Seventeen state agencies, affecting 22 license types, have currently committed to adopt the NMLS MSB Call report for Q1 2017 reporting. The NMLS MSB Call Report applies to licensees who conduct the following activities: money transmission, check cashing, issuing or selling travelers checks, issuing or selling drafts, foreign currency dealing and exchange, issuing or selling money orders, bill paying, issuing or selling prepaid access/stored value products, and virtual currency that hold a Money Services Business (MSB) license during the calendar quarter in adopting jurisdictions. The majority of agencies are mandating reporting through NMLS. As such, the time to verify that your systems are collecting the correct data points is now.
NMLS currently acts as the system of record for 36 jurisdictions involved in some aspect of money services business licensing, so anticipate that the number of jurisdictions also requiring the NMLS MSB Call Report will increase as regulators become more comfortable with the new uniform reporting format. Current agencies who have announced that they will adopt the NMLS MSB Call Report as of Q1 2017 include those that regulate MSB-related licenses in Arkansas, Connecticut, Georgia, Illinois, Kansas, Louisiana, Massachusetts, Nebraska, North Carolina, North Dakota, Pennsylvania, Puerto Rico, Rhode Island, South Dakota, Vermont, Washington and Wyoming. You can review the list of included MSB licenses here.
The NMLS MSB Call Report will become active in the system in the first quarter of 2017, with the initial report due May 15, 2017, 45 days after the first quarter end. A Q1 report is expected to contain data collected with respect to licensable activities occurring in adopting jurisdictions between January 1, 2017, and March 31, 2017. Required quarterly reporting includes company level financial condition items, company-wide transactions detail, state transactions detail, and permissible investments reporting. Note the requirements for company-wide transaction detail. A company licensed in one or more of the adopting states must be able to collect company-wide data for submission. Annual requirements, which apply to licensees engaged in foreign money transmission activity, include information regarding all foreign transactions completed during the entire calendar year at a company-wide and state level.
Of concern is the fact that NMLS has not yet provided final XML and data specification files. Companies should familiarize themselves with the draft data specifications found here. In addition, watch for NMLS-provided training opportunities that are posted on the NMLS Resource Center. It appears that NMLS is continuing to solicit initial feedback on what has been built so far and intends to complete additional user testing in January. Unfortunately for affected companies, not having the complete set of finalized data points in hand now creates a challenge in being prepared to accurately collect the necessary data as of January 1, 2017. MSB-licensed companies should be sure to attend NMLS scheduled online trainings, participate in any subsequent user testing opportunities, and consider attending in-person training that is scheduled to take place in connection with the annual NMLS User Conference and Training in February, so that they can insure that they are prepared to submit the correct data points.