California DFAL License Requirements: Who Needs One in 2026?

Updated August 17, 2026 to reflect S.B. 97’s repeal of the DFAL’s stablecoin chapter and its narrowed definition of digital financial asset, and to replace the widely-circulated $500,000 surety-bond figure with what the rulemaking record actually shows. That analysis was first published as Complying With Calif. Crypto License Law’s 11th-Hour Rewrite, Law360 Expert Analysis, August 13, 2026, by Chanté Eliaszadeh and Brandon Orewyler. Updated September 5, 2026 after a full citation check against the enacted texts and the rulemaking file: the stablecoin, definitional-exclusion, New York conditional-license, kiosk, and surety-bond passages were corrected, and the Legislature’s stated reason for the stablecoin repeal was added.

Key Takeaways

1. The regime is live: a business conducting digital financial asset business activity with or on behalf of California residents needs a DFPI license or a pending application, or an exemption that actually fits.

2. Daily penalties make waiting the worst option: enforcement exposure runs to $100,000 per day, so operating while planning to apply is the one indefensible posture.

3. A New York BitLicense helps; a California MTL does not: the section 3205 conditional license is the DFAL’s head start for out-of-state licensees, it reaches only New York authority issued or approved by January 1, 2025, and it lifts none of the DFAL’s own requirements.

4. Bond and net worth are set in review: section 3207 fixes no dollar amount—it leaves the surety bond “in a form and amount as determined by the department”—and the widely circulated $500,000 bond figure is not what the rulemaking record shows.

5. The DFAL adds to the money-transmission analysis: it does not replace it, and S.B. 97 repealed the stablecoin chapter and widened the exclusions from the definition of digital financial asset.

Do You Need a License Under California’s Digital Financial Assets Law?

If your business exchanges, transfers, or stores digital financial assets with or on behalf of California residents, then on or after July 1, 2026 you need one of three things: a license from the Department of Financial Protection and Innovation (DFPI), a completed license application filed on or before July 1, 2026 that is awaiting decision, or an exemption under Financial Code section 3103—most commonly the de minimis carve-out for activity reasonably expected to total $50,000 or less per year. Operating outside those three lanes is unlicensed activity exposed to civil penalties of up to $100,000 per day.¹

The Digital Financial Assets Law (DFAL), Cal. Fin. Code Division 1.25 (commencing with section 3101), added by A.B. 39 (Stats. 2023, ch. 792), is California’s dedicated digital-asset licensing regime, and it sits on top of—not instead of—the state’s money transmitter framework.²³ The three lawful lanes come straight from the operative section:

The decision logic reduces to a few lines:

def needs_dfal_license(activity, ca_residents, annual_value_usd):
    covered = activity in {"exchange", "transfer", "store_custody"}  # Fin. Code 3102
    if not (covered and ca_residents):
        return False
    if annual_value_usd <= 50_000:        # 3103 de minimis exemption
        return False
    # otherwise: license (3203), pending application filed
    # on or before 2026-07-01 (3201(b)), or another 3103 exemption
    return True

What Counts as Digital Financial Asset Business Activity

The statute defines a digital financial asset as a “digital representation of value that is used as a medium of exchange, unit of account, or store of value, and that is not legal tender, whether or not denominated in legal tender.”⁴ Covered business activity centers on “[e]xchanging, transferring, or storing a digital financial asset” for or on behalf of a California resident, with storage and exchange defined through assuming or maintaining control of the asset on the resident’s behalf.⁴

Two practical consequences follow. First, custody is the gravitational center: businesses that hold customer assets—exchanges, hosted wallets, custodians—are squarely covered. Second, the “on behalf of a resident” framing means an out-of-state or offshore platform serving California customers is inside the perimeter; the license obligation follows the resident, not the server.

How California Got Here: The Canonical Dates

Note the compressed endgame: the implementing regulations became effective two days before the licensure trigger, after an OAL disapproval and a second modification round. Businesses that built compliance plans on the proposed rules should re-check them against the final text.⁸

The Exemptions, Including the $50,000 De Minimis Carve-Out

Financial Code section 3103(b) lists seventeen exempt categories, including government entities and banks, and section 3103(c) lets the commissioner exempt further persons or transactions by regulation or order and post them on the department’s website. The exemption most relevant to startups is de minimis: the law does not reach a person whose covered activity with, or on behalf of, California residents “is reasonably expected to be valued, in the aggregate, on an annual basis at fifty thousand dollars ($50,000) or less.”⁹

Three cautions. The measure is aggregate annual value of activity, not revenue or profit—a small business moving customer crypto can blow through $50,000 of transaction value quickly. The test is what is “reasonably expected,” so a growth-stage business cannot ride the exemption while projecting past it. And exemptions are fact-specific: confirm the current section 3103 list and the DFPI’s posted exemptions before relying on any of them.

A New York License Helps. A California MTL Does Not.

The DFAL’s head start for out-of-state licensees goes to New York licensees. Under section 3205(a), the commissioner may issue a conditional license to an applicant that holds a New York virtual-currency license under 23 NYCRR Part 200 (the BitLicense) or a New York limited-purpose trust company charter with approval to conduct virtual-currency business—but only if that New York authority was issued or approved no later than January 1, 2025, and only where the applicant pays all appropriate fees and complies with the requirements of the division.¹⁰ The conditional license is a bridge, not a destination: under section 3205(c) it expires at the earliest of the issuance of an unconditional license, the denial of the application, or the revocation of the New York license or the disapproval or revocation of the New York charter.¹⁰

What section 3205 does not do is grandfather California’s own money transmitter licensees. An MTL under the Money Transmission Act covers money transmission;³ the DFAL is a separate, parallel regime for digital financial asset business activity, and a business subject to both needs both. For the multi-state picture—including which states require no license at all for standalone crypto activity—see our 50-state crypto licensing map.

Bond and Net Worth: What the Statute Says vs. What DFPI Expects

The statute deliberately fixes no dollar amounts. Section 3207 requires each licensee to “maintain a surety bond or trust account in United States dollars in a form and amount as determined by the department,” and capital requirements are likewise set by the DFPI in the application process.¹¹

What the DFPI has actually signaled is one number, and it is not the bond: its application guidance states the department “expects an initial amount of $100,000 in tangible net worth as part of the DFAL license application,” with the final figure set later in review under section 3207(b).⁷

The $500,000 Bond That Isn’t

A $500,000 surety bond figure circulates through client alerts and compliance-vendor guides, in at least one instance as a fixed floor. We ran it down for a Law360 Expert Analysis piece, and it appears nowhere in the regime: not in the statute, not in the final regulations, not in the DFPI’s licensing guidance, and not in the Nationwide Multistate Licensing System checklist—which records the minimum bond amount as $0.00.¹¹ The rulemaking file explains where the number comes from. Two industry commenters, the MSBA and the CBAC, asked the DFPI to establish minimum and maximum surety bond amounts, on a formula the MSBA put at a $100,000 minimum and a $500,000 maximum and described as aligned with the NMLS money-transmitter model law; the department declined, stating that the “DFAL does not require the Department to enact minimum and/or maximum surety bond amounts in a regulation” and that it “is not yet able to predict or project typical surety bond amounts.”¹¹

The number’s absence is deliberate rather than accidental. The Office of Administrative Law had flagged the proposed surety-bond rule as unclear, faulting the proposed section because it was “unclear from the proposed section how the Department will determine the amount of the surety bond to be maintained by a licensee.”¹¹ The DFPI’s fix was not to publish a flat number. Told to explain how it would decide, the department adopted a rule binding the commissioner to consider “only the factors” the statute already supplies for capital and liquidity, applied—in the department’s words—“on a case-by-case basis,” pointing at the capital test and closing the list.¹¹

A business that budgets for a hard $500,000 line is budgeting against a figure the agency has declined to adopt. Both the bond and the net-worth number are calibration points the DFPI moves case by case; confirm current amounts directly with the department before relying on either.

Stablecoins Under the DFAL: The Chapter That Was Repealed

The DFAL no longer has a stablecoin chapter. As enacted, Chapter 6 would have barred a covered person from dealing in a stablecoin unless both conditions were met: the issuer was a DFAL applicant or licensee, a bank, or a qualifying trust company, and the issuer at all times held eligible securities at least equal to its outstanding stablecoins—with DFPI commissioner approval under section 3603 as the alternative path. One day before the licensing trigger, S.B. 97 deleted the whole of it. The operative language is flat: “Chapter 6 (commencing with Section 3601) of Division 1.25 of the Financial Code is repealed.”¹²

The Legislature gave its reason, and it is the federal calendar. The Senate floor analysis of the final bill states that “the ultimate effect of the law will curtail California’s role in regulating stablecoin issuers and the exchange, transfer, or storage of stablecoins,” and that “[r]ecognizing the preemptive elements of the federal law, this bill removes stablecoin provisions from DFAL to remove the short-term administrative burden on DFPI and businesses subject to DFAL related to compliance.”¹³ Rather than run bespoke state reserve rules for the roughly six months before the GENIUS Act takes effect, California stepped back.

That leaves a gap, and it is the practical point for any stablecoin business: California’s dedicated stablecoin rules are gone, the federal regime is not yet operative, and general DFAL licensing still reaches stablecoin activity in the meantime. The GENIUS Act takes effect on the earlier of January 18, 2027 or 120 days after the primary federal payment stablecoin regulators issue any final regulations implementing it.¹⁴ Even then, its licensing preemption is narrow: it reaches federal qualified payment stablecoin issuers and approved bank and credit-union subsidiaries, expressly preserves state authority over state-chartered institutions, and leaves state qualified payment stablecoin issuers under their home-state regulator.¹⁴ A business that exchanges, transfers, or stores stablecoins for California residents, rather than issuing them, is not covered by that preemption at all, and sits inside the DFAL licensing perimeter on the ordinary three-lane analysis above—with or without Chapter 6. Our GENIUS Act stablecoin compliance roadmap tracks the federal timeline.

S.B. 97 also rewrote the exclusions from the definition of digital financial asset. It broadened the existing in-game carve-out: section 3102(g)(2)(B) now reaches a digital representation of value issued by or on behalf of a publisher and “used primarily within online games or game platforms and that is not otherwise a digital financial asset,” where the pre-amendment text required use “solely within an online game, game platform, or family of games.” It reworked the merchant affinity and rewards exclusion at section 3102(g)(2)(A) to cover a transaction in which a merchant grants “digital representations of value that primarily relate to the affinity or rewards program” and that cannot be taken from or exchanged with the merchant for legal tender, bank or credit union credit, or a digital financial asset. And it added a new exclusion at section 3102(g)(2)(D) for “[a] digital record of ownership, or equivalent thereto, of tangible or intangible goods,” expressly including works of art, collectibles, merchandise, virtual land, in-game assets, qualifying merchant loyalty points, and event tickets.¹² For retailers running points programs, game publishers with in-platform currencies, and NFT and collectibles platforms, those are meaningful clarifications.

Crypto Kiosks: SB 401’s Separate Overlay

California paired the DFAL with a dedicated kiosk statute (SB 401, Stats. 2023, ch. 871). Its conduct rules bound operators well before the licensing trigger; its licensing duty arrived with it:

• Transaction cap—an operator may not accept or dispense more than $1,000 in a day from or to a single customer via a digital financial asset transaction kiosk (Fin. Code § 3902).¹⁵
• Charge cap—on or after January 1, 2025, an operator may not collect charges, direct or indirect and including the spread between the exchange market price and the price charged the customer, exceeding the greater of $5 or 15% of the U.S. dollar equivalent of the digital financial assets involved in the transaction (Fin. Code §§ 3901(a), 3904).¹⁵
• Licensing compliance—on or after July 1, 2026, kiosk operators must ensure the digital financial asset business activity running through their machines complies with the DFAL’s licensing regime (Fin. Code § 3907).¹⁵

Kiosk operators also face a separate federal layer; see our FinCEN CVC kiosk compliance guide.

Enforcement Exposure: $100,000 Per Day

The DFAL’s enforcement section is blunt. A person that engages in covered activity without a license faces a civil penalty of up to $100,000 for each day of violation; a licensee or covered person that materially violates the law faces up to $20,000 per day. The penalty “continues to accrue until the date the violation ceases.”¹

The DFPI now has a dedicated digital-asset regime, final regulations, and an application pipeline that opened in March—the ingredients of an enforcement program. For how aggressively regulators are using their crypto authority elsewhere, see our crypto enforcement tracker.

What to Do Now

• If you applied by July 1, 2026—you may operate while the application is pending. Keep activity within the scope described in the application, and expect the DFPI to set your bond and net-worth figures during review.
• If you did not apply and serve California residents—get an exemption analysis done now. If no exemption fits, the choices are stopping or restructuring the covered activity, or applying and staying out of the California market until the license issues. Daily-accruing penalties make “keep operating while we apply” the one indefensible option.
• If you hold a New York BitLicense or trust charter issued or approved on or before January 1, 2025—evaluate the section 3205 conditional-license path; it is the head start the statute offers out-of-state licensees, and it lifts none of the DFAL’s own fees or requirements.
• If California is one state among many—the DFAL adds to, rather than replaces, the money-transmission analysis. Start from the 50-state map and the multi-state licensing cost guide.

Need California DFAL Guidance?

Astraea Counsel advises crypto and fintech companies on California DFAL licensing, exemption analysis, DFPI applications, and multi-state licensing strategy. Our analysis of the regime’s final-week rewrite was published by Law360 as Complying With Calif. Crypto License Law’s 11th-Hour Rewrite (Expert Analysis, August 13, 2026). Explore our Regulatory Compliance services, read how we work with a cryptocurrency lawyer in California, or contact us to discuss your position.

Related Resources

• State-by-State Crypto Licensing Map (2026)—Where a license is, and is not, required for standalone crypto activity across all fifty states.
• Do Crypto Companies Need a Money Transmitter License?—The threshold question, answered by business model.
• What Multi-State Crypto Money Transmitter Licensing Actually Costs—Fees, bonds, and net-worth thresholds across states.
• GENIUS Act Stablecoin Compliance Roadmap—The federal stablecoin timeline that will eventually preempt part of the state picture.
• FinCEN’s CVC Kiosk Crackdown—The federal MSB layer for kiosk operators.
• Crypto Enforcement Tracker (2024-2026)—Federal SEC and CFTC enforcement actions and penalties.
• Complying With Calif. Crypto License Law’s 11th-Hour Rewrite—Our Law360 Expert Analysis on the DFAL’s final-week rewrite and what it changed for applicants (August 13, 2026).

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Disclaimer: This article provides general information only and does not constitute legal advice. California DFAL requirements, DFPI guidance, and regulatory amounts change; verify current requirements against the statute, the final regulations, and the DFPI, and consult qualified counsel before relying on this guide.

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Sources and Citations

Footnotes

1. Cal. Fin. Code § 3201 (licensure requirement operative July 1, 2026; lawful lanes are a license under § 3203, a completed application submitted on or before July 1, 2026 that is “awaiting approval or denial,” or an exemption; section text as most recently amended by SB 97, Stats. 2026, ch. 52, effective June 30, 2026); Cal. Fin. Code § 3407 (civil penalties: up to $100,000 per day for unlicensed activity; up to $20,000 per day for licensee violations; penalties accrue “until the date the violation ceases”). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=3201; https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=3407. ↩ ↩² ↩³

2. Digital Financial Assets Law, Cal. Fin. Code Division 1.25 (commencing with § 3101), enacted by AB 39 (Stats. 2023, ch. 792, effective Jan. 1, 2024). Section 3101: “This division shall be known as the Digital Financial Assets Law.” https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=3101. ↩ ↩²

3. Cal. Fin. Code § 2030(a) (Money Transmission Act, Fin. Code Division 1.2) (“A person shall not engage in the business of money transmission in this state, or advertise, solicit, or hold itself out as providing money transmission in this state, unless the person is licensed or exempt from licensure under this division or is an agent of a person licensed or exempt from licensure under this division.”); Cal. Fin. Code § 2003(r) (defining “money transmission” as selling or issuing payment instruments to, selling or issuing stored value to, or receiving money for transmission from, a person located in this state). The Digital Financial Assets Law is a separate division, Fin. Code Division 1.25, with its own licensure requirement at § 3201; a license issued under Division 1.2 confers no authority under Division 1.25. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=2030; https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=2003. ↩ ↩²

4. Cal. Fin. Code § 3102 (definitions) (as amended by S.B. 97, Stats. 2026, ch. 52, eff. June 30, 2026): a digital financial asset is a “digital representation of value that is used as a medium of exchange, unit of account, or store of value, and that is not legal tender, whether or not denominated in legal tender”; digital financial asset business activity includes “[e]xchanging, transferring, or storing a digital financial asset,” with storage and exchange defined through assuming or maintaining control on behalf of a resident. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=3102. ↩ ↩²

5. AB 2269 (2021-2022 Reg. Sess.), vetoed by Governor Newsom on September 23, 2022; the veto message called it “premature to lock a licensing structure in statute without considering both this work and forthcoming federal actions,” “this work” being the extensive research and outreach the Administration conducted after issuing Executive Order N-9-22. Veto message: https://www.gov.ca.gov/wp-content/uploads/2022/09/AB-2269-VETO.pdf; bill: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB2269. ↩

6. AB 1934 (Stats. 2024, ch. 945), amending Fin. Code § 3201 to substitute July 1, 2026 for July 1, 2025. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB1934. ↩

7. California Department of Financial Protection and Innovation, Monthly Bulletin (March 2026) (DFAL license applications accepted through NMLS beginning March 9, 2026), https://dfpi.ca.gov/news/monthly-bulletins/monthly-bulletin-march-2026/; Cal. Code Regs. tit. 10, §§ 1200(e)-(f), 1212 (application filed on NMLS Forms MU1 and MU2); California Department of Financial Protection and Innovation, “Digital Financial Assets Law—Preparing for your Application” (“The Department expects an initial amount of $100,000 in tangible net worth as part of the DFAL license application,” with the final amount determined under Fin. Code § 3207(b) “later in the application process”), https://dfpi.ca.gov/regulated-industries/digital-financial-assets/digital-financial-assets-law-frequently-asked-questions/digital-financial-assets-law-preparing-for-your-application/. ↩ ↩²

8. California Department of Financial Protection and Innovation, Digital Financial Assets Law Regulations, Opinions and Releases (rulemaking PRO 02-23: Office of Administrative Law disapproval May 12, 2026; Notice of Second Modification June 5, 2026; final regulations approved with an effective date of June 29, 2026). https://dfpi.ca.gov/rules-enforcement/laws-and-regulations/digital-financial-assets-law-regulations-opinions-releases/. ↩ ↩² ↩³

9. Cal. Fin. Code § 3103(b) (exempting, inter alia, a person whose digital financial asset business activity with or on behalf of residents “is reasonably expected to be valued, in the aggregate, on an annual basis at fifty thousand dollars ($50,000) or less”). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=3103. ↩

10. Cal. Fin. Code § 3205 (conditional licenses for holders of a New York virtual-currency license under 23 NYCRR Part 200 or a New York limited-purpose trust company charter with approval to conduct virtual-currency business, issued or approved no later than January 1, 2025). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=3205. ↩ ↩²

11. Cal. Fin. Code § 3207 (licensee “shall maintain a surety bond or trust account in United States dollars in a form and amount as determined by the department”); Cal. Code Regs. tit. 10, § 1230(b) (Commissioner “shall consider only the factors set forth at Financial Code section 3207, subdivision (b), in determining the amount of the surety bond”); Office of Administrative Law, Decision of Disapproval of Regulatory Action, OAL Matter No. 2026-0330-04 (May 19, 2026; reciting the May 12, 2026 notice) (clarity standard, Cal. Gov. Code § 11349.1(a)(3); surety-bond defect in proposed Cal. Code Regs. tit. 10, § 1230); DFPI, “Digital Financial Assets Law—Preparing for your Application”; DFPI, Notice of Second Modification to Text (June 5, 2026) (§ 1230 modified “to clarify the factors that the Commissioner shall consider in setting a surety bond amount for individual applicants on a case-by-case basis”); DFPI, Final Statement of Reasons, PRO 02-23 (June 25, 2026) (responses to comments 1.8.9 and 1.9.10, declining a proposed $100,000 minimum and $500,000 maximum bond range, the maximum rendered “$500,00” in the original: the “DFAL does not require the Department to enact minimum and/or maximum surety bond amounts in a regulation”); NMLS, CA-DFPI DFAL License new-application checklist (updated June 8, 2026) (ESB minimum bond amount $0.00). Outside that declined comment, the $500,000 figure circulating in practitioner alerts appears in none of these sources. Analysis first published as Chanté Eliaszadeh and Brandon Orewyler, “Complying With Calif. Crypto License Law’s 11th-Hour Rewrite,” Law360 (Aug. 13, 2026), https://www.law360.com/articles/2510279. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=3207. ↩ ↩² ↩³ ↩⁴ ↩⁵

12. S.B. 97, Stats. 2026, ch. 52 (urgency statute, eff. June 30, 2026), § 9 (“Chapter 6 (commencing with Section 3601) of Division 1.25 of the Financial Code is repealed.”); compare former Cal. Fin. Code §§ 3601, 3603 (added by A.B. 39, Stats. 2023, ch. 792; § 3603 amended by A.B. 1934, Stats. 2024, ch. 945). S.B. 97 also amended Cal. Fin. Code §§ 3102, 3103, 3201, 3205, 3211, 3307, 3501, 3505, and 3701; the definitional exclusions at § 3102(g)(2) as amended are described in the text above, and the pre-amendment text is former Cal. Fin. Code § 3102(g)(2) (as added by A.B. 39, Stats. 2023, ch. 792). See S.B. 97 committee analyses (2025-2026 Reg. Sess.). https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB97. ↩ ↩²

13. Senate Rules Committee, Office of Senate Floor Analyses, Analysis of S.B. 97 (Grayson), Unfinished Business (July 7, 2026), at 4 (“On July 18, 2025, the federal government enacted a law related to stablecoins (P.L. No: 119-27). While the law is still being implemented by federal regulators, the ultimate effect of the law will curtail California’s role in regulating stablecoin issuers and the exchange, transfer, or storage of stablecoins. Recognizing the preemptive elements of the federal law, this bill removes stablecoin provisions from DFAL to remove the short-term administrative burden on DFPI and businesses subject to DFAL related to compliance.”); see also Assembly Floor Analysis of S.B. 97, as amended June 23, 2026 (June 24, 2026), at 2 (describing the GENIUS Act’s dual-track framework as the federal backdrop to the bill). Both analyses are reachable from https://leginfo.legislature.ca.gov/faces/billAnalysisClient.xhtml?bill_id=202520260SB97. ↩

14. Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), Pub. L. No. 119-27, 139 Stat. 419 (July 18, 2025). Section 20 provides that “[t]his Act, and the amendments made by this Act, shall take effect on the earlier of (1) the date that is 18 months after the date of enactment of this Act; or (2) the date that is 120 days after the date on which the primary Federal payment stablecoin regulators issue any final regulations implementing this Act,” eighteen months from July 18, 2025 being January 18, 2027. On preemption, § 5(h) provides that “[t]he provisions of this section supersede and preempt any State requirement for a charter, license, or other authorization to do business with respect to a Federal qualified payment stablecoin issuer or subsidiary of an insured depository institution or credit union that is approved under this section to be a permitted payment stablecoin issuer,” while preserving State authority to “charter, license, supervise, or regulate an insured depository institution or credit union chartered in such State”; § 7(a) leaves State qualified payment stablecoin issuers under their State payment stablecoin regulator’s supervisory, examination, and enforcement authority; and § 7(f)(4) excepts “State laws relating to the chartering, licensure, or other authorization to do business as a permitted payment stablecoin issuer” from the Act’s savings clause for State consumer protection law. The Act’s restriction on digital asset service providers offering or selling payment stablecoins, § 3(b)(1), begins three years after enactment. https://www.govinfo.gov/app/details/PLAW-119publ27. ↩ ↩²

15. SB 401 (Stats. 2023, ch. 871), Cal. Fin. Code §§ 3901-3907: § 3902 ($1,000 daily per-customer kiosk limit: “An operator shall not accept or dispense more than one thousand dollars ($1,000) in a day from or to a customer”); § 3904 (on or after January 1, 2025, cap on “charges, whether direct or indirect,” at the greater of $5 or 15% of the dollar equivalent of the assets in the transaction; “charges” is defined at § 3901(a) to include fees and the spread between the exchange market price and the price charged the customer); § 3907 (kiosk-operator duty to ensure DFAL licensing compliance, as amended by Stats. 2024, ch. 945). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FIN&sectionNum=3902. ↩ ↩² ↩³