Why now

Cyber is in every exam.

The MTRA Money Transmitter Examination Manual (June 2026) runs core IT/IS procedures on every exam, asks whether the licensee has a CISO, and tests how controls actually run.

Source: McDermott Will & Emery — what the MTRA's examination manual means for money transmitters

Small licensees are being fined.

In August 2026, NYDFS fined a revenue-exempt money transmitter $250,000 over a generic risk assessment and a narrow patch policy.

Source: Data Protection Report — NYDFS levies $250,000 fine on licensee

States are writing it into law.

Mississippi's Data Security for Money Transmitters Act (effective July 1, 2026) requires a qualified individual, a written security program, incident response, BCP/DR and training, regardless of size.

Source: JDSupra — Mississippi enacts Data Security for Money Transmitters Act

Two ways to work together

MSB Cyber Exam Readiness Review

$6,500 fixed — 3 weeks

  • Mock CORE IT/IS exam against the MTRA manual
  • Company-specific risk assessment
  • Asset and vendor inventory check
  • Gap report ranked by exam risk
  • Board-ready summary

Fractional CISO / Qualified Individual

From $2,500/month — 6-month minimum

  • Named security lead for examiners and bank partners
  • Written ISP, IRP and BCP/DR kept current
  • Annual risk assessment
  • Patch and vendor oversight
  • Incident response tabletop
  • Quarterly board report
  • Exam-day support

Your attorneys keep licensing and AML. We handle the IT/IS section.

Ron Moore, Founder & Principal Consultant

  • Former VP of Technology and CISO at Bitcoin Depot
  • Former SVP-level executive at Cardtronics
  • Former CTO at EDC ATM
  • Co-founded a check-cashing fintech that was acquired

I've sat on the licensee side of state examinations.

How it works

  1. 20-minute call

    Review your last exam report or upcoming entry letter.

  2. 3-week Readiness Review

    A ranked fix list against the manual's IT/IS procedures.

  3. Optional ongoing support

    Fractional CISO coverage through your next exam.

What examiners pull for IT/IS

A one-page checklist based on the MTRA manual's IT/IS procedures and document request list.

Prefer to grab it now? Download the checklist (PDF)

Exam in the next 12 months? Let's look at where you stand.

Book a 20-minute call