How MSB registration and renewal deadlines work
FinCEN sets two separate deadlines for MSBs: one for registering when you begin operating and one for renewing your registration every two years. Both processes are completed using Form 107.
Initial registration
Most Money Services Businesses (MSBs) must register with FinCEN by filing Form 107 within 180 days of beginning MSB activities. The registration requirement applies to MSB principals, while agents operating under a registered principal generally do not file their own registration.
Form 107 must be submitted electronically through the BSA E-Filing System. FinCEN no longer accepts paper filings for MSB registration.
Renewal
MSB registration must be renewed every two years, with each renewal due by December 31.
The renewal schedule is based on the calendar year of your initial registration, not the exact day you filed. Your first renewal is due on December 31 of the year after you registered, and every two years after that.
For example:
- If you register on any date in 2025, your first renewal is due December 31, 2026.
- If you renew in 2026, your next renewal is due December 31, 2028.
FinCEN does not send renewal reminders. If you miss the renewal deadline, your registration lapses. The renewal requirement is established under 31 CFR 1022.380(b).
How to renew your MSB registration
You renew your MSB registration electronically through the BSA E-Filing System using FinCEN Report 107 (RMSB). The process usually takes only a few minutes to complete if you saved your previous Form 107 and your business information has not changed.
Step 1: Log in to the BSA E-Filing System
Sign in to the BSA E-Filing System using the same account your business uses to file CTRs, SARs, or other BSA reports.
Step 2: Open Form 107 (RMSB)
Select “File FinCEN Report 107 (RMSB)”. If you saved a PDF copy of your previous Form 107, open it and update only the information that has changed before submitting it as your renewal. Otherwise, complete a new Form 107 from the beginning.
Step 3: Select Renewal and verify your information
In Part I, check Box 1b (Renewal). Have your BSA ID or previous registration number available to help identify your existing registration.
Carefully review all required fields before submitting, especially your Employer Identification Number (EIN). An incorrect or missing taxpayer identification number can prevent your business from appearing in FinCEN’s public MSB Registrant Search.
Step 4: Sign and submit
Electronically sign the form using your BSA E-Filing PIN, then submit your renewal.
Step 5: Save your proof and verify your listing
Download and save both the submitted Form 107 and the submission confirmation receipt. FinCEN requires MSBs to retain registration records for five years. Because FinCEN no longer mails acknowledgment letters, the submission receipt together with your public listing serves as proof of registration.
Your renewed registration typically appears in the public MSB Registrant Search within about two weeks.
What happens if you miss your renewal deadline
If you miss your MSB renewal deadline, your registration lapses, and continuing to operate without an active registration is unlawful.
A lapsed registration can result in civil penalties of over $10,000 per violation. Each day that the violation continues counts as a separate violation.
FinCEN removes MSBs that fail to renew from the public MSB Registrant Search during its annual purge every May. Banks, payment providers, and other financial partners often use this register to verify that an MSB is properly registered. Being removed from the list can trigger account reviews, additional compliance checks, or account closure due to de-risking concerns.
A lapsed registration may also be identified during IRS BSA examinations and state money transmitter or MSB license reviews.
There is no grace period or separate reinstatement process for expired MSB registrations. The solution is to submit a renewal Form 107 through the BSA E-Filing System as soon as possible.
If your business was removed from the public register, filing the renewal generally restores your listing within about two weeks.
When re-registration is required
Re-registration is a new Form 107 filing required after certain changes to your MSB. It is separate from the regular two-year renewal cycle and has its own filing deadline.
Three events trigger re-registration:
- A change in ownership or control that requires re-registration under state law
- A transfer of more than 10% of the voting power or equity interests (unless the transfer must be reported to the SEC)
- An increase of more than 50% in the number of agents
You must file a re-registration within 180 days of the triggering event.
Re-registration starts a new two-year registration period. Your next renewal deadline is calculated from the year the triggering event occurred, not your original registration year.
When filing Form 107, select Box 1d (Re-registration) in Part I instead of Box 1b (Renewal). If you select Box 1d, the form will also ask you to identify the reason for re-registration, such as re-registration required under state law, a transfer of more than 10% of equity interests, or an increase of more than 50% in the number of agents.
Routine updates, such as an address change or new bank account, do not require re-registration. These changes are handled through an amended filing by selecting Box 1c (Correct/amend a prior report) in Part I.
The three re-registration triggers above are the same checks used in the calculator. If any of them apply to your business, your calculated renewal date no longer controls and you must file a re-registration now.
FinCEN registration vs. state money transmitter license renewal
FinCEN registration and state money transmitter licenses are two separate compliance requirements. Registering with FinCEN does not authorize you to transmit money in any state, and holding state licenses does not satisfy your FinCEN registration obligation. Most money transmitters need to maintain both.
| FinCEN registration (federal) | State money transmitter license |
|---|
| What it is | Registration, not a license | License to operate in that state |
|---|
| Where it's filed | BSA E-Filing (Form 107) | NMLS (most states) |
|---|
| Cost | Free | Application and renewal fees, surety bond, net worth requirements |
|---|
| Renewal | Every 2 years | Typically annual |
|---|
| Deadline | December 31 (calendar-year cycle) | Varies by state; NMLS renewal window is typically Nov 1–Dec 31 |
|---|
| If it lapses | Federal violation, § 1960 criminal risk, removed from the MSB register | Operating unlicensed in that state, also a § 1960 crime |
|---|
The term "MSB renewal" can refer to either federal registration renewal or state license renewal. This calculator covers only the FinCEN MSB registration renewal deadline. State license renewal dates are separate and vary by state.
To check state money transmitter licenses, use NMLS Consumer Access.
This calculator is an independent tool and is not affiliated with or endorsed by FinCEN or the U.S. Department of the Treasury. Deadlines are calculated from the rules in 31 CFR 1022.380. This is general information, not legal or compliance advice. Verify your specific situation at fincen.gov or with the FinCEN Resource Center.