What are the eligibility requirements for a money transmitter license, and must a company actually hold customer funds?

The requirement for a money transmitter license is that your business is classified as a money services business (MSB). Within the MSB umbrella, your Flow of Funds (FOF) is as such, that you would be considered doing money transmission and hence require a money transmitter license (MTL) in that particular US State in which you are conducting business.

The definition of money transmission will vary from State to State, and then naturally, there is the federal definition as well put out by FinCEN.

Merely holding on to and transmitting customer funds or facilitating a transaction between a buyer and seller is not detailed (informative) enough to make a definitive statement on the classification of a money transmitter or not.

It honestly comes from the transaction set, fund flow, and the overall intent of the transactions. Is it B2B or B2C, P2P, etc.? There may even be certain exemptions on the money transmitter license requirements.