United States – Idaho Payments & Fintech Regulation

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

Last updated · 14 modules · 106 sourced findings · 136 sources in the cumulative register

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

Jurisdiction brief

Latest update · 4 November 2026

Lead Signal

A bill introduced into the Idaho Senate this year would layer a new state-level tax onto international money transmissions originating in the state, and it has moved far enough through the legislative process to warrant attention even though it remains unenacted. Senate Bill 1440 would require licensed money transmitters to collect a flat $5 charge on the first $500 of an outbound international transfer, plus 4% on any amount above that threshold, with the proceeds remitted quarterly to the state tax authority. The bill was introduced on 26 March 2026 and referred to the Senate's Local Government & Taxation Committee, where it has sat since; nothing in the available record establishes whether it has advanced further. What makes this worth tracking is the stacking effect: this would sit on top of the federal 1% excise tax on remittances that has been in force since the start of 2026, so a transmitter and, ultimately, a sender in Idaho could face two layers of transaction-based tax on the same outbound transfer. For money transmitters operating corridor business out of Idaho, this is a compliance-system question as much as a cost question — a state-specific collection, calculation and quarterly-remittance obligation would need to be built and tested well before any effective date, and the uncertainty about the bill's committee status makes it hard to know how much runway there is to do that.

Key regulatory facts for United States – Idaho
Regulatory DimensionUnited States – Idaho Standing Position
JurisdictionUnited States – Idaho (US-ID)
Regulatory ScopePayments & Fintech Regulation (14 modules, 106 sourced findings)
Licensing, Authorisation & Market AccessVirtual-currency kiosk/exchange activity in Idaho continues to be governed solely by the generic Idaho Money Transmitters Act (Idaho Code § 26-2901 et seq.), administered by the Securities Bureau, Idaho Department of...
Conduct, Safeguarding & PromotionsIdaho's safeguarding mechanism for money transmitters is a scaled security device (surety bond, irrevocable letter of credit, or similar), not a UK/EU-style client-money segregation or trust regime.
Stablecoins & Digital MoneyIdaho has no enacted stablecoin-specific statute as of the baseline date.
Operational Resilience & Critical InfrastructureIdaho has no state-specific operational-resilience statute for payments; state-chartered banks/credit unions are examined under the federal/CSBS InTREx framework and FFIEC guidance.
Primary Instruments CitedUnited States – Idaho Official Instrument (finance.idaho.gov money-transmitters), United States – Idaho Official Instrument (finance.idaho.gov Money-20Transmitters-20Act-pdf), United States – Idaho Official Instrument (bondexchange.com idaho-money-transmitter-bond-a-c), United States – Idaho Official Instrument (finance.idaho.gov 2025-12-02-Apex-Order-of-Denial-), United States – Idaho Official Instrument (billtrack50.com 1983173)
Last Confirmed / Updated2026-11-04 (136 sources in cumulative register)

#

Virtual-currency kiosk/exchange activity in Idaho continues to be governed solely by the generic Idaho Money Transmitters Act (Idaho Code § 26-2901 et seq.), administered by the Securities Bureau, Idaho Department of Finance. A 2026 attempt to layer kiosk-specific licensing/AML obligations (SB1359a) passed the legislature but was vetoed by Gov. Little on April 8-9, 2026, preserving the status quo.

Horizon · 2027-Q1 (± a year)Possible redrafted Idaho Virtual Currency Kiosk Fraud Prevention ActProposed · Tier 1 source
Horizon · 2027-Q1 (± a year)Idaho excise tax on international money transmissions (S1440)Proposed · Tier 1 source
Standing sub-brief · as of 7 July 2026 325 words · last cycle 2026-11-03

Licensing, Authorisation & Market Access

Idaho's non-bank payments licensing gateway is unified under the Idaho Money Transmitters Act (Idaho Code Title 26, Chapter 29), administered by the Securities Bureau of the Idaho Department of Finance. The Act covers non-bank money transmitters, stored-value issuers/sellers, and virtual-currency exchangers, requiring each to hold an Idaho Money Transmitter Licence. Minimum capitalisation and bonding thresholds require net worth of at least $50,000, rising $25,000 per branch to a maximum of $250,000, alongside a surety bond of at least $10,000, rising $5,000 per branch to a maximum of $500,000. Enforcement of this gateway is active rather than merely nominal: the Department of Finance denied Apex Capital Enterprises LLC's licence application for failing the Act's net-worth qualification requirements under Idaho Code 26-2916. An independent baseline-research verification challenge dated 2026-07-05 flagged that the cited order PDF's stated date (2025-12-02) may not match the Department's administrative-action page metadata, which reportedly shows a last-update of 2025-08-22; the precise order date is therefore treated as unconfirmed pending re-verification, though the underlying enforcement fact -- a denial for net-worth failure -- is not itself disputed.

Periodic update · new data 2026-11-03

Licensing, Authorisation & Market Access

Idaho's licensing framework for money transmission remains anchored in the state's general Money Transmitters Act, with no movement toward the Conference of State Bank Supervisors' Money Transmission Modernization Act, the harmonising model law that by September 2026 had been enacted in some form by thirty-one states. Idaho is not among that group, and no legislative activity suggests that is changing. For a licensee already authorised in Idaho, this means the state's statutory text, examination approach, and bonding/net-worth requirements continue to sit outside the increasingly standardised multistate model, so a multistate licensee must continue to read Idaho's provisions on their own terms rather than assume the Model Act's language controls.

The one piece of live legislative movement touching market access and the licensed-transmitter population is Senate Bill 1440, introduced to impose a new excise charge on outbound international money transmission. Although the measure is fiscal rather than licensing in character, it operates directly on the population of entities licensed to transmit money internationally from Idaho, since it is the licensed transmitter who is made responsible for collecting the charge and remitting it quarterly to the Idaho State Tax Commission. The bill was reported printed and referred to the Local Government and Taxation committee on 27 March 2026; there is no record of it having advanced beyond that referral.

Outlook

Whether Senate Bill 1440 is reported out of committee before the legislative session closes is the operative question for licensed transmitters serving international corridors out of Idaho. Absent enactment, no change to the underlying licensing regime is in prospect, and Idaho's continued non-adoption of the Money Transmission Modernization Act means multistate licensees should expect to keep treating Idaho as a bespoke jurisdiction within their compliance mapping rather than one folded into the harmonised model.

4 earlier distinct update(s)
Periodic update · new data 2026-10-25

Licensing, Authorisation & Market Access

Idaho's market-access framework for payment and money-transmission businesses is anchored in the Money Transmitters Act, Idaho Code Section 26-2901 et seq., which requires any person engaging in the business of money transmission in Idaho, absent a narrow exemption under Idaho Code Section 26-2904, to hold a state licence. This statute is unchanged but forms the necessary backdrop to two fresh Department of Finance decisions that show the licensing gateway in active operation.

First, the Department entered an Agreement and Order with Rockwallet LLC in April 2026, resolving findings that the firm had engaged in the business of money transmission in Idaho without a licence from at least April 2023 through the date of the order. No monetary penalty was disclosed as part of the resolution. Second, and separately, the Department denied a money-transmitter licence application submitted by PayKES L.L.C., dated March 25, 2026, on the ground that the applicant failed to meet the statutory net-worth and financial-responsibility requirements set out in Idaho Code Sections 26-2905 and 26-2910. Together these two decisions illustrate both ends of the licensing gateway's function: enforcement against an entity that operated without ever obtaining a licence, and gatekeeping against an applicant that sought a licence but could not meet the capital-adequacy bar.

Alongside this enforcement and licensing activity, the Idaho Legislature enacted the Distributed Ledger Technology Act, Senate Bill 1296, signed by the Governor on March 19, 2026, designated Session Law Chapter 78, and effective July 1, 2026. The Act establishes a right for individuals to self-custody software or hardware cryptocurrency wallets and to operate distributed-ledger technology nodes, and bars state or local governing bodies from enacting an ordinance, resolution, or rule that would prohibit, restrict, or otherwise impair those activities. Critically, this protection is framed around individual activity, not commercial money-transmission services, and the Act sits alongside the pre-existing Money Transmitters Act licensing regime without displacing or narrowing it. A business conducting money transmission, including a virtual-currency exchange or custodial service, continues to require a licence under the existing statute regardless of the DLT Act's individual-rights protections.

The net effect for market participants is a bifurcated but coherent structure: individuals retain a newly-codified right to self-custody and run nodes without governmental interference, while commercial money-transmission activity, whether fiat or virtual-currency denominated, remains subject to the Money Transmitters Act's licensing, net-worth, and bonding requirements, which the Department has shown it continues to enforce both against unlicensed incumbents and against under-capitalised applicants.

Outlook

The Department of Finance's enforcement posture toward unlicensed virtual-currency money transmission, evidenced by the Rockwallet order, and its gatekeeping posture toward under-capitalised licence applicants, evidenced by the PayKES denial, both point toward continued active administration of the existing statutory licensing gateway rather than any near-term change to the underlying legal standard. The DLT Act's self-custody and node-operation protections, now in force since July 1, 2026, establish a durable individual-rights boundary that licensing decisions and any future legislative activity will need to respect, without altering the licensing obligations that apply to commercial money-transmission businesses operating in the state.

Periodic update · new data 2026-10-11

Licensing, Authorisation & Market Access

Idaho's market-access framework for payment and money-transmission businesses is anchored in the Money Transmitters Act, Idaho Code Section 26-2901 et seq., which requires any person engaging in the business of money transmission in Idaho, absent a narrow exemption under Idaho Code Section 26-2904, to hold a state licence. This statute is unchanged this cycle but forms the necessary backdrop to two fresh Department of Finance decisions that show the licensing gateway in active operation.

First, the Department entered an Agreement and Order with Rockwallet LLC in April 2026, resolving findings that the firm had engaged in the business of money transmission in Idaho without a licence from at least April 2023 through the date of the order. No monetary penalty was disclosed as part of the resolution. Second, and separately, the Department denied a money-transmitter licence application submitted by PayKES L.L.C., dated March 25, 2026, on the ground that the applicant failed to meet the statutory net-worth and financial-responsibility requirements set out in Idaho Code Sections 26-2905 and 26-2910. Together these two decisions illustrate both ends of the licensing gateway's function: enforcement against an entity that operated without ever obtaining a licence, and gatekeeping against an applicant that sought a licence but could not meet the capital-adequacy bar.

Alongside this enforcement and licensing activity, the Idaho Legislature enacted the Distributed Ledger Technology Act, Senate Bill 1296, signed by the Governor on March 19, 2026, designated Session Law Chapter 78, and effective July 1, 2026. The Act establishes a right for individuals to self-custody software or hardware cryptocurrency wallets and to operate distributed-ledger technology nodes, and bars state or local governing bodies from enacting an ordinance, resolution, or rule that would prohibit, restrict, or otherwise impair those activities. Critically, this protection is framed around individual activity, not commercial money-transmission services, and the Act sits alongside the pre-existing Money Transmitters Act licensing regime without displacing or narrowing it. A business conducting money transmission, including a virtual-currency exchange or custodial service, continues to require a licence under the existing statute regardless of the DLT Act's individual-rights protections.

The net effect for market participants is a bifurcated but coherent structure: individuals retain a newly-codified right to self-custody and run nodes without governmental interference, while commercial money-transmission activity, whether fiat or virtual-currency denominated, remains subject to the Money Transmitters Act's licensing, net-worth, and bonding requirements, which the Department has shown this cycle it continues to enforce both against unlicensed incumbents and against under-capitalised applicants.

Outlook

The Department of Finance's enforcement posture toward unlicensed virtual-currency money transmission, evidenced by the Rockwallet order, and its gatekeeping posture toward under-capitalised licence applicants, evidenced by the PayKES denial, both point toward continued active administration of the existing statutory licensing gateway rather than any near-term change to the underlying legal standard. The DLT Act's self-custody and node-operation protections, now in force since July 1, 2026, establish a durable individual-rights boundary that licensing decisions and any future legislative activity will need to respect, without altering the licensing obligations that apply to commercial money-transmission businesses operating in the state.

Periodic update · new data 2026-09-28

Licensing, Authorisation & Market Access

Idaho's money-transmitter licensing framework, administered by the Idaho Department of Finance's Securities Bureau under the Idaho Money Transmitters Act (Idaho Code §26-2901 et seq.), remains the operative gateway for non-bank payment institutions in the state, requiring a surety bond scaling from $10,000 to $500,000 depending on transaction volume plus a minimum net-worth threshold. No change to those bonding or net-worth figures was reported this cycle; the framework's structural stability is the backdrop against which this cycle's one material development occurred.

That development is Idaho Senate Bill 1440, introduced in the 2026 session, which would have imposed a new excise tax on international money-transmission transactions: a flat $5 fee on transfers under $500, and a 4% tax on the portion of any transaction exceeding $500, collected at the point of transaction by the licensed transmitter and remitted quarterly to the Idaho State Tax Commission. The bill would not have altered who needs a license or the terms of licensure -- it targets the transaction itself, layering a new state revenue mechanism on top of the existing licensing perimeter rather than touching the perimeter itself. This is a nonbank_pi_emi-facing measure: it speaks to licensed money transmitters specifically, the category under which non-bank payment institutions and e-money-adjacent transmitters in Idaho operate, and does not engage bank-channel payment activity.

Procedurally, S1440 was referred to the Senate Local Government & Taxation Committee on March 27, 2026, and received no further recorded floor action before the 2026 session adjourned on April 2, 2026. The bill is therefore stalled rather than rejected: it did not receive a committee vote that killed it outright, nor did it reach the floor for a vote that failed. That distinction matters for how the finding should be read going into future sessions -- a bill that dies in adjournment without a negative committee vote is procedurally live to be reintroduced with the same or similar text in a subsequent session, whereas an outright floor defeat would signal a harder political ceiling.

Outlook

The licensing and bonding framework itself shows no sign of near-term change and should be treated as stable. The excise-tax proposal is the item to track: its structure -- transmitter-collected, transaction-tiered, remitted quarterly -- is a template that could be reintroduced largely intact in a future Idaho legislative session, and the committee-stage stall (rather than a decisive defeat) leaves that reintroduction path open. Firms holding or seeking Idaho money-transmitter licenses with material international-transfer volume should treat this as a watch item for the next session rather than a resolved question.

Periodic update · new data 2026-09-22

Licensing, Authorisation & Market Access

Idaho SB1359a, the Virtual Currency Kiosk Fraud Prevention Act, was vetoed by Governor Little on April 8-9, 2026. The bill would have created a new Chapter 54 under Title 28 of the Idaho Code, imposing kiosk-specific licensing conditions on top of the existing money-transmitter framework: mandatory blockchain-analytics and tracing software, capped new-customer transactions, a delayed first-transaction settlement window, and fraud-related fee refunds. Following the veto, virtual-currency kiosk and exchange operators in Idaho continue to access the market through the same non-bank money-transmitter licensing pathway, Idaho Code § 26-2901 et seq., administered by the Securities Bureau of the Idaho Department of Finance, carrying no exemption and no kiosk-specific authorization tier.

This is explicitly a non-bank market-access story: the licensing lane in question is the nonbank payment-institution and e-money-institution lane, not a bank charter, and the veto leaves that lane's contours unchanged. No new capital, bonding, or conduct-of-business condition attaches to kiosk operation as a result of this cycle's development; the market-access bar for entering Idaho's virtual-currency kiosk business remains exactly what it was before the bill was introduced.

Outlook

A redrafted Virtual Currency Kiosk Fraud Prevention Act addressing the Governor's stated drafting deficiencies could reach the Idaho Legislature in the 2027 session. If enacted, it would introduce Idaho's first kiosk-specific licensing overlay on the non-bank money-transmitter regime. Until then, market access for virtual-currency kiosk operators in Idaho remains governed by the generic framework alone.

Sources and findings (21)
  1. T1https://www.finance.idaho.gov/securities-bureau/money-transmitters/retrieved
  2. T1https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdfretrieved
  3. T3https://www.bondexchange.com/idaho-money-transmitter-bond-a-comprehensive-guide/retrieved
  4. T1https://www.finance.idaho.gov/wp-content/uploads/2023/09/2025-12-02-Apex-Order-of-Denial.pdfretrieved
  5. T2https://www.billtrack50.com/billdetail/1983173retrieved
  6. T1https://www.finance.idaho.gov/securities-bureau/money-transmitters/retrieved
  7. T1Idaho SB1359a (Virtual Currency Kiosk Fraud Prevention Act) — Idaho SB1359a (Virtual Currency Kiosk Fraud Prevention Act) — Vetoed by Gov. Little 2026-04-08/09; would have created Chapter 54, Title 28, Idaho Code requiring kiosk operators to hold money-transmitter licences, deploy blockchain analytics, cap new-customer transactions, delay first settlement 72 hours, and provide fraud refunds.retrieved
  8. T1Idaho Money Transmitters Act, Idaho Code § 26-2901 et seq. — Idaho Money Transmitters Act, Idaho Code § 26-2901 et seq. — Standing generic licensing regime administered by the Securities Bureau, Idaho Department of Finance, applicable to virtual-currency exchangers/kiosk operators absent kiosk-specific overlay.retrieved
  9. T1Idaho Department of Finance Securities Bureau — Idaho Department of Finance Securities Bureau — non-bank money transmitters, stored-value issuers/sellers, and virtual-currency exchangers under the Idaho Money Transmitters Act (Idaho Code Title 26, Chapter 29)retrieved
  10. T3Idaho Money Transmitters Act — Idaho Money Transmitters Act — net worth of at least $50,000 (+$25,000/branch, max $250,000) and a surety bond of at least $10,000 (+$5,000/branch, max $500,000)retrieved
  11. T2Senate Bill 1359 (2026) — Senate Bill 1359 (2026) — the existing MTL regime (Chapter 29, Title 26), requiring virtual-currency kiosk operators to hold an Idaho money-transmitter license -- passed both chambers but subsequently vetoed (see W7/W10)retrieved
  12. T1Idaho Senate Bill 1440 (2026) — Idaho Senate Bill 1440 (2026) — $5 flat fee under $500 and 4% excise tax above $500 per international money-transmission transaction, collected by licensed transmitters and remitted quarterly to the Idaho State Tax Commission.retrieved
  13. T2Idaho Senate Bill 1440 (2026) — Idaho Senate Bill 1440 (2026) — Referred to Senate Local Government & Taxation on March 27, 2026; the 2026 session adjourned April 2, 2026 with no further recorded floor action.retrieved
  14. T1Idaho Department of Finance Securities Bureau — Idaho Department of Finance Securities Bureau — Requires money-transmitter licensing under the Idaho Money Transmitters Act (Idaho Code §26-2901 et seq.), including a surety bond ($10,000-$500,000 depending on transaction volume) and minimum net worth; no change to bonding thresholds this cycle.retrieved
  15. T1Idaho Money Transmitters Act — Idaho Money Transmitters Act — Idaho Code §26-2903(1) requires a money-transmitter licence for anyone engaging in the business of money transmission in Idaho, absent a §26-2904 exemption.retrieved
  16. T1Rockwallet LLC — Idaho Department of Finance entered an Agreement and Order with Rockwallet LLC (April 2026) resolving unlicensed money-transmission findings dating from April 2023.retrieved
  17. T1PayKES L.L.C. — Idaho Department of Finance denied PayKES L.L.C.'s money-transmitter licence application (dated 2026-03-25) for failing the statutory net-worth and financial-responsibility tests under Idaho Code §§26-2905, 26-2910.retrieved
  18. T1Distributed Ledger Technology Act (S1296) — Distributed Ledger Technology Act (S1296) — Idaho's Distributed Ledger Technology Act was signed by the Governor on 2026-03-19, Session Law Chapter 78, effective 2026-07-01, enacting rights to self-custody DLT private/public keys and to run DLT nodes; it sits alongside the pre-existing MTL licensing regime without displacing it.retrieved
  19. T3Idaho Money Transmitters Act, Idaho Code Title 26, Chapter 29 — Idaho Money Transmitters Act, Idaho Code Title 26, Chapter 29 — Idaho has not adopted the Money Transmission Modernization Act; money transmitters, including virtual-currency exchangers under Department of Finance administrative policy, remain licensed under the original 1994 statute, with a 180-day deemed-approval clock under section 26-2910.retrieved
  20. T1Idaho SB 1440 (international money transmission excise tax) — Idaho SB 1440 (international money transmission excise tax) — SB 1440, which would have imposed a $5-plus-4% state excise tax on international money transmissions originating in Idaho, died when the legislature adjourned sine die on 2026-04-02 without advancing past Senate committee referral.retrieved
  21. T3Idaho (CSBS Money Transmission Modernization Act adoption status) — Idaho (CSBS Money Transmission Modernization Act adoption status) — Idaho has not enacted the CSBS Money Transmission Modernization Act; 31 states had enacted it in whole or part as of September 2026.retrieved

#

Idaho's safeguarding mechanism for money transmitters is a scaled security device (surety bond, irrevocable letter of credit, or similar), not a UK/EU-style client-money segregation or trust regime. Conduct/promotions are governed generically by the Idaho Consumer Protection Act, enforced by the Attorney General.

Open gap — wpm-int-3W1b financial-promotion-enforcement sweep for US-ID was not actively resolved this cycle.no under-indexing note recorded
Standing sub-brief · as of 7 July 2026 204 words · last cycle 2026-07-05

Conduct, Safeguarding & Promotions

Idaho money transmitters must furnish a safeguarding security device of at least $10,000, increasing $5,000 per branch to a maximum of $500,000, running to the state for the benefit of claimants against the licensee under Idaho Code 26-2908. This is a bond/security-device model, not a UK/EU-style client-money trust or segregation regime -- a materially different consumer-protection architecture from jurisdictions that mandate ring-fenced safeguarding accounts. There is no dedicated payments financial-promotions regime in Idaho; conduct and promotional practices are instead governed generically by the Idaho Consumer Protection Act (Title 48, Chapter 6), enforced through Attorney General Consumer Protection Division civil enforcement and private rights of action for unfair or deceptive acts or practices.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T1https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdfretrieved
  2. T3https://idaholegalservicesauthority.com/idaho-consumer-protection-lawretrieved
  3. T1https://www.ag.idaho.gov/consumer-protection/retrieved
  4. T1https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/Money%20Transmitters%20Act.pdfretrieved
  5. T2https://www.billtrack50.com/billdetail/1983173retrieved
  6. T1Idaho money transmitters — Idaho money transmitters — at least $10,000 (increasing $5,000 per branch, max $500,000), running to the state for the benefit of claimants against the licensee (Idaho Code 26-2908) -- a bond/security-device model, not a UK/EU-style client-money trust or segregation regimeretrieved
  7. T1Idaho Consumer Protection Act (Title 48, Chapter 6) — Idaho Consumer Protection Act (Title 48, Chapter 6) — Attorney General Consumer Protection Division civil enforcement and private rights of action for unfair or deceptive acts/practices, in absence of a dedicated payments financial-promotions regimeretrieved

#

Idaho has no enacted stablecoin-specific statute as of the baseline date. A GENIUS Act-aligned framework was introduced repeatedly in the 2026 session (HB586/821/901, SB1423) but none enacted. A separate Bitcoin/digital-asset rights framework (SB1296, 2024) is in force.

Open gap — wpm-int-1W2/W9 emerging-rails sweep for US-ID was not actively resolved this cycle due to pooled search-budget allocation to crypto/AML threads.US state-level divergence coverage was limited to W1a this cycle.
Standing sub-brief · as of 7 July 2026 224 words · last cycle 2026-07-05

Stablecoins & Digital Money

Idaho has no enacted stablecoin-specific statute as of the baseline date. The 2026 legislative session saw four separate bills addressing stablecoins introduced -- HB 586, HB 821, HB 901, and Senate Bill 1423 (the FAST Act) -- continuing a pattern of repeated but unsuccessful attempts to legislate a GENIUS-Act-aligned state framework. SB 1423 passed the Senate but died without a House hearing, leaving Idaho without an enacted framework. Lobbying around the stablecoin push was active: World Liberty Financial disclosed hosting Idaho legislators (see W13).

no periodic updates on record for this sub-brief

Sources and findings (8)
  1. T3https://www.eastidahonews.com/2026/04/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/retrieved
  2. T2https://idahofreedom.org/house-bill-821-fast-act-stablecoins/retrieved
  3. T3https://idahocapitalsun.com/2026/04/21/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/retrieved
  4. T1https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdfretrieved
  5. T1https://legislature.idaho.gov/wp-content/uploads/sessioninfo/2024/legislation/S1296.pdfretrieved
  6. T1https://www.finance.idaho.gov/securities-bureau/money-transmitters/retrieved
  7. T3Idaho Senate Bill 1423 (2026, FAST Act) — Idaho Senate Bill 1423 (2026, FAST Act) — Idaho without an enacted GENIUS-Act-aligned state stablecoin framework as of the baseline date (four bills introduced in the 2026 session: HB 586, HB 821, HB 901, SB 1423; none enacted)retrieved
  8. T1Idaho Senate Bill 1296 (2024) — Idaho Senate Bill 1296 (2024) — self-custody, Bitcoin mining, and Bitcoin node-running without state/local government restriction (new chapter, Title 28, Idaho Code), a digital-asset-rights layer distinct from the still-pending stablecoin frameworkretrieved

#

Idaho has no state-specific operational-resilience statute for payments; state-chartered banks/credit unions are examined under the federal/CSBS InTREx framework and FFIEC guidance.

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 2026 131 words · last cycle 2026-07-05

Operational Resilience & Critical Infrastructure

Idaho has no state-specific operational-resilience statute for payments equivalent to a DORA- or PS21/3-style regime. Idaho-chartered banks and credit unions instead undergo IT/cyber-risk examination through the interagency InTREx programme (FDIC/CSBS/Federal Reserve), relying entirely on the federal examination stack rather than any state rule. That federal stack itself shifted during the baseline period: the FFIEC's Cybersecurity Assessment Tool sunset on August 31, 2025, redirecting Idaho-chartered institutions toward the NIST Cybersecurity Framework 2.0 and sector tools such as the Cyber Risk Institute Profile.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.finance.idaho.gov/consumer-education-r/cybersecurity-and-identity-theft-prevention/retrieved
  2. T1https://oig.federalreserve.gov/reports/board-cybersecurity-community-banking-may2025.pdfretrieved
  3. T3https://www.bdo.com/insights/assurance/what-the-sunset-of-ffeics-cybersecurity-assessment-tool-means-for-financial-institutionsretrieved
  4. T3https://its.idaho.gov/opportunities-initiatives/retrieved
  5. T1Idaho-chartered banks and credit unions — Idaho-chartered banks and credit unions — the interagency InTREx program (FDIC/CSBS/Federal Reserve) rather than any Idaho payments-specific operational-resilience statuteretrieved
  6. T3FFIEC Cybersecurity Assessment Tool (CAT) — FFIEC Cybersecurity Assessment Tool (CAT) — August 31, 2025, redirecting Idaho-chartered institutions toward NIST Cybersecurity Framework 2.0 and sector tools such as the Cyber Risk Institute Profileretrieved

#

Idaho imposes no state-specific card-scheme or interchange regulation; surcharging is legal statewide subject only to federal card-brand caps. Repeated attempts (2023, 2025) to bar interchange on the tax/gratuity portion have failed.

Standing sub-brief · as of 7 July 2026 140 words · last cycle 2026-07-05

Scheme & Network Compliance

Idaho merchants operate under a permissive surcharge regime, subject only to federal card-network caps -- Visa's 3% cap and Mastercard's 4% cap, or actual cost if lower -- with no state-specific surcharge statute. This permissive posture is consistent with the state's own use of card fees, including in courts and the Tax Commission. A second consecutive attempt to restrict interchange scope, Senate Bill 1055 (2025), which would have prohibited card processors from charging interchange on the tax or gratuity portion of a transaction under a proposed new Idaho Code 63-3643, failed to pass, following a near-identical failed 2023 bill (SB 1066).

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://codes.findlaw.com/id/title-31-counties-and-county-law/id-st-sect-31-3221retrieved
  2. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/idaho-surcharge-laws/retrieved
  3. T2https://idahofreedom.org/senate-bill-1055-electronic-payments-taxes-fees/retrieved
  4. T1https://www.sco.idaho.gov/LivePages/fiscal-policies-credit-card-fees.aspxretrieved
  5. T3Idaho merchants — Idaho merchants — federal card-network caps (Visa 3%/Mastercard 4% or actual cost, whichever is lower), with no state-specific surcharge statuteretrieved
  6. T2Idaho Senate Bill 1055 (2025) — Idaho Senate Bill 1055 (2025) — the tax or gratuity portion of a transaction (new Idaho Code 63-3643); failed to pass, following a near-identical failed 2023 bill (SB 1066)retrieved

#

Idaho has no state-run payment corridor or rail; cross-border/interstate settlement flows through federal rails and correspondents. The 2024 D. Idaho PayServices Bank ruling confirms Fed discretion over master-account access.

Open gap — wpm-int-4Whether S1440 has advanced past committee since 2026-03-27 was not established this cycle.US state-level legislative-process depth is a bias-correction under-index area; primary bill-text/floor-vote sourcing recommended for future cycles.
Horizon · 2026-Q4 (± a year)Idaho S1440 remittance excise tax pending in committeeProposed · Tier 1 source
Standing sub-brief · as of 7 July 2026 173 words · last cycle 2026-11-01

Payment Corridor Dynamics

Idaho has no state-run payment corridor or rail; cross-border and interstate settlement flows through federal rails -- Fedwire, FedNow, and ACH -- and correspondent banking relationships. The Idaho Money Transmitters Act nonetheless brings outbound cross-border remittance corridors within the state's licensing scope, since it licenses money transmission both within the United States and to locations outside the United States. The corridor-access landscape nationally is shaped by a precedent that originated in Idaho's federal district: the U.S. District Court for the District of Idaho held, in PayServices Bank v. Federal Reserve Bank of San Francisco, that FRBSF had discretion under 12 U.S.C. 342 to deny a master-account request, confirming Federal Reserve Banks' near-unfettered discretion over direct settlement-rail access nationally.

Periodic update · new data 2026-11-04

Payment Corridor Dynamics

Idaho Senate Bill 1440 proposes a new state-level excise tax on international money transmissions originating in the state. As drafted, the tax structure is a flat $5 on the first $500 of a transmission plus 4% on any amount transmitted above $500, to be collected by the licensed money transmitter handling the transfer and remitted quarterly to the Idaho State Tax Commission. The bill was introduced on 26 March 2026 and referred to the Senate Local Government & Taxation Committee; it has not been enacted, and the available record does not establish whether it has moved past that committee stage since referral.

The significance of this proposal lies in where it would sit relative to existing federal law. A federal excise tax of 1% on remittance transfers has applied since 1 January 2026. If S1440 were enacted as drafted, an outbound international transfer originating in Idaho above $500 would be subject to both the federal 1% charge and the new state-level $5-plus-4% structure, compounding the effective cost of moving money out of the state through licensed transmitter channels. This is a corridor-level cost and compliance question distinct from Idaho's general money-transmitter licensing framework: it does not change who needs a licence, but it would change what a licensed transmitter must calculate, collect and remit on a qualifying transaction, and on what cadence.

No information in the current record indicates whether other states are considering parallel measures, nor whether Idaho's bill is modelled on an existing enacted scheme elsewhere. The proposal is fiat-remittance-focused on its face; nothing in the bill text available distinguishes treatment by payment rail or by the sending channel used.

Outlook

The near-term question is procedural: whether the Local Government & Taxation Committee advances S1440 before the end of the current session, lets it lapse, or it is revived in a later session. Firms operating remittance corridors through Idaho-licensed money transmitters should treat the stacking of a new state tax on top of the existing federal remittance excise as a live possibility for compliance-system planning, even while the bill remains in committee and its ultimate fate is unresolved.

1 earlier distinct update(s)
Periodic update · new data 2026-11-03

Payment Corridor Dynamics

The dynamics of international remittance corridors routed through Idaho-licensed transmitters face a prospective new cost layer under Senate Bill 1440. The bill would impose a flat $5 charge on the first $500 of an international money transmission, plus 4% on amounts transmitted above that threshold, collected by the licensed transmitter and remitted quarterly to the Idaho State Tax Commission. Because this would sit on top of the existing federal 1% remittance transfer tax, the combined effect for a consumer sending a mid-sized transfer internationally from Idaho would be a materially higher total charge than the federal tax alone, with the state-level component weighted more heavily toward smaller transfers given its flat-fee structure on the first $500.

The bill was reported printed and referred to the Local Government and Taxation committee on 27 March 2026 and has not been reported to have advanced further since. It remains a proposal: no excise obligation currently applies, and nothing in the record to date indicates whether the committee will report it favourably, amend it, or decline to act on it before the session ends.

Outlook

If Senate Bill 1440 is enacted, outbound international remittance corridors passing through Idaho-licensed money transmitters would see a direct increase in the all-in cost of sending money abroad, layered on top of the federal remittance tax, with the proportional effect heaviest on smaller-value transfers because of the flat $5 component. Absent enactment, no change to corridor economics is expected, and the relevant question for the next reporting period is simply whether the bill clears committee.

Sources and findings (7)
  1. T1https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/retrieved
  2. T1https://www.finance.idaho.gov/securities-bureau/money-transmitters/retrieved
  3. T1https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/retrieved
  4. T1Idaho Money Transmitters Act — Idaho Money Transmitters Act — both within the United States and to locations outside the United States, bringing outbound cross-border remittance corridors within Idaho's state licensing scoperetrieved
  5. T1PayServices Bank — PayServices Bank — the U.S. District Court for the District of Idaho held that the Federal Reserve Bank of San Francisco had discretion under 12 U.S.C. 342 to deny a master-account request, confirming Fed Banks' near-unfettered discretion over direct settlement-rail access nationallyretrieved
  6. T3Idaho outbound remittance corridor — Idaho outbound remittance corridor — No Idaho-specific surcharge sits atop the federal 1% remittance excise tax created by the One Big Beautiful Bill Act (effective for transfers after 2025-12-31); the effective rate on a cash-funded outbound transfer originating in Idaho is the federal 1% alone.retrieved
  7. T1Idaho Senate Bill 1440 — Idaho Senate Bill 1440 — A tax of $5 on the first $500 transmitted internationally and 4% on amounts exceeding $500, collected by the licensed money transmitter and remitted quarterly to the Idaho State Tax Commission.retrieved

#

Idaho's payments-relevant financial industry is dominated by a fast-growing credit-union sector (ICCU) alongside consolidating community banks, most visibly Glacier Bancorp's 2025 acquisition of Bank of Idaho.

Standing sub-brief · as of 7 July 2026 163 words · last cycle 2026-07-05

Industry Structure & Commercial Dynamics

Idaho's payments-relevant financial-industry structure is defined by a fast-growing credit-union sector alongside consolidating community banks. Idaho Central Credit Union, the largest state-chartered credit union in Idaho, holds approximately $10 billion in assets, ranking in the top 20 U.S. credit unions and functioning as a structurally significant nonbank deposit/payments competitor to community banks. This scale sits within an ongoing structural tension: the Idaho Bankers Association actively contests the credit-union model's tax-exempt status as a competitive-structure issue vis-a-vis taxed community banks. Community-bank consolidation continued in parallel, with Glacier Bancorp's acquisition of Bank of Idaho Holding Co. (see W13) adding to the state's competitive landscape.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.sec.gov/Archives/edgar/data/0000868671/000086867125000063/pressreleasedatedmay1202.htmretrieved
  2. T4https://www.temenos.com/success-story/iccu-success-story/retrieved
  3. T2https://www.creditunionsonline.com/idaho-credit-unions.htmlretrieved
  4. T3https://idahobankers.org/community-banking/retrieved
  5. T4Idaho Central Credit Union (ICCU) — Idaho Central Credit Union (ICCU) — approximately $10 billion in assets, ranking in the top 20 U.S. credit unions, a structurally significant nonbank deposit/payments competitor to community banksretrieved
  6. T3Idaho Bankers Association — Idaho Bankers Association — the credit-union model as a competitive-structure issue vis-a-vis taxed community banks, reflecting an ongoing bank-vs-credit-union structural tension in Idaho's payments/deposit marketretrieved

Idaho's litigation/enforcement register centres on the federal Fed master-account discretion precedent, DoF administrative MTL denials, and the 2026 veto of bipartisan crypto-kiosk fraud legislation.

Standing sub-brief · as of 7 July 2026 256 words · last cycle 2026-07-05

Legal & Litigation

Idaho's litigation and enforcement register for the baseline period centres on three developments. First, the District of Idaho held in PayServices Bank v. Federal Reserve Bank of San Francisco that FRBSF properly exercised discretion to deny a master-account application, dismissing APA, Mandamus Act, and Due Process claims on March 30, 2024 -- a binding precedent on payment-rail access litigated in Idaho's federal court, with a national reach on Federal Reserve master-account discretion (see W5/W12). Second, the Idaho Department of Finance denied Apex Capital Enterprises LLC's money-transmitter licence application for failing net-worth qualification requirements under Idaho Code 26-2916; an independent baseline-research verification challenge (2026-07-05) flagged that the order PDF's stated date (2025-12-02) may not match the Department's administrative-action page metadata, which reportedly shows a last-update of 2025-08-22, so the precise order date is treated as unconfirmed pending re-verification, though the underlying denial itself is not disputed. Third, Governor Brad Little vetoed the bipartisan Virtual Currency Kiosk Fraud Prevention Act (SB 1359) on April 2/3, 2026, despite its passage through both the House and Senate; AARP Idaho publicly disputed the veto rationale, and sponsors indicated intent to bring revised legislation in a future session (see W1a/W10).

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/retrieved
  2. T1https://www.finance.idaho.gov/wp-content/uploads/2023/09/2025-12-02-Apex-Order-of-Denial.pdfretrieved
  3. T3https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.htmlretrieved
  4. T1District of Idaho — District of Idaho — FRBSF properly exercised discretion to deny a master-account application, dismissing APA, Mandamus Act, and Due Process claims (March 30, 2024) -- a binding precedent on payment-rail access litigated in Idaho's federal courtretrieved
  5. T1Apex Capital Enterprises LLC — Apex Capital Enterprises LLC — the Idaho Department of Finance for failing net-worth qualification requirements (Idaho Code 26-2916). NOTE: an independent baseline-research verification challenge (2026-07-05) flagged that the cited order PDF date (2025-12-02) may not match the Department's administrative-action page metadata, which reportedly shows a last-update of 2025-08-22; the exact order date is therefore treated as unconfirmed pending re-verification, though the underlying enforcement fact (a denial for net-worth failure) is not itself disputed.retrieved
  6. T3Governor Brad Little — Governor Brad Little — the bipartisan Virtual Currency Kiosk Fraud Prevention Act (SB 1359) on April 2/3, 2026, despite passage through both the House and Senate; AARP Idaho publicly disputed the veto rationale and sponsors indicated intent to bring revised legislation in a future sessionretrieved

#

Idaho has no dedicated merchant-acquiring statute; acquiring is delivered through bank/credit-union partnerships with national processors under general federal card-network rules.

Open gap — wpm-int-2W8 merchant-acquiring sweep for US-ID was not actively resolved this cycle.no under-indexing note recorded
Standing sub-brief · as of 7 July 2026 85 words · last cycle 2026-07-05

Merchant Acquiring & Risk

Idaho has no dedicated merchant-acquiring statute; high-risk-MCC treatment is governed by processor and network policy rather than state law. Idaho Central Credit Union delivers merchant-acquiring services to Idaho businesses through a partnership with Fiserv/Clover, illustrating the credit-union/bank-partnership delivery model that substitutes for a dedicated state acquiring framework.

Outlook

Absent any signal of a forthcoming state acquiring statute, this module's posture is stable: acquiring and high-risk-merchant treatment will continue to be set by national processor and card-network policy rather than Idaho-specific rulemaking.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T4https://www.iccu.com/business/services/merchant-services/retrieved
  2. T3https://merchantcostconsulting.com/lower-credit-card-processing-fees/idaho-surcharge-laws/retrieved
  3. T1https://www.finance.idaho.gov/securities-bureau/money-transmitters/retrieved
  4. T4Idaho Central Credit Union — Idaho Central Credit Union — a partnership with Fiserv/Clover, since Idaho has no dedicated merchant-acquiring statute -- high-risk-MCC treatment is governed by processor/network policy, not state lawretrieved

#

Product innovation in Idaho payments concentrates in credit-union/fintech vendor partnerships and the pending stablecoin/digital-asset legislative track; no state sandbox or open-banking mandate exists.

Standing sub-brief · as of 7 July 2026 172 words · last cycle 2026-07-05

Product Innovation & Market Development

Product innovation in Idaho's payments space in the baseline period runs through two channels: regulatory accommodation and credit-union vendor partnerships. The Idaho Department of Finance signalled regulatory accommodation for crypto-ATM businesses via its September 2025 Crypto ATM Framework Keys paper, framing a right-sized oversight approach intended to let crypto-ATM operators keep operating in Idaho while protecting consumers -- non-statutory guidance that precedes any enacted kiosk statute. On the vendor-deployment side, Idaho Central Credit Union deployed Zest AI for AI-automated credit underwriting, reporting a 30%+ increase in loan approvals across auto, personal, and credit-card lending with bias testing built into the model.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T4https://www.zest.ai/learn/success_stories/idaho-central-credit-union/retrieved
  2. T4https://www.fintechfutures.com/press-releases/idaho-central-credit-union-selects-upstart-for-personal-lendingretrieved
  3. T4https://www.fintechfutures.com/credit-unions-building-societies/idaho-central-credit-union-opts-for-alkami-orb-platformretrieved
  4. T1https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdfretrieved
  5. T1Idaho Department of Finance — Idaho Department of Finance — its September 2025 Crypto ATM Framework Keys paper, framing a 'right-sized' oversight approach intended to let crypto-ATM operators keep operating in Idaho while protecting consumersretrieved
  6. T4Idaho Central Credit Union — Idaho Central Credit Union — Zest AI, reporting a 30%+ increase in loan approvals across auto, personal, and credit-card lending with bias testing built into the modelretrieved

#

Idaho's most acute payments consumer-harm vector is APP-style fraud via crypto kiosks targeting seniors; a 2026 bill to address it passed both chambers but was vetoed.

Standing sub-brief · as of 7 July 2026 197 words · last cycle 2026-07-05

Consumer Protection & APP Fraud

Idaho's most acute and fastest-growing payments consumer-harm vector is cryptocurrency-related fraud. The Idaho Attorney General reported cryptocurrency-related consumer fraud losses rising from $19 million in 2023 to over $35 million in 2024, with seniors the largest victim group, driven substantially by crypto-ATM/kiosk scams; FBI Internet Crime Complaint Center 2025 data puts Idaho crypto-fraud losses above $48 million. A legislative response was mounted in 2026: Senate Bill 1359 would have imposed new-customer transaction limits of $2,000 per 24 hours and $10,000 per 30 days, a 72-hour settlement delay on first transactions, mandatory fraud warnings, and fee refunds for fraud victims. None of these protections are in force following Governor Brad Little's veto of the bill (see W7/W1a) despite its passage through both chambers.

no periodic updates on record for this sub-brief

Sources and findings (8)
  1. T1https://www.ag.idaho.gov/newsroom/attorney-general-labrador-warns-idahoans-about-cryptocurrency-atm-scams/retrieved
  2. T3https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.htmlretrieved
  3. T3https://www.aarp.org/states/idaho/protecting-your-money-from-crypto-kiosk-fraud/retrieved
  4. T2https://www.billtrack50.com/billdetail/1983173retrieved
  5. T3https://idaholegalservicesauthority.com/idaho-consumer-protection-lawretrieved
  6. T1https://www.finance.idaho.gov/wp-content/uploads/2025/09/SFFEP-Crypto-ATM-Final-Approved.pdfretrieved
  7. T1Idaho Attorney General — Idaho Attorney General — $19 million (2023) to over $35 million (2024), with seniors the largest victim group, driven substantially by crypto-ATM/kiosk scams; FBI IC3 2025 data puts Idaho crypto-fraud losses above $48 millionretrieved
  8. T2Senate Bill 1359 (2026, vetoed) — Senate Bill 1359 (2026, vetoed) — new-customer transaction limits ($2,000/24hrs, $10,000/30 days), a 72-hour settlement delay on first transactions, mandatory fraud warnings, and fee refunds for fraud victims -- none in force following the gubernatorial vetoretrieved

#

Idaho's payments AML/CFT posture rests on the federal BSA/FinCEN MSB framework layered onto state MTL licensing; no original illicit-finance analysis performed in this module.

Standing sub-brief · as of 7 July 2026 161 words · last cycle 2026-07-05

AML/CFT & Financial Crime

This module carries the Sentinel.gi payments-context AML posture only; no original illicit-finance analysis is performed here, consistent with WPM's scope guardrail treating illicit-finance use of any instrument as a cross-reference to the Financial Intelligence Monitor rather than a WPM conclusion. Direct Sentinel.gi feed content for US-ID was recorded as absent this cycle and has been substituted with public federal sourcing: Idaho-licensed money transmitters must register with FinCEN as Money Services Businesses on Form 107, renewing every two years, maintaining a written BSA/AML compliance programme with a designated compliance officer, and filing Suspicious Activity Reports for transactions of $2,000 or more that are known or suspected to be suspicious.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.federalregister.gov/documents/2026/04/10/2026-07033/anti-money-laundering-and-countering-the-financing-of-terrorism-programsretrieved
  2. T?FIM (sentinel.gi) per-JID baseline profile — United States — Idaho — Idaho operates under the federal BSA/AML framework (FinCEN, OFAC) with state-level money transmitter licensing administered by the Idaho Department of Finance. No Idaho-specific BO registry exists; the state relies on the federal CTA regime, now sharply narrowed. State AML supervisory capacity is modest relative to crypto-enabled fraud exposure.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness
  4. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence
  5. T3FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: OFAC listing
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure

#

Idaho community banks/credit unions access settlement rails predominantly through correspondent relationships rather than direct Fed master accounts, reflecting the discretionary access regime confirmed in D. Idaho.

Standing sub-brief · as of 7 July 2026 184 words · last cycle 2026-07-05

Correspondent Banking, Settlement & Access

Idaho community banks access Fed settlement rails predominantly via correspondent banking relationships -- for example, with Bankers' Bank of the West, which includes FedNow onboarding support -- rather than direct Fed master accounts. This pattern reflects the discretionary master-account regime confirmed in PayServices Bank v. Federal Reserve Bank of San Francisco (see W5/W7), under which Federal Reserve Banks retain broad discretion over direct settlement-rail access -- an asymmetry that compounds further for non-bank money transmitters (W1a), which have no comparable statutory path to direct settlement-rail access at all. The Idaho Bank Act reinforces the integration of state and federal oversight in this space, permitting the Director of the Department of Finance to rely on federal examination reports from the Federal Reserve, OCC, and FDIC in lieu of independent state holding-company examination.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.consumerfinancemonitor.com/2024/04/30/districts-of-wyoming-and-idaho-affirm-broad-fed-powers-over-master-accounts/retrieved
  2. T4https://www.bbwest.com/idaho-contactsretrieved
  3. T1https://www.finance.idaho.gov/wp-content/uploads/legal/statutes-rules/documents/2022-Idaho-Bank-Act.pdfretrieved
  4. T1https://www.federalreserve.gov/newsevents/speech/bowman20250227a.htmretrieved
  5. T4Idaho community banks — Idaho community banks — correspondent banking relationships (e.g., Bankers' Bank of the West, including FedNow onboarding support) rather than direct Fed master accounts, per the discretionary master-account regime confirmed in PayServices Bank v. FRBSFretrieved
  6. T1Idaho Bank Act — Idaho Bank Act — federal examination reports (Federal Reserve, OCC, FDIC) in lieu of independent state holding-company examination, integrating state correspondent/settlement oversight with the federal banking-agency examination stackretrieved

#

Idaho's payments-adjacent commercial activity in the baseline window is dominated by regulatory/legislative product events rather than confirmed new M&A; the state's marquee bank M&A event (Glacier/Bank of Idaho) closed just outside the strict 12-month window.

Standing sub-brief · as of 7 July 2026 256 words · last cycle 2026-07-05

Commercial Intelligence (M&A, Investment & Product)

Glacier Bancorp, Inc. completed its acquisition of Bank of Idaho Holding Co. on May 1, 2025, for $245.4 million (announced January 13, 2025), adding approximately $1.3 billion in assets and 15 locations across Eastern Idaho, Boise, and Eastern Washington -- Glacier's 26th bank acquisition since 2000. On the product side, Alkami Technology deployed its ORB digital-banking platform at Idaho Central Credit Union, integrating with ICCU's Fiserv DNA core to add ACH and wire capabilities to its digital-banking product suite; the deal value was not publicly disclosed. Separately, Upstart partnered with Idaho Central Credit Union to expand personal-loan origination across Idaho, Washington, and eastern Oregon via its AI lending marketplace (the Upstart Referral Network); this deal value was also not publicly disclosed. On the legislative-commercial interface, World Liberty Financial lobbied Idaho legislators in support of stablecoin legislation, disclosing approximately $18,000 in travel and lodging plus roughly $450-900 in meals for a Mar-a-Lago dinner hosting three Idaho senators and representatives between February and April 2026, in support of HB 586, HB 821, HB 901, and SB 1423 (see W2).

no periodic updates on record for this sub-brief

Sources and findings (9)
  1. T1https://www.finance.idaho.gov/wp-content/uploads/2025/09/Crypto-ATM-Framework-Final.pdfretrieved
  2. T3https://idahocapitalsun.com/2026/04/21/trump-family-crypto-venture-lobbied-for-stablecoin-bill-hosted-idaho-legislators-at-mar-a-lago/retrieved
  3. T3https://www.idahopress.com/news/sen-ruchti-aarp-disappointed-in-veto-of-legislation-addressing-virtual-currency-kiosk-fraud/article_409b6089-36cd-4589-a3e6-db0d49bac826.htmlretrieved
  4. T4https://www.zest.ai/learn/success_stories/idaho-central-credit-union/retrieved
  5. T1https://www.sec.gov/Archives/edgar/data/0000868671/000086867125000063/pressreleasedatedmay1202.htmretrieved
  6. T1Glacier Bancorp, Inc. — Glacier Bancorp, Inc. — Bank of Idaho Holding Co. on May 1, 2025 for $245.4 million (announced Jan 13, 2025), adding ~$1.3bn in assets and 15 locations across Eastern Idaho, Boise, and Eastern Washington -- Glacier's 26th bank acquisition since 2000retrieved
  7. T4Alkami Technology — Alkami Technology — Idaho Central Credit Union, integrating with ICCU's Fiserv DNA core to add ACH and wire capabilities to its digital-banking product suiteretrieved
  8. T4Upstart — Idaho Central Credit Union to expand personal-loan origination across Idaho, Washington, and eastern Oregon via its AI lending marketplace (Upstart Referral Network)retrieved
  9. T3World Liberty Financial — World Liberty Financial — approximately $18,000 in travel/lodging plus roughly $450-900 in meals for a Mar-a-Lago dinner hosting three Idaho senators/representatives (Feb-Apr 2026), in support of HB 586/821/901 and SB 1423retrieved
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