MSB Call Report: What Money Transmitters File Each Quarter Through NMLS

The MSB Call Report is the quarterly report that licensed money transmitters and other money services businesses file through NMLS within 45 days of each calendar quarter end. The third quarter 2026 report is due by 14 November 2026 and the fourth quarter report by 14 February 2027, which also carries a full year of destination country data. In 2024, 42 states, the District of Columbia and Puerto Rico required their licensees to file it. A late report places a licence item in NMLS that can block renewal.

The report replaced a patchwork of state forms with one standard filing. It gives every state regulator the same view of a licensee's balance sheet, transaction volumes by state and its permissible investments, which are the eligible assets a licensee must hold to cover what it owes customers. Regulators use it to set examination schedules, calculate assessments and test compliance.

Who must file

Every company holding a money services business licence during the calendar quarter in a state that has adopted the report must file it. That covers money transmitters, cheque cashers, issuers and sellers of money orders, travellers' cheques and drafts, foreign currency dealers, bill payers, prepaid access and stored value providers, and virtual currency businesses.

The report is filed once per quarter at company level, even for a firm licensed in many states. The state transactions section is filed separately for each adopting state in which the company is licensed. A company holding more than one licence type in a state files one report for that state. All sections must be submitted together.

The NMLS 2024 Money Services Businesses Report shows the scale: 2,777 money services companies held 11,221 licences in NMLS, and reported money transmission volume of about USD 4.06 trillion in 2024. Of 599 licensed money transmitter companies, 329 reported money transmission on the call report that year.

Filing is done inside NMLS. Data can be keyed in field by field or uploaded in bulk as an XML or CSV file, which suits firms with high volumes across many states. Only companies with an active NMLS record can file, and NMLS has not set a fee for using the call report. Any company holding a licence during the quarter must file, so a firm approved in late September 2026 files a third quarter report by 14 November 2026 even though it transmitted little or nothing.

Due dates for 2026 and 2027

The report runs on a calendar year, even for firms with a different fiscal year. NMLS sets the deadline as 45 days after each quarter ends.

Some state notices express the same deadlines as the 15th of the month. Nevada's January 2026 memo, for example, lists 15 February, 15 May, 15 August and 15 November. Filing by the earlier date removes the doubt.

The four sections and what each requires

NMLS requires only the fields relevant to the activities selected on the company record. Virtual currency activity does not require destination country reporting.

The rules that cause most errors

The NMLS guidance and frequently asked questions answer most of the questions that produce wrong filings. The key rules are:

• Licensee level, not group level. The financial condition section must reflect the licensee and its own subsidiaries. Parent company consolidated figures are not acceptable.
• US GAAP and US dollars. Figures follow US generally accepted accounting principles unless the field definitions say otherwise.
• Standalone quarters. The balance sheet is reported at quarter end, but the income statement covers only the three months of the quarter, not the year to date.
• A transmission liability stays open until the customer is paid. Sending funds to a paying agent does not close the obligation. It stays outstanding until the beneficiary is paid, the money is refunded or it is handed over as unclaimed property.
• Virtual currency in US dollars. Use a generally accepted exchange rate and be ready to show how the value was reached. Customer virtual currency and all stablecoins go in field FC90; other virtual currency held for the company's own account goes in FC140.
• Customer virtual currency liability cannot be less than customer balances. The outstanding virtual currency liability (FC230) cannot be lower than the virtual currency held for customers (PI140).
• Corrections go to the original quarter. A licensee can revise a submitted report for up to 24 months; an adjustment belongs in the quarter it relates to.

A related point for stablecoin businesses: in March 2026 CSBS issued MTMA guidance on stablecoin tangibility. It confirms that on-balance-sheet, fiat-backed stablecoins redeemable at par for cash count as tangible assets when calculating tangible net worth, and that stablecoins issued in compliance with the GENIUS Act meet that test.

State-specific additions

The call report is a common core, not the whole of a state's reporting. Common additions include:

Where a state requires only a self-prepared financial statement, the call report can satisfy it. Where it requires compiled, reviewed or audited statements, those must still be filed separately.

What goes wrong, from the regulators' own orders

On 9 February 2026 the Washington Department of Financial Institutions entered a consent order with CoinZoom, Inc.. The statement of charges alleged that the firm's first quarter 2024 call report, due on 15 May 2024, was filed on or about 29 May 2024; that its fourth quarter call report and draft audited financial statements contained conflicting figures; and that its 2022 and 2023 annual assessment reports did not reconcile with the four quarterly call reports for those years. Combined with a net worth shortfall and late reporting of adverse actions, the order required surrender of the Washington licence, a three-year industry ban and a USD 150,000 fine, of which USD 50,000 was stayed. CoinZoom did not admit wrongdoing.

The common errors we see map closely to that list:

• filing late because the quarter close takes longer than 45 days
• using parent group figures instead of licensee-level figures
• reporting year-to-date income in a quarterly field
• closing transmission liabilities when funds reach a paying agent
• state volumes that do not add up to company-wide volumes
• permissible investments that do not match the ledger
• call reports that do not reconcile to audited accounts or state annual reports

Building a repeatable quarterly process

1. Close the books at licensee level within 20 to 25 days of quarter end, separate from any group close.
2. Run the outstanding obligations report from the transaction system and reconcile it to the general ledger.
3. Map transactions to states using the customer location rules each state applies, and check the state totals against the company-wide total.
4. Calculate permissible investments at market value and confirm the coverage figure.
5. Prepare the filing in NMLS and clear the completeness checks. Warnings can be submitted with an explanatory note where the figure is correct.
6. Review and sign off by someone other than the preparer, comparing the report with the prior quarter and the last audited accounts.
7. Submit by the due date and confirm no licence item remains.
8. Keep the workpapers so the figures can be explained at examination or renewal.

The same data then feeds the annual NMLS renewal and the audited accounts, which is why accuracy each quarter matters more than speed at year end.

How the call report fits the wider reporting calendar

The call report is one of several recurring filings for a licensed money transmitter, alongside licence renewal, audited accounts, surety bond maintenance and federal reporting under the Bank Secrecy Act for a FinCEN-registered money services business. Our guide to multi-jurisdiction regulatory reporting sets the US cycle beside UK, EU, Canadian and Australian reporting for firms licensed in several markets.

Regulatory Counsel prepares and reviews MSB Call Reports as part of its regulatory reporting service, including reconciliation to audited accounts and state annual reports.