These advances can be used to fund a participating employee’s Health Savings Account, Health Reimbursement Account, and/or Flexible Spending Account, or as a general payroll advance. _ offers an electronic payment solution in which its non-employer clients can utilize _’s Digital Disbursements platform to transfer payroll advances to individuals. _ is a California money transmitter licensee. _ (“_”) has requested a determination that its digital disbursements offering (“Digital Disbursements”) qualifies for the payroll processing exemption in Financial Code section 2010, subdivision (j). Thank you for your letter to the Department of Business Oversight (“Department”) dated March 11, 2020, which provided additional information requested by the Department.
Re: _ – Request for Exemption under Financial Code section 2010(j)
