What Is the NMLS MSB Call Report, and How Is It Filed?

Key takeaways

• The MSB Call Report is the uniform report licensed money services businesses file through NMLS, replacing separate state reports in adopting states.
• Sections I, II(a), II(b) and III are due 45 days after the end of each calendar quarter; Sections IV(a) and IV(b) are filed with the fourth quarter report for the full year.
• Section I is the licensee's own financial condition under US GAAP, consolidated with its subsidiaries but never with its parent.
• Section II(b) reports activity in each state, including the surety bond, average daily transmission liability and the bond amount available as a permissible investment.
• Filed reports can be revised for up to 24 months, and the data is shared with every state regulator through NMLS.

What are the key facts on the MSB Call Report?

The MSB Call Report is the quarterly regulatory report for licensed money services businesses in the United States, shared with every adopting state.

Who must file the MSB Call Report?

Every company that held an MSB license in an adopting state at any point during the calendar quarter.

NMLS describes the report's purpose as providing timely, comprehensive and uniform information on licensees' financial condition, transactional activity and compliance with permissible investment requirements, in place of individual state reports. The submission guidance covers money transmission, check cashing, travelers checks, drafts, foreign currency dealing, money orders, bill paying, prepaid access and stored value, and virtual currency. The filer needs an active NMLS record. Section II fields are required only for the activities the company selected on its Company Form (MU1), so a check casher completes far less than a multi-product money transmitter.

What are the sections of the report?

Six sections: financial condition, company and state transactions, permissible investments, and two destination country sections.

The NMLS section guide notes that virtual currency activity does not require destination country reporting in Section IV.

What does Section I require?

The licensee's own financial condition, under US GAAP, in US dollars.

According to NMLS, Section I is prepared under GAAP unless the field definitions direct otherwise, consolidated at the licensee level including its subsidiaries. Parent-level figures, or figures that include the parent's financial information, are not acceptable. Virtual currency is valued in US dollars using a generally accepted exchange rate, and the licensee should be able to document that valuation. In adopting states, a company required to file a self-prepared financial statement can use the call report for that purpose; one required to file compiled, reviewed or audited statements must still file those separately through NMLS. Section I is where regulators test capital requirements such as tangible net worth under the MTMA.

What does Section II(b) ask for each state?

Counts and dollar amounts for each activity in the state, plus the state's bond and liability figures.

Field ST362 is ST360 minus ST361: the part of the bond above average daily liability, which under MTMA-based laws counts toward permissible investments. Our guide to average daily money transmission liability explains ST361, and the NMLS state detail page lists every field.

What does Section III cover?

The company's permissible investments and its outstanding and average daily transmission liability.

Section III lists assets from PI10 to PI115, liabilities in PI120 and PI130, and virtual currency in PI140 to PI180. Its PI105 subtotal does not apply state caps, so each licensee must test its figures against each state's rules separately. Our line-by-line guide to Section III and our state-by-state table of permissible investments cover both steps.

How is the report filed and corrected?

Through NMLS, by manual entry, CSV upload by section or XML upload, with all required sections submitted together.

Sections can be prepared in advance but are submitted as one filing. A licensee may revise a previously submitted quarterly report for up to 24 months after submission. NMLS states the data is confidential but available to all state regulators under the system's information-sharing arrangements, which it says are permitted under 12 U.S.C. 5111. Some states add their own requirements: the Texas Department of Banking, in a memo of November 13, 2023, told licensees to keep completing a Texas permissible investment report alongside the call report, due within 45 days of quarter end and kept on file for examiners.

What does a filing calendar look like?

Four quarterly deadlines, with the destination country sections added to the fourth.

Worked example. A money transmitter licensed in 32 adopting states with foreign transmission activity plans its next four filings, counting 45 days from each quarter end.

In one state, Section II(b) shows a surety bond of $500,000 in ST360 and average daily transmission liability of $380,000 in ST361, so ST362, the bond available for permissible investment, is $120,000. That $120,000 must agree to the bond line in the licensee's Section III working papers for MTMA states. All four due dates in this example fall on a Saturday or a Sunday, so licensees should confirm with NMLS how the deadline applies rather than assume it moves to the next business day.

Which figures must agree across sections?

Regulators compare sections with each other, and with other filings, for the same quarter.

• Cash and investments in Section III should be consistent with the balance sheet in Section I.
• Outstanding transmission liability in PI120 should move in line with volumes in Sections II(a) and II(b).
• The sum of state-level activity in Section II(b) should reconcile to company-wide activity in Section II(a).
• Average daily liability by state in ST361 should be supportable from the same daily records as PI130.
• Financial statements filed separately should agree with Section I for the same date.

Because the report is shared through NMLS with every adopting state, an inconsistency is visible to all of them at once.

How should a licensee run the quarterly process?

As a short close that starts from reconciled daily records, not as a new exercise after quarter end.

The timetable works only if the daily figures already exist. A licensee that reconciles obligations and assets every day takes Section II(b) liability averages and Section III balances from its history; one that does not must rebuild 90 days of positions under deadline.

What are the common errors?

Most errors are classification and scope problems rather than arithmetic, and most can be caught by comparing the draft with the previous quarter.

• Including the parent company's figures in Section I, which NMLS does not accept.
• Reporting Other Investments in PI100 above 20% of PI105 without the explanatory note NMLS expects.
• Omitting Section II(b) for an adopting state where the licensee holds a license but had little activity.
• Calculating average daily transmission liability from month-end balances.
• Valuing virtual currency from a single exchange rather than an active-market price.
• Forgetting Sections IV(a) and IV(b) in the fourth quarter filing.

What should be checked before filing?

These checks catch most errors before regulators do.

• Confirm the activities selected on the MU1, which drive the Section II fields required.
• Prepare Section I at licensee level, consolidated with subsidiaries and excluding the parent.
• Build Section II(b) for every adopting state where the company is licensed.
• Agree ST360 to the bond on file and ST361 to the daily liability history for each state.
• Complete Section III and the state cap analysis from reconciled figures.
• Add Sections IV(a) and IV(b) to the fourth quarter filing if the company transmits abroad.
• File within 45 days of quarter end and correct errors promptly through the amendment process.

How does Safeheld help?

Safeheld reconciles bank, custody and ledger records for each entity and currency every day and produces a prepared report pack for the NMLS MSB Call Report, which the licensee reviews and completes.

See regulatory evidence.

Frequently asked questions

What is the MSB Call Report?

The uniform report that licensed money services businesses file through NMLS on their financial condition, transactions and permissible investments, in place of separate state reports in adopting states.

When is the MSB Call Report due?

Sections I, II(a), II(b) and III are due 45 days after the end of each calendar quarter. Sections IV(a) and IV(b) are filed with the fourth quarter report and cover the full calendar year.

Who must file the MSB Call Report?

Every company holding at least one MSB license in an adopting state during the calendar quarter, with an active NMLS record.

What are the sections of the MSB Call Report?

Section I Financial Condition, Section II(a) Company-wide Transactions, Section II(b) State Transactions, Section III Permissible Investments, and Sections IV(a) and IV(b) Destination Country Detail.

Can a filed MSB Call Report be amended?

Yes. Licensees may revise a submitted quarterly report for up to 24 months after submission.

Does Section I include the parent company?

No. It is consolidated at the licensee level with its subsidiaries; parent-level figures are not acceptable.

Do virtual currency licensees file destination country data?

No. NMLS states that virtual currency activity does not require destination country reporting in Section IV.

How is the MSB Call Report filed?

Through NMLS, by manual entry, by uploading a CSV template for each section, or by uploading an XML file, with all required sections submitted together.

References

• NMLS, MSB Call Report overview and definitions
• NMLS, MSB Call Report detail report sections
• NMLS, MSB Call Report reporting frequency
• NMLS, Submission of the MSB Call Report
• NMLS, MSB Call Report financial condition (Section I)
• NMLS, MSB Call Report Section II(b): state transaction detail
• Texas Department of Banking, memo on permissible investment reporting (November 13, 2023, PDF)

About Safeheld

Safeheld is reconciliation and regulatory financial control software for regulated firms that hold client money. For US money services businesses it reconciles obligations and assets every day and prepares the call report figures from the same records, for the licensee to review and file. To discuss your money transmission operations, contact us at safeheld.com/contact.

This article is general information on US money services business reporting and is not legal or regulatory advice.