Many people confuse MSB renewal, re-registration, and corrections, leading to compliance gaps that can result in exam findings and even cost up to $5,000 per day in fines.
This guide explains exactly when each filing type–MSB renewal vs. re-registration vs. corrections–applies and how to handle them.
Related: What Is a Money Services Business (MSB)? MSB Registration Explained
MSB Renewal: Your Biennial Check-In
MSB renewal is straightforward: every two years, you file an updated Form 107 to keep your registration active. The deadline is December 31 of your renewal year (either odd or even years, depending on when you originally registered).
Renewal is purely calendar-driven. No specific business event triggers it. You'll update all sections of the form—business details, agent lists, ownership information—even if nothing has changed, to confirm accuracy.
What to know:
- File by December 31 of your biennial cycle
- Covers all current business information
- Missing the deadline invites immediate penalties and increased scrutiny
Consider syncing your MSB renewal reminders with state MTL renewal dates to avoid overlapping deadlines.
Related: Unified MTL Exams: What Networked Supervision Means for You
MSB Re-Registration: When Major Changes Happen
Re-registration is different from renewal. It's triggered by significant changes to your business structure, not the calendar. When a triggering event occurs, you must file a complete new Form 107 promptly upon discovery, within 180 days. This resets your two-year registration clock.
Events that trigger re-registration:
- Ownership or control changes under applicable state law (such as new majority stakeholders)
- Transfers of more than 10% of voting power or equity interest (SEC-reported transfers are exempt)
- Agent network growth exceeding 50% during your current registration period
These triggers reflect real structural shifts—acquiring another company, bringing on major investors, or rapidly expanding your agent network. Filing promptly prevents compliance gaps that could stall licensing efforts.
MSB Corrections: Fixing Non-Material Errors
Corrections address clerical mistakes or outdated information discovered after you've filed. Unlike renewal or re-registration, corrections don't require a full Form 107 refile. You submit an amendment through supplemental filing or notice per Form 107 instructions.
Common correction scenarios:
- Typos in addresses or names
- Outdated contact information
- Minor agent listing errors
File corrections as soon as you discover the error—there's no 180-day window and no impact on your registration period. Note that structural changes like ownership shifts require re-registration, not a correction.
