NMLS recently updated its Money Services Business Call Report to reflect virtual currency’s impact on money transmitter licensing and to refine other financial reporting requirements. The updated report, which covers the first quarter reporting period (January 1 to March 31), is due May 15.
Virtual Currency-Specific Adjustments
The sections in the MSB Call Report for companywide and state transactions require a detailed breakdown of those involving virtual currency. NMLS has provided definitions for each of these fields in its updated Field Definitions document.
Note that, for reporting purposes, NMLS requires the virtual currency valuation to be “in U.S. Dollars and should be based on a generally accepted exchange rate and the licensee, when requested, should be able to document and substantiate how they arrived at the valuation.”
- TA 180: Total # of Virtual Currency to Virtual Currency Exchange Transactions
- TA 190: Total $ amount of Virtual Currency to Virtual Currency Exchange Transactions
- TA 200: Total # of Virtual Currency to U.S. Dollar Exchange Transactions
- TA 210: Total $ amount of Virtual Currency to U.S. Dollar Exchange Transactions
- TA 220: Total # of U.S. Dollar to Virtual Currency Exchange Transactions
- TA 230: Total $ amount of U.S. Dollar to Virtual Currency Exchange Transactions
- TA 240: Total # of Virtual Currency to Virtual Currency Facilitated Exchange Transactions
- TA 250: Total $ amount of Virtual Currency to Virtual Currency Facilitated Exchange Transactions
- TA 280: Total # of Virtual Currency to/from U.S. Dollar Facilitated Exchange Transactions
- TA 290: Total $ amount of Virtual Currency to/from U.S. Dollar Facilitated Exchange Transactions
- TA 300: Total # of Virtual Currency Stored Value Transactions
- TA 310: Total $ amount of Virtual Currency Stored Value Transactions
- TA 320: Total # of Virtual Currency Transmissions
- TA 330: Total $ amount of Virtual Currency Transmissions
- TA 340: TOTAL # of Virtual Currency Transactions. This field should be calculated based on provided information.
- TA 350: TOTAL $ Amount of Virtual Currency Transactions. This field should be calculated based on provided information.
Financial Condition Refinements
The report also contains two additional line items in the Financial Condition tab that further refine reporting requirements:
- FC 630: Net Income (loss) – This is the income from continuing operations before income tax, less income tax. It should be calculated based on information that has already been provided.
- FC 680: Comprehensive Income – This is the sum of net income, income (or loss) from the sale of a segment of the business, extraordinary items net of tax effect, and other comprehensive income or currency translation adjustments. It should be calculated based on information that has already been provided.
Please don’t hesitate to reach out to your team at APPROVED and Orrick with any questions.