For platforms that hold fan payments and pay creators

Holding fan money for creators can be money transmission.

Envoy walks through how fan money really moves on a platform — who holds it, who pays out, whether a licensed processor holds it instead, whether it can go anywhere but the creator — and checks the four conditions of the agent-of-payee exemption. It records each state’s status off CSBS’s own map, dated, and keeps the analysis for counsel.

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Opens in this browser with an invented fan platform already in it. No account, no email address, nothing installed.

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The problem

A licence in every state, unless you are the creator’s agent.

A platform that takes a fan’s money and later pays it to a creator can be transmitting money under state law. The Money Transmission Modernization Act, enacted in full or in part by thirty-one states, carries an agent-of-payee exemption: each creator appoints the platform in writing, the platform holds itself out that way, and paying the platform counts as paying the creator.

31 states

have enacted the Money Transmission Modernization Act in full or in part.

CSBS →

4 conditions

of the agent-of-payee exemption, each one checked.

Per state

a licence, if the exemption does not hold.

Will never say a licence is not needed.

Envoy reads the answers as low, agent of payee, weak or high, and says why. Money that can be sent on to anyone but the creator reads high. More signed agreements than creators is refused. A checkout that never says it takes payment on the creator’s behalf, unsigned creators, an old analysis and an unchecked state are each called out.

How it works

Walk-through, states, the file

Walk through the money

Five questions about who holds it and where it can go, and the four agent-of-payee conditions.

Check each state

Users per state, whether it has enacted the act, whether its own law has the exemption, any licence held, and the day it was checked.

Hand counsel the file

The reading, everything weak, the walk-through and every state, printable.

What it will never do

It shows the exposure. It decides nothing.

Envoy never says a licence is not needed. That is counsel’s call, and the file is for them.

No state list of its own.Each state is read off CSBS’s map and dated.

No money handled.Envoy records how money moves; it moves none.

It is not a lawyer.Not legal advice.

It never touches a payment.The subscription is for software.

Pricing

Priced per platform

Less than one state’s licence application fee.

Most platforms

One platform

$29/month

One platform paying creators.

The money walk-through
Agent-of-payee conditions
Every state, dated

One platform, yearly

$290/year

The same, two months free.

Everything in One platform
Printable file for counsel
Export for your lawyer

Subscription. Your bank statement says Envoy Software. Refunded in full on request within 30 days. Your licence key is emailed to you within two working days of payment.

Checkout is our own bitcoin server, not a card processor — nobody we had to apply to and nobody who can close the account. The button takes you straight to it. Give your email address there — that is where your key is sent.

Questions

The ones we actually get asked

What is agent of payee?

When each creator appoints the platform in writing to collect on their behalf, the platform holds itself out that way, and paying the platform counts as paying the creator.

Does a licensed processor help?

If a licensed processor holds the money instead of the platform, the reading changes. Envoy asks.

Why date each state?

Because enactments change. Envoy keeps the day each one was read off CSBS’s map.

Is this legal advice?

No. It is the file you hand counsel.

What do I actually get when I pay?

The demo on this page is the whole program, running on invented records. Paying gets you a licence key — one line of text, emailed to the address you give at checkout within two working days. Paste it into the program and from then on it keeps your own records. Until then, nothing you type into it is kept.

The key is checked inside the page, on your own machine. It never calls us, so there is still no account and nothing about your business goes anywhere. If you ever stop paying, your records stay exactly where they are, read-only, and Export still hands you every one of them.

Open the demo before the next state letter

The invented fan platform’s checkout never says it takes payment on the creator’s behalf, 260 creators are unsigned, the analysis is fourteen months old with no counsel review, and two states were never properly checked.

Open the demo See pricing