5544 package, CSBS model law), pending Senate committee since July 1, 2026, with engrossed repeal date July 1, 2027. Horizon · 2027-01-01 (± a quarter) Money Transmission Modernization Act takes effect Adopted · Tier 3 source Horizon · 2027-07-01 (± a quarter) Current Money Transmission Services Act repealed Adopted · Tier 3 source Horizon · 2027-01-01 (± a year) HB 5544 Money Transmission Modernization Act potential enactment Proposed · Tier 1 source Horizon · 2027-07-01 (± a year) Michigan Money Transmission Modernization Act repeal/replace of 2006 PA 250 Proposed · Tier 1 source Horizon · 2027-07-01 (± a quarter) Money Transmission Modernization Act repeal of current MI MTL regime Proposed · Tier 1 source Horizon · 2027-07-01 (± a year) Michigan Money Transmission Modernization Act (HB 5544) repeal/transition date Proposed · Tier 1 source Standing sub-brief · as of 6 August 2026 144 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. #### Outlook This baseline is assessed as stable for now, but Michigan's pending MTMA modernization bills (HB 5544 and SB 835) would revise net-worth, surety-bond, and permissible-investment standards for money transmitters, including virtual-currency administrators and exchangers, without introducing a dedicated virtual-currency licensing regime. Read full sub-brief · 144 words 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. Evidence 7 Sources and findings (7) - T1[https://www.legislature.mi.gov/documents/mcl/pdf/mcl-Act-250-of-2006.pdf](https://www.legislature.mi.gov/documents/mcl/pdf/mcl-Act-250-of-2006.pdf) - T1[https://www.michigan.gov/difs/industry/licensing-cf/money-transmit](https://www.michigan.gov/difs/industry/licensing-cf/money-transmit) - T1[https://origin-sl.michigan.gov/difs/0,5269,7-303-13648_60667_76248---,00.html](https://origin-sl.michigan.gov/difs/0,5269,7-303-13648_60667_76248---,00.html) - T1[https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission](https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission) - T1[https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm](https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm) - T2[https://legiscan.com/MI/text/SB0835/id/3396679](https://legiscan.com/MI/text/SB0835/id/3396679) - T3[https://fraxtional.co/feeds/blog/mi-money-transmitter-license](https://fraxtional.co/feeds/blog/mi-money-transmitter-license) ### W1bConduct, Safeguarding & PromotionsProbableconfirmed 2026-07-05▾# Safeguarding rests on a permissible-investments requirement backed by surety bond, with DIFS examination/confidentiality powers under Section 26. The pending MTMA bill would introduce a statutory trust mechanism over permissible investments for customer benefit in insolvency, a stronger safeguarding model than current law but not yet in force. Standing sub-brief · as of 6 August 2026 143 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Financial Promotions Michigan House Bill 5544 would adopt the full CSBS Money Transmission Modernization Act template, including payroll processors, as part of a 31-state MTMA adoption wave. Companion Senate Bill 835 would adopt the same full MTMA template but with a payroll-processor exemption for agents of the payor. Both bills apply to non-bank money-service businesses and payment or e-money institutions rather than to depository banks, and neither introduces a dedicated virtual-currency licensing regime; Michigan would continue to license virtual-currency administrators and exchangers as ordinary money transmitters. #### Outlook HB 5544 and SB 835 are assessed as a High-confidence, elevated-impact development for Michigan's money-transmission conduct framework, with an expected enactment disposition around 2026-Q4 on a year-wide uncertainty band; Michigan's pending MTMA adoption would align the state with the broader 31-state CSBS modernization wave while leaving virtual-currency activity licensed as ordinary money transmission. Read full sub-brief · 143 words 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. Evidence 4 Sources and findings (4) - T1[https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission](https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission) - T1[https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission](https://www.michigan.gov/difs/news-and-outreach/faq/consumer-finance/money-transmission) - T1[https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm](https://legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm) - T1[https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification](https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification) ### W2Stablecoins & Digital Money1 gapProbableconfirmed 2026-07-05▾# Michigan has no dedicated state-level stablecoin issuance statute; the operative framework is the federal GENIUS Act (signed 2025-07-18), being implemented through OCC, FDIC and joint FinCEN/OFAC rulemakings during 2026, applicable nationwide including to Michigan state-chartered banks. Open gap — wpm-int-2 No 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 rule Consultation · Tier 1 source Horizon · 2026-05-01 (± a quarter) OCC comment period closes on GENIUS Act implementing rule Consultation · Tier 1 source Horizon · 2026-06-09 (± a quarter) FinCEN/OFAC comment period closes on PPSI AML/CFT proposed rule Consultation · Tier 1 source Standing sub-brief · as of 7 July 2026 206 words · last cycle 2026-07-05 #### Stablecoins & Digital Money Michigan has no dedicated state-level stablecoin statute; the operative framework for both bank and non-bank issuers serving Michigan is the federal GENIUS Act, signed into law on 2025-07-18, which establishes a federal framework for payment-stablecoin issuance, operation and regulation applying nationwide. Three implementing rulemakings are proceeding in parallel through 2026. The OCC has proposed a rule governing stablecoin issuance and custody activities of national banks, federal savings associations, federal branches, and federal- or state-qualified payment stablecoin issuers, with comments due 2026-05-01 — a track that directly shapes the issuer pathway available to Michigan state-chartered banks. The FDIC proposed, on 2025-12-19, application requirements and procedures for FDIC-supervised institutions, including Michigan state nonmember banks, to issue payment stablecoins through a subsidiary. And FinCEN and OFAC jointly proposed a rule, with comments due 2026-06-09, treating permitted payment stablecoin issuers as Bank Secrecy Act financial institutions subject to AML and sanctions-compliance obligations. #### Outlook With both the OCC and FinCEN/OFAC comment periods now closed, final rule text and effective dates are the next milestones to watch; these will determine the practical issuance pathway — and compliance burden — for any Michigan-chartered bank or qualified issuer seeking to enter stablecoin issuance ahead of, or absent, any Michigan-specific statute. Read full sub-brief · 206 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.kslaw.com/news-and-insights/stablecoin-legislation-has-left-the-stable](https://www.kslaw.com/news-and-insights/stablecoin-legislation-has-left-the-stable) - T1[https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the](https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the) - T1[https://www.federalregister.gov/documents/2025/12/19/2025-23510/approval-requirements-for-issuance-of-payment-stablecoins-by-subsidiaries-of-fdic-supervised-insured](https://www.federalregister.gov/documents/2025/12/19/2025-23510/approval-requirements-for-issuance-of-payment-stablecoins-by-subsidiaries-of-fdic-supervised-insured) - T1[https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism](https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism) ### W3Operational Resilience & Critical InfrastructureProbableconfirmed 2026-07-05▾# Michigan's operational-resilience layer combines MCL 445.72 breach notification, DIFS cybersecurity event notification (Form FIS 2359), and PA 690 of 2018 for insurance licensees. A five-bill reform package (SB 360-364), passed by the Senate August 2025, would tighten the breach standard to a firm 45-day deadline with new civil penalties; pending in the House as of March 2026. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 7 July 2026 191 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Michigan's operational-resilience layer combines general and sector-specific instruments. The Identity Theft Protection Act (MCL 445.72) requires notice to affected Michigan residents without unreasonable delay upon discovery of a security breach, unless substantial harm is unlikely, with a safe harbor for institutions compliant with federal interagency guidance. DIFS separately requires licensees to notify it within 10 business days of determining a cybersecurity event occurred (Form FIS 2359), under the Michigan Insurance Data Security Law (PA 690 of 2018), alongside an annual compliance-certification filing (Form FIS 2360) due February 15. A five-bill reform package, Senate Bills 360-364, would tighten this standard considerably: a firm 45-day breach-notification deadline, civil fines of up to $2,000, and alignment with NIST CSF 2.0. The package passed the Senate 19-15 on 2025-08-26 and remained pending in the House Committee on Government Operations as of March 2026. #### Outlook Enactment of SB 360-364 would convert Michigan's current "without unreasonable delay" standard into a hard deadline with attached financial penalties, raising both the compliance bar and the enforcement exposure for payments firms operating in the state; its progress through the House is the item to track. Read full sub-brief · 191 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-445-72](https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-445-72) - T1[https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification](https://www.michigan.gov/difs/industry/industry-news/cybersecurity-event-and-attestation-update-notification) - T3[https://www.recordinglaw.com/us-laws/data-privacy-laws/michigan-data-privacy-laws/data-breach-notification/](https://www.recordinglaw.com/us-laws/data-privacy-laws/michigan-data-privacy-laws/data-breach-notification/) - T3[https://www.perkinscoie.com/en/news-insights/security-breach-notification-chart-michigan.html](https://www.perkinscoie.com/en/news-insights/security-breach-notification-chart-michigan.html) ### W4Scheme & Network ComplianceProbableconfirmed 2026-07-05▾# Michigan permits credit-card surcharging (since a 2013 settlement lifted the Visa/Mastercard ban) but imposes state-specific disclosure duties, prohibits debit surcharging, and treats surcharge fees as part of the taxable sales price under the General Sales Tax Act per 2024 Treasury guidance. Standing sub-brief · as of 7 July 2026 97 words · last cycle 2026-07-05 #### Scheme & Network Compliance Michigan merchants have been permitted to surcharge credit-card transactions since a 2013 Visa/Mastercard/bank class-action settlement lifted the contractual surcharging ban; debit-card surcharging remains prohibited under card-network rules and federal law. The Michigan Department of Treasury has determined that credit-card surcharges form part of the taxable "gross proceeds" or "sales price" under the General Sales Tax Act, subjecting them to the state's 6% sales tax. #### Outlook The sales-tax treatment of surcharges adds a distinct compliance layer for Michigan merchants beyond card-network disclosure rules, and is a state-specific wrinkle on an otherwise federally-settled surcharging landscape. Read full sub-brief · 97 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/shopping/credit-debit-card-surcharges](https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/shopping/credit-debit-card-surcharges) - T1[https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-act-379-of-1984](https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-act-379-of-1984) - T2[https://www.nfib.com/news/news/mi-department-of-treasury-to-small-business-credit-card-surcharge-fees-subject-to-sales-tax/](https://www.nfib.com/news/news/mi-department-of-treasury-to-small-business-credit-card-surcharge-fees-subject-to-sales-tax/) - T3[https://www.getnickel.com/surcharge-laws/michigan](https://www.getnickel.com/surcharge-laws/michigan) - T3[https://merchantcostconsulting.com/lower-credit-card-processing-fees/michigan-credit-card-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/michigan-credit-card-surcharge-laws/) ### W5Payment Corridor DynamicsProbableconfirmed 2026-07-05▾# Michigan financial institutions participate in the national FedNow rail; MSUFCU is a documented Michigan participant operating receive-only with planned send-side expansion, reflecting national credit-union-led gradual FedNow adoption rather than Michigan-specific corridor infrastructure. Standing sub-brief · as of 7 July 2026 126 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Michigan State University Federal Credit Union (MSUFCU) participates in the FedNow Service on a receive-only basis, with planned send-side capability, citing gig-worker and student demand for instant access to funds. This sits within a national FedNow expansion in which the service reached more than 1,500 participating financial institutions across all 50 states by late 2025 — a 44% year-on-year increase — with the per-transaction limit raised from $1 million to $10 million effective November 2025. No Michigan-specific corridor infrastructure beyond this national-rail participation was identified this cycle. #### Outlook MSUFCU's stated intent to add send-side capability, and its exploration of further FedNow use cases (see W9), positions it as a bellwether for credit-union-led instant-payments adoption in Michigan rather than evidence of state-specific corridor build-out. Read full sub-brief · 126 words no periodic updates on record for this sub-brief Evidence 2 Sources and findings (2) - T1[https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union](https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union) - T1[https://www.frbservices.org/news/fed360/issues/121625/general-2026-fees-payment-system-enhancements](https://www.frbservices.org/news/fed360/issues/121625/general-2026-fees-payment-system-enhancements) ### W6Industry Structure & CommercialProbableconfirmed 2026-07-05▾# Michigan's payments-adjacent industry structure is being reshaped by Fifth Third's $10.9-12.7bn acquisition of Comerica, alongside a growing Detroit/Ann Arbor fintech and credit-union-fintech-partnership ecosystem (Rocket Companies, Bankjoy, InvestNext, Autobooks, MSUFCU-Zirtue). Standing sub-brief · as of 7 July 2026 163 words · last cycle 2026-07-05 #### Industry Structure & Commercial Dynamics Michigan's payments-adjacent banking structure was reshaped in the review period by Fifth Third Bancorp's $12.7 billion all-stock acquisition of Comerica Incorporated, closed in February 2026. The combination creates the ninth-largest US bank by assets (approximately $288 billion) and makes Fifth Third the largest bank by Michigan and Detroit retail deposit share, with 227 combined Michigan branches remaining after 75 closures. Separately, MSUFCU partnered with fintech Zirtue, integrated with Plaid, to offer a friends-and-family lending platform. Detroit's broader fintech ecosystem includes Autobooks (embedded SMB banking, which raised a $50 million Series C in 2022 plus $40 million in further growth funding), InvestNext, and Y Combinator-backed digital-banking provider Bankjoy. #### Outlook The Fifth Third-Comerica combination is the dominant structural fact shaping Michigan's payments-adjacent banking landscape and will condition deposit concentration, branch access and settlement scale for the state for years to come; the smaller credit-union-fintech partnership activity (MSUFCU-Zirtue) and the Detroit embedded-fintech cluster represent the complementary, lower-scale layer of market development. Read full sub-brief · 163 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T2[https://www.detroitnews.com/story/business/2026/06/01/fifth-third-comerica-bank-branch-closures-michigan/90360145007/](https://www.detroitnews.com/story/business/2026/06/01/fifth-third-comerica-bank-branch-closures-michigan/90360145007/) - T2[https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/](https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/) - T2[https://www.americanbanker.com/creditunions/news/michigan-credit-union-helps-members-borrow-from-friends-and-family](https://www.americanbanker.com/creditunions/news/michigan-credit-union-helps-members-borrow-from-friends-and-family) - T3[https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026](https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026) - T3[https://builtin.com/companies/location/na/usa/mi/type/fintech-companies](https://builtin.com/companies/location/na/usa/mi/type/fintech-companies) ### W7Legal & Litigation1 judgmentConfirmedconfirmed 2026-07-05▾# Michigan's enforcement campaign against prediction-market operators continued: Coinbase stipulated Oct 7, 2026 to halt new MI sports contracts and wind down by Oct 10, 2026; a CFTC interim final rule (eff. Oct 19, 2026) codified that licensed-sportsbook wagers are not CFTC swaps. Key judgment — Probable · impact ELEVATED Michigan'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 2026 137 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. #### Outlook The ruling leaves Michigan's state enforcement track intact in the near term, but the underlying federal preemption questions raised by Polymarket, Robinhood and related litigants remain unresolved; further appellate activity is the item to watch, and the outcome will have implications well beyond Michigan for the state-versus-federal division of authority over event-contract markets. Read full sub-brief · 137 words 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. Evidence 4 Sources and findings (4) - T2[https://michigangaming.com/michigans-fight-over-prediction-markets/](https://michigangaming.com/michigans-fight-over-prediction-markets/) - T2[https://www.gamblinginsider.com/news/115936/michigan-kalshi-lawsuit-polymarket-robinhood-prediction-markets](https://www.gamblinginsider.com/news/115936/michigan-kalshi-lawsuit-polymarket-robinhood-prediction-markets) - T1[https://www.gamblinginsider.com/news/167546/michigan-judge-denies-polymarket-robinhood-injunctions](https://www.gamblinginsider.com/news/167546/michigan-judge-denies-polymarket-robinhood-injunctions) - T3[https://www.playmichigan.com/news/federal-judge-denies-polymarket-bid-to-block-michigan-enforcement/](https://www.playmichigan.com/news/federal-judge-denies-polymarket-bid-to-block-michigan-enforcement/) ### W8Merchant Acquiring & RiskProbableconfirmed 2026-07-05▾# Michigan's merchant-acquiring risk framework is defined largely by consumer-facing surcharge disclosure rules rather than a distinct acquiring-license regime; merchants operate under the general bank-sponsorship/card-network model, with MI-specific obligations concentrated in surcharge signage/receipt/online disclosure. Standing sub-brief · as of 7 July 2026 102 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk Michigan does not operate a distinct merchant-acquiring license regime; fintechs and merchants instead access card networks, wires and ACH through the standard U.S. sponsor-bank model. The state's principal acquiring-adjacent obligations are consumer-facing surcharge rules: signage and disclosure requirements at the store entrance and point-of-sale terminal, and online disclosure at first mention of a credit-card payment option, with surcharges capped at processing cost and prohibited from varying by card brand. #### Outlook Michigan's acquiring-risk framework remains thin relative to a dedicated licensing regime, with surcharge disclosure compliance the primary state-specific obligation layered on top of the national sponsor-bank access model. Read full sub-brief · 102 words no periodic updates on record for this sub-brief Evidence 3 Sources and findings (3) - T3[https://www.getnickel.com/surcharge-laws/michigan](https://www.getnickel.com/surcharge-laws/michigan) - T1[https://www.legislature.mi.gov/documents/2013-2014/billanalysis/House/archive/2013-HLA-4255-74A48DFB.HTM](https://www.legislature.mi.gov/documents/2013-2014/billanalysis/House/archive/2013-HLA-4255-74A48DFB.HTM) - T3[https://www.lithic.com/blog/bank-partners](https://www.lithic.com/blog/bank-partners) ### W9Product Innovation & Market DevelopmentProbableconfirmed 2026-07-05▾# Michigan's product-innovation layer is anchored in Detroit's growing embedded-fintech and credit-union-fintech ecosystem (Autobooks, InvestNext, Bankjoy, MSUFCU FedNow/Zirtue), supported by public seed-stage capital via the City of Detroit's Startup Fund. Standing sub-brief · as of 7 July 2026 106 words · last cycle 2026-07-05 #### Product Innovation & Market Development The City of Detroit launched a $700,000 Startup Fund distributing seed grants of $15,000 and scale grants of $50,000 to Detroit-area startups, including fintechs; a second round in February 2026 awarded $300,000 across 13 startups. Separately, MSUFCU is exploring additional FedNow use cases beyond its current receive-only participation, including indirect auto-loan funding, student-loan refund disbursement, and insurance-payout disbursement. #### Outlook Both threads point to Michigan's product-innovation layer being anchored in public seed capital and credit-union-led instant-payments experimentation rather than a distinct state regulatory sandbox; MSUFCU's use-case expansion is the item most likely to generate further FedNow-linked product activity in the next cycle. Read full sub-brief · 106 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union](https://www.frbservices.org/financial-services/fednow/industry-stories/real-talk/msu-federal-credit-union) - T2[https://detroitmi.gov/news/detroit-launches-first-its-kind-700000-startup-fund-fuel-job-creation-and-talent-retention](https://detroitmi.gov/news/detroit-launches-first-its-kind-700000-startup-fund-fuel-job-creation-and-talent-retention) - T2[https://www.crainsdetroit.com/entrepreneurship/detroits-municipal-startup-fund-awards-its-first-300000](https://www.crainsdetroit.com/entrepreneurship/detroits-municipal-startup-fund-awards-its-first-300000) - T3[https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026](https://www.purpose.jobs/blog/top-tech-companies-in-michigan-2026) ### W10Consumer Protection & APP FraudProbableconfirmed 2026-07-05▾# Michigan consumer protection for payments harms runs through the AG's Consumer Protection Team and DIFS, with active AG alerts targeting P2P payment-app scams and AI voice-cloning fraud; there is no dedicated state APP-fraud reimbursement mandate. Standing sub-brief · as of 7 July 2026 114 words · last cycle 2026-07-05 #### Consumer Protection & APP Fraud The Michigan Attorney General's Consumer Protection Team maintains active alerts warning consumers about peer-to-peer payment-app scams, including "return the money" patterns exploiting stolen funds, directing victims to the app host, the FTC, or the CFPB. In April 2026, during Money Smart Week, Attorney General Dana Nessel reissued an AI Scams consumer alert warning of AI-generated deepfake voice-cloning fraud that impersonates loved ones to solicit payment-app transfers. #### Outlook Michigan has no dedicated state APP-fraud reimbursement mandate; consumer redress for payment-app fraud continues to depend on federal complaint channels (FTC, CFPB) and informal AG-level alerting rather than a statutory liability-shifting regime, leaving a policy gap relative to reimbursement models developed elsewhere. Read full sub-brief · 114 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/scams/payment-apps-and-scams](https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/scams/payment-apps-and-scams) - T1[https://www.michigan.gov/ag/news/press-releases/2026/04/20/ag-nessel-reissues-ai-scams-consumer-alert-during-money-smart-week](https://www.michigan.gov/ag/news/press-releases/2026/04/20/ag-nessel-reissues-ai-scams-consumer-alert-during-money-smart-week) - T1[https://www.michigan.gov/ag/news/press-releases/2024/12/23/ag-nessel-warns-consumers-about-holiday-payment-apps-and-scams](https://www.michigan.gov/ag/news/press-releases/2024/12/23/ag-nessel-warns-consumers-about-holiday-payment-apps-and-scams) - T1[https://www.michigan.gov/ag/consumer-protection](https://www.michigan.gov/ag/consumer-protection) ### W11AML/CFT & Financial Crime1 gapSourced from Sentinel.gi ↗Probableconfirmed 2026-07-05▾# W11 carries the Sentinel.gi feed only; no jurisdiction-specific Sentinel.gi content for US-MI was retrievable this cycle. Standing federal BSA framework layers onto MTSA licensees; no original illicit-finance analysis performed (FIM territory). Open gap — wpm-int-1 No AML/CFT (W11) delta for US-MI was found this cycle. no under-indexing note recorded Standing sub-brief · as of 7 July 2026 133 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime This module is sourced from the Sentinel.gi feed; no Michigan-specific Sentinel.gi content was retrievable via open-web search this cycle. What can be carried is the standing statutory backdrop: Michigan MTSA licensees must maintain a documented AML/BSA compliance program as a continuing condition of licensure, alongside quarterly MSB Call Reports, and both the current MTSA and the pending MTMA incorporate the federal Bank Secrecy Act (Public Law 91-508) and its implementing regulations by reference into state licensing conditions. No original illicit-finance analysis has been performed here; readers seeking substantive AML/CFT intelligence should consult the Sentinel.gi feed directly. #### Outlook Sentinel-fed W11 coverage for Michigan is thin relative to Anglosphere and EU jurisdictions in this feed; this is a known under-indexing pattern rather than a signal that Michigan-specific illicit-finance activity is absent. Read full sub-brief · 133 words no periodic updates on record for this sub-brief Evidence 7 Sources and findings (7) - T1[https://www.legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm](https://www.legislature.mi.gov/documents/2023-2024/billintroduced/House/htm/2024-HIB-5798.htm) - 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. - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness - T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC licence-change - T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: FinCEN — Financial institutions nationwide, including Michigan-based banks and MSBs - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap ### W12Correspondent Banking, Settlement & AccessUncertainconfirmed 2026-07-05▾# No Michigan-specific correspondent-banking de-risking event or settlement-access initiative identified; Michigan institutions subject to the same national de-risking pressures, mitigated partly by scale gains from Fifth Third-Comerica. Standing sub-brief · as of 6 August 2026 212 words · last cycle 2026-08-05 #### Correspondent Banking, Settlement & Access Michigan-licensed money-service businesses sit within a correspondent-banking and settlement overlay that applies across both bank and non-bank institutions rather than to one access tier alone. FinCEN's Corporate Transparency Act beneficial-ownership rule has narrowed reporting scope to foreign entities only, exempting domestic entities and their beneficial owners; the final rule is pending review at the Office of Management and Budget's Office of Information and Regulatory Affairs since 5 June 2026, a disposition that will determine whether the domestic-entity exemption becomes permanent. Separately, FinCEN's AML/CFT program-effectiveness proposal under 31 CFR Part 1021 would require board-level approval of AML/CFT programs, a documented risk-assessment methodology, and a US-located responsible officer for BSA-regulated institutions, including casinos; the comment period closed on 9 June 2026 and the final rule remains pending. #### Outlook The CTA beneficial-ownership final rule's OMB disposition is expected around 2026-Q4 on a half-year uncertainty band. FinCEN's Part 1021 final rule is expected around 2027-Q1 on a half-year uncertainty band. The narrowed CTA scope reduces the beneficial-ownership transparency backdrop for Michigan-registered entities, and the Part 1021 governance standard, if finalized as proposed, would raise compliance costs for Michigan's Detroit commercial and tribal casino payment operations; both developments are flagged as illicit-finance relevant, with original analysis belonging to the Financial Integrity Monitor. Read full sub-brief · 212 words 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. Evidence 2 Sources and findings (2) - T1[https://www.congress.gov/crs-product/IF10873](https://www.congress.gov/crs-product/IF10873) - T2[https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/](https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/) ### W13Commercial Intelligence (M&A, Investment & Product)Probableconfirmed 2026-07-05▾# Trailing 12 months (Jul 2025-Jul 2026) saw major MI-linked M&A: Fifth Third-Comerica, Acrisure-Heartland Payroll Solutions, Rocket Companies-Redfin/Mr. Cooper, and Supreme Lending-Michigan Mutual, alongside continued Detroit fintech seed activity. Standing sub-brief · as of 7 July 2026 221 words · last cycle 2026-10-26 #### 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. #### Outlook The concentration of large, completed M&A around Fifth Third-Comerica and Rocket's mortgage-servicing consolidation marks the highest level of Michigan-linked payments-adjacent deal activity captured this cycle; further integration milestones (Rocket's Redfin/Mr. Cooper buyout program) and any update on the undisclosed-value Supreme Lending-Michigan Mutual and Benzinga-Unlock transactions are the items to track next cycle. Read full sub-brief · 221 words 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. Evidence 6 Sources and findings (6) - T2[https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/](https://www.detroitnews.com/story/business/2025/10/06/fifth-third-bancorp-buy-comerica-10-9-billion-tie-up-big-regional-banks/86545764007/) - T2[https://www.crainsdetroit.com/mergers-acquisitions/these-were-largest-michigan-ma-deals-2025](https://www.crainsdetroit.com/mergers-acquisitions/these-were-largest-michigan-ma-deals-2025) - T1[https://ir.rocketcompanies.com/news-and-events/press-releases/press-release-details/2025/Rocket-Companies-Closes-14-2-Billion-Acquisition-of-Mr--Cooper/default.aspx](https://ir.rocketcompanies.com/news-and-events/press-releases/press-release-details/2025/Rocket-Companies-Closes-14-2-Billion-Acquisition-of-Mr--Cooper/default.aspx) - T2[https://www.detroitnews.com/story/business/2026/03/20/rocket-companies-offers-buyouts-as-it-integrates-redfin-and-mr-cooper/89243158007/](https://www.detroitnews.com/story/business/2026/03/20/rocket-companies-offers-buyouts-as-it-integrates-redfin-and-mr-cooper/89243158007/) - T3[https://www.housingwire.com/articles/supreme-lending-to-acquire-michigan-mutual-sources/](https://www.housingwire.com/articles/supreme-lending-to-acquire-michigan-mutual-sources/) - T3[https://www.ellty.com/blog/detroit-investors](https://www.ellty.com/blog/detroit-investors) No modules match. 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