NMLS recently announced updates to the Money Services Business (MSB) Call Report, which will take effect starting with the third-quarter MSB Call Report filings due Nov. 14, 2024.
These updates aim to better align the report with the Model Money Transmission Modernization Act (MTMA) and further refine financial reporting requirements with adjustments to the permissible investment section and state transaction details.
Realigned permissible investments section
The MSB Call Report will include updates to the permissible investment line items to align with the MTMA’s permissible investment types. These changes include definition adjustments to current fields and new breakouts. Impacted fields include:
- Revise and expand PI20 (Deposits in All Foreign Banks)
- Expand PI60 (Due from agents (net of allowance for doubtful accounts))
- Revise and expand PI70 (Investments rated A or its equivalent and above)
- Update PI105 (Subtotal for Permissible Investment Calculation)
New state transactions transmission liability fields
The report will also feature new line items for surety bonds and state-specific average daily outstanding transmission liability (ADTL) in a new Transmission Liability Section:
- New field ST360 (Surety Bond): Report the amount of the surety bond held in the state
- New field ST361 (Total ADTL in the State): Report the average daily transmission liability in the state for the quarter
- New calculated field ST362 (Surety Bond Amount for Permissible Investment): ST360 minus ST361
These new fields were added based on input received during the NMLS public comment period related to the permissible investments field adjustments. The new fields are intended to support compliance standards outlined in the MTMA, enhancing the accuracy of state transaction reporting. Full definitions can be found here.
Implementation timeline
These changes are effective for the Q3 2024 MSB Call Report filings, due on November 14, covering the period from July 1 to September 30. Companies should incorporate these updates into their reporting processes to ensure compliance.
APPROVED can help
Please contact us if you have any questions or need assistance with the Q3 2024 MSB Call Report.