On June 26, 2025, the Conference of State Bank Supervisors (CSBS) published guidance under the Model Money Transmission Modernization Act (MTMA) concerning the calculation of tangible net worth for virtual currency.

The MTMA is a model statute drafted to encourage uniformity among the states in the regulation of money transmitters. According to the CSBS, 27 states have adopted the MTMA in whole or in part. CSBS recently established a process for issuing non-binding, advisory guidance on the implementation of the MTMA, and the guidance issued June 26 is the first to be published under the new process. 

Under the MTMA, licensees must maintain a tangible net worth (TNW) measured as total assets minus total liabilities minus intangible assets, all as calculated in accordance with US GAAP. The guidance provides that when calculating tangible net worth, money transmitters with virtual currency assets on balance sheet must include all such virtual currency assets in total assets. For these purposes, a virtual currency asset need not be subtracted from total assets where the virtual currency asset has a corresponding customer liability denominated in the same virtual currency.

The guidance, which is nonbinding, includes several conditions and limitations. Most notably, it only applies if a licensee’s day-to-day business includes incurring obligations to customers denominated in the relevant virtual currency.