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This structure provides significant advantages, including operational simplicity, faster speed to market, and greater policy independence—allowing processors to streamline compliance and reduce friction in launching new services or adapting to network changes. MALPBs are more narrowly scoped than traditional banks and do not engage in deposit-taking, lending, or consumer banking. This helps the parent company avoid classification as a bank holding company for purposes of the Bank Holding Company Act, which carries additional regulatory burdens and restrictions on commercial activities. The model also offers resilience -- processors can maintain continuity even if a third-party sponsor exits the market or shifts priorities. With Georgia’s Department of Banking and Finance providing a robust regulatory framework, and Fiserv already operational as the first MALPB in the U.S., this charter structure is poised to reshape how merchant acquirers engage with the payments ecosystem. The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Services Banking and Finance Corporate and M&A Electronic and Mobile Commerce Industries Financial Services Payments and Fintech Key contacts Robert J. Pile Partner Atlanta, United States Brian M. Murphy Partner Atlanta, United States Hannah C. 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Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the member firms or their controlled, managed or affiliated entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For information on Konexo please also see the Legal Notices page of this website ATTORNEY ADVERTISING - Prior results do not guarantee a similar outcome. Unless otherwise indicated, attorneys at Eversheds Sutherland (US) LLP are not certified by the Texas Board of Legal Specialization.

The Georgia MALPB: A Strategic Alternative to Traditional Sponsor Banks for Merchant Card Processing Services

August 01, 2025

United States

The Georgia Merchant Acquirer Limited Purpose Bank (MALPB) offers a compelling alternative to traditional sponsor bank models by enabling payment processors to directly access card networks like Visa and Mastercard without relying on third-party financial institutions.

This structure provides significant advantages, including operational simplicity, faster speed to market, and greater policy independence—allowing processors to streamline compliance and reduce friction in launching new services or adapting to network changes.

MALPBs are more narrowly scoped than traditional banks and do not engage in deposit-taking, lending, or consumer banking. This helps the parent company avoid classification as a bank holding company for purposes of the Bank Holding Company Act, which carries additional regulatory burdens and restrictions on commercial activities. The model also offers resilience -- processors can maintain continuity even if a third-party sponsor exits the market or shifts priorities. With Georgia’s Department of Banking and Finance providing a robust regulatory framework, and Fiserv already operational as the first MALPB in the U.S., this charter structure is poised to reshape how merchant acquirers engage with the payments ecosystem.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.

Robert J. Pile

Partner

Atlanta, United States

Brian M. Murphy

Partner

Atlanta, United States

hannahwiniarski@eversheds-sutherland.com

Hannah C. Winiarski

Special Counsel

Chicago, United States | Atlanta, United States

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Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed or affiliated firms and the members of Eversheds Sutherland (Europe) Limited and Eversheds Sutherland (Africa) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the member firms or their controlled, managed or affiliated entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For information on Konexo please also see the Legal Notices page of this website
ATTORNEY ADVERTISING - Prior results do not guarantee a similar outcome.
Unless otherwise indicated, attorneys at Eversheds Sutherland (US) LLP are not certified by the Texas Board of Legal Specialization.

The Georgia MALPB: A Strategic Alternative to Traditional Sponsor Banks for Merchant Card Processing Services

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