Recently, NMLS announced updates to the Money Services Business (MSB) Call Report effective in the third quarter for filings due November 14. These updates aim to align the report with the Model Money Transmission Modernization Act (MTMA) and refine financial reporting requirements, particularly in the Permissible Investment (PI) section and State Transaction (ST) details. Changes include definition adjustments to current fields and new breakouts in the following fields, like revising and expanding PI20 (i.e., Deposits in All Foreign Banks), expanding PI60 (i.e., Due from agents (net of allowance for doubtful accounts)), revising and expanding PI70 (i.e., Investments rated A or its equivalent and above), and updating PI105 (i.e., Subtotal for a Permissible Investment Calculation).
The report also features new line items for surety bonds and state-specific average daily outstanding transmission liability (ADTL) in a new section titled “Transmission Lability” with three new STs: a new field called ST360 (i.e., Surety Bond) to report the amount of the surety bond held in the state; another new field named ST361 (i.e., the total ADTL in the state) created to report the average daily transmission liability in the state for the quarter; and a newly calculated field named ST362 (i.e., the Surety Bond Amount for Permissible Investment), which is the difference of ST360 from ST361.
These additions support compliance standards outlined in the MTMA and enhance the accuracy of state transaction reporting. These changes go into effect for the Q3 2024 MSB Call Report filings, due on November 14, covering the period from July 1 to September 31.
