Money services businesses are often required to submit evidence of registration with FinCEN along with their state license applications. For example, California money transmitter license applicants and New York virtual currency business activity license applicants must enter their FinCEN registration confirmation number and filing date into the “Approvals and Designations” section of the NMLS Company Form (MU1).
MSBs required to register with FinCEN should refer to FinCEN’s Registration of Money Services Business Electronic Filing Instructions, which state that registration is required within 180 days of establishment. To complete the registration, MSBs must first enroll in the BSA E-Filing System. Once enrolled, MSBs must complete the registration using FinCEN Form 107, which is housed in the system. Two weeks after submitting that form, we recommend visiting the MSB Registrant Search to ensure that the registration was accepted and processed, and to print a MSB Registration Status Information letter.
Importantly, MSBs need to renew their registrations every even-numbered year, on or before December 31. This means, for example, that if an MSB registered on October 15, 2021, then it must file a renewal by December 31, 2022, and every 24 months thereafter. Renewals must be submitted on a new FinCEN Form 107 through the system. Additionally, FinCEN registration confirmation numbers change with each renewal. Therefore, as soon as a new number is issued to a state licensed MSB, they should update their NMLS Company Form to avoid state licensing regulators flagging their failure to do so.