If you're a billing aggregator and you're simply providing billing information but not handling the payments, are you considered a money services business?

No, if you're a billing aggregator in the United States that is solely providing billing information and not handling the payments, you are not considered a money services business (MSB). Consequently, you do not require a money transmitter license.

The key factor for requiring a money transmitter license is the actual handling of funds. Since the billing aggregator in this scenario is not processing payments but merely consolidating billing information, they are not engaging in money transmission. Therefore, they are not subject to the same regulatory requirements that apply to MSBs.