Money Transmitter Licence Maintenance
The state-level work that keeps every money transmitter licence in good standing: renewals, call reports, bonds, net worth, permissible investments, change filings and examinations.
Money transmitter licence maintenance is the work that keeps every state licence in good standing between renewals: NMLS renewals, quarterly MSB Call Reports, audited accounts, surety bonds, net worth and permissible investments, change of control and key individual filings, and examination preparation. We run it as one calendar across every state you hold.
Speak to a compliance expertSpeak to a compliance expert
Tell us the business, the states you hold licences in and where your programme stands. Every enquiry is answered the same business day, with a written proposal setting out the scope, the team and the timing.
Your enquiry
What we do
A money transmitter licence has to be kept, not only won. Each state expects quarterly reports, audited accounts, a surety bond and net worth that move with the business, permissible investments that cover customer obligations every day, approval before a change of control and a clean renewal every year. The model law behind most of these rules, the Money Transmission Modernization Act, had been adopted in full by 23 states and in part by 8 by August 2026.
We keep one calendar for every licence and one file for every state. We reconcile each [MSB Call Report](/insights/msb-call-report-nmls-guide) to the accounts before it is filed, test the bond and net worth against volumes each quarter, clear licence items in NMLS before the renewal window opens and prepare every [renewal](/insights/nmls-annual-renewal-money-transmitters-2026) in October rather than December.
When the business changes, the licences have to follow. New investors, new key individuals, new products and new states each carry their own filing and deadline. We prepare and track those filings, and support the firm through state examinations from the first-day document request to the final report.
Footprint review
Every licence, open NMLS item, bond, net worth position and deadline, in one view.
One calendar
Federal and state dates for the year, with an owner and evidence for each.
File and reconcile
Call reports, renewals, amendments and change filings prepared, checked and filed.
Examination support
Document requests, interviews and responses managed through to the final report.
What's Included
NMLS renewals
Licence items cleared, records updated and every renewal filed well before 31 December.
MSB Call Reports
Quarterly reports prepared, reconciled to the accounts and filed within 45 days of quarter end.
Bonds and net worth
Required amounts recalculated each quarter, with riders filed when volumes rise.
Permissible investments
Daily coverage of customer obligations, evidenced monthly and reported quarterly.
Change filings
Change of control applications, key individual notices and record amendments in NMLS.
Examination preparation
First-day document lists, evidence packs and responses for state examiners.
The licence maintenance year
Standards shown are those of the Money Transmission Modernization Act. State versions vary, and we confirm each state in your footprint.
| When | Work | Rule |
|---|---|---|
| 1 November to 31 December | NMLS renewal for every licence, with licence items cleared first | State law; NMLS |
| 14 Nov, 14 Feb, 15 May, 14 Aug | MSB Call Report, reconciled to the accounts | 45 days after quarter end |
| Within 90 days of year end | Audited accounts and annual report | MTMA 7.02 |
| Each quarter | Bond and net worth tested against volume and assets | MTMA 10.01 and 10.02 |
| Daily, evidenced monthly | Permissible investments cover customer obligations | MTMA 10.03 |
| Before the change | Change of control approval (25% presumed control) | MTMA 6.01 |
| Within 15 days | New key individual notice | MTMA 6.02 |
| Every two years by 31 December | FinCEN Form 107 renewal | 31 C.F.R. 1022.380 |
Who this service is for
Firm types
- - Money transmitters licensed in several states
- - Payment fintechs with a growing state footprint
- - Crypto firms holding money transmitter licences
- - Foreign groups with a licensed US subsidiary
Situations & Triggers
- - Renewal window approaching with open licence items
- - Late or inconsistent call reports
- - Investment or acquisition changing control
- - State examination notice received
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
NMLS Annual Renewal for Money Transmitters: The 2026 Checklist
The 2026 NMLS renewal window for money transmitter licences runs from 1 November to 31 December. What regulators check, the fees, reinstatement rules and the deficiencies that stop a renewal.
MSB Call Report: What Money Transmitters File Each Quarter Through NMLS
The MSB Call Report is due 45 days after each quarter end. Due dates for 2026 and 2027, the four sections, state-specific additions and the errors that lead to enforcement.
Money Transmitter Compliance Calendar: November 2026 to December 2027
Every recurring federal and state compliance date for US money transmitters from November 2026 to December 2027: renewals, call reports, Form 107, audited accounts and event-driven deadlines.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a compliance expertFrequently asked questions
NMLS renewals, quarterly MSB Call Reports, audited accounts and annual reports, surety bond and net worth monitoring, permissible investments, change of control and key individual filings, record amendments in NMLS and examination preparation.
1 November to 31 December in most states. For 2026, licensees must complete updated NMLS disclosure questions and employment reporting before a renewal request can be submitted.
Within 45 days of each calendar quarter end: 14 November, 14 February, 15 May and 14 August.
Each state sets its own rule. Under the MTMA model it is the greater of USD 100,000 or the average daily money transmission liability in the state over the last three months, capped at USD 500,000, so it can rise as the business grows.
Under the MTMA, control is presumed at 25% of voting interests, and a holder of 10% or more is presumed to have controlling influence unless that is rebutted. Prior written approval is needed before control is acquired.
Yes. We manage filings across the whole footprint, including states that collect some items outside NMLS, and confirm each state's own rules rather than relying on the model law.
Yes. Some states allow reinstatement of an expired licence in January and February with extra fees, and late or wrong call reports can be filed or amended. The sooner the gap is closed, the fewer states raise it at renewal.
As a fixed retainer scoped to the number of states and filings. The scope and the fee are set out in writing before work begins.