From November to February, a licensed US money transmitter renews its state licenses in NMLS between November 1 and December 31, files the third-quarter MSB Call Report by November 14 and the fourth-quarter report by February 14, and revises its agent list each January 1. In the last year of each 2-year registration period, its FinCEN registration renewal is due by December 31 too.
NMLS annual renewal: November 1 to December 31
State licenses managed in NMLS, including money transmitter licenses, renew in the annual renewal period from November 1 to December 31. Most of the work happens before the window opens:
- Review your company record (Form MU1) and branch records (Form MU3) and bring them up to date.
- Check every license is in a status that can be renewed.
- Resolve outstanding license items the states have set.
- Read each state's renewal checklist for extra requirements and fees.
Not every state uses the full window. Georgia's renewal period for money services businesses runs from November 1 to December 1, and later renewals can be fined. If you miss December 31, some states allow reinstatement from January 1 to the end of February. A license that isn't renewed can be terminated, and getting it back means applying again.
MSB Call Reports: November 14 and February 14
The MSB Call Report is due within 45 days of each calendar quarter end. Two of the four fall in this stretch:
- Third quarter, July to September: November 14.
- Fourth quarter, October to December: February 14, together with the annual transaction destination country sections.
If a state sets a different deadline in its own law, you file the full report by that state's deadline.
FinCEN registration renewal: December 31, every 2 years
Money services businesses register with FinCEN for 2-calendar-year periods, and renew by filing FinCEN Form 107 by December 31 of the year before each new period starts (31 CFR 1022.380). If you first registered in 2025, your initial period is 2025 and 2026, and the renewal for 2027 and 2028 is due by December 31, 2026.
A change in ownership or control, a transfer of more than 10% of voting power or equity that you report to a state, or a more than 50% increase in agents means re-registering within 180 days, which starts a new 2-year period. See the FinCEN MSB registration renewal for the detail.
January 1: the agent list
If you use agents, you revise your agent list each January 1, under the same registration rule (1022.380(d)). It's easy to forget in the middle of renewal season.
The rest of the year
- Audited financial statements: many states ask for them within 90 days of your fiscal year end.
- Independent AML review: your AML program needs independent review on a regular basis (31 CFR 1022.210).
- OFAC blocked property: if you hold any, report it by September 30 each year (31 CFR 501.603).
- New York licensees: the Part 500 cybersecurity certification and the Part 504 certification by April 15.
- Suspicious activity reports aren't on a calendar, but each one has its own 30-day deadline.
Get reminded before each deadline
Regmindr sets up your compliance calendar from a template in about two minutes, and emails your team before each deadline is due.
Sources
- NMLS: Annual renewal overview for companies
- NMLS: MSB Call Report reporting frequency
- Georgia Department of Banking and Finance: How do I renew my MSB license?
- 31 CFR 1022.380: Registration of money services businesses
- 31 CFR 1022.210: Anti-money laundering programs for money services businesses
- 31 CFR 501.603: Reports of blocked property
This page is a summary, not legal or regulatory advice. The rules in the sources above take precedence.