I think they’re 10 years too late. Every major company-FB, GOOG, Amazon, SQ, Stripe, and others, have state licenses. People who do compliance grouse about the dozens of states crawling around your operations, but I guarantee it’s a less complex and more company friendly model.

The time to market isn’t necessarily any better. NY is the long tent pole in any licensing exercise and can take 18 months to three years if the political appointees aren’t keeping tabs on the licensing staff. An OCC charter would also take years.

In the meantime, which VC backing you will have that patience? Most think on 12 and 18 month timeframes. If money transmission is core to your business, you’ll be better off getting the state licenses. Texas, Washington, Colorado and evening California can approve you in months.