• IDAl-IO DEPARTMENT OF FINANCE January 13, 2020

BRADLITrLE Governor

PATRICIA R. PERKINS Director

RE: Money Transmission Licensing Inquiry regarding

Dear ,

The Idaho Department of Finance (The "Department") is in receipt of your cotTespondence of November 20, 2019, wherein you request guidance regarding the applicability of the Idaho Money Transmitter Act ("the Act") to the business model of (" ").

Based on the info1mation provide in your conespondence as well as the Department's review of the Bill Payment Service Contract, the Department has dete1mined to take a no-action position as it pe11ains to the licensing provisions of the Act. This determination is based specifically on our understanding that will be operating pursuant to a formal agreement with each biller and that agreement will create an agency relationship in which payment for the consumer to the biller satisfies the consumer's obligation to the biller.1

If you have questions or comments on this matter, please contact the undersigned at norman.real@finance.idaho.gov or via telephone at (208)332-8082.

Sincerely

orman Real Financial Examiner ///Investigator Idaho Department of Finance

1 This decision is based solely on the unique circumstances of the activity described. This letter should not be construed as a finding that that licensure is not required in other jurisdictions where other users or recipients may reside.

SECURITIES BUREAU 800 Park Boulevard, Suite 200, Boise, ID 83712 Mail Toi P.O. Box83720, Boise ID 83720-0031

Phone1 (208) 332-8004 Fax1 (208) 332-8099 http1//www.finance.idaho.gov

PROTECTING THE INTEGRI1Y OF IDAHO FINANCIAL MARKETS SINCE 1905

Subject: FW: Money Transmission License Importance: High

Good Morning Mr. Real, Just thought I would check back on my questions below. If I need to contact someone else or go through a more formal process, please let me know.

Thanks for your help,

Confldentlality Notice: This email message, including any attachments, contains or may contain confldential information intended only for the addressee. If you have received this message in error, please accept my apology and notify me immediately by reply message and delete this email message along with any attachments from your system.

From: Sent: Wednesday, November 20, 2019 2:19 PM To: 'norman.real@finance.idaho.gov' Subject: Money Transmission License Importance: High

Good Afternoon Mr. Real, I am the Compliance Officer for . We are a payment processor primarily for utility companies, but we also process payments through RPPS. This means we may process payments to pay a persons car payment or other debt owed. We do not process payments between persons and do not process internationally. Based on the no action letters on your website, it appears that we do not need to obtain a money transmitter license from the State of Idaho.

Can you help me verify whether this is correct?

I have attached our business plan and the two no action letters from your website that appear most applicable.

If I need to contact someone else, please let me know.

Thanks for your help,

Confldentiallty Notice: This email message, including any attachments, contains or may contain confldential information intended only for the addressee. If you have received this message In error, please accept my apology and notify me immediately by reply message and delete this email message along with any attachments from your system.

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