Can someone just help me clarify the timing of MSB registrations? The only note in the regs is for initial registrations:

31 CFR 1022.380 - Registration period. A money services business must be registered for the initial registration period and each renewal period. The initial registration period is the two-calendar-year period beginning with the calendar year in which the money services business is first required to be registered. However, the initial registration period for a money services business required to register by December 31, 2001 (see paragraph (b)(3) of this section) is the two-calendar year period beginning 2002. Each two-calendar-year period following the initial registration period is a renewal period.

This says to me ^ that on initial registration, say 6/1/2020, my registration ends 12/31/21 and I need to renew before that date. I know registrations last for 24 months. Why do I see some customer's renew registration on say 9/30/21? They are only getting 15 months out of their registration based on the calendar period rule. What am I missing here?

Their website states: After an MSB completes its initial registration, the form to renew its registration must be filed by December 31 of the second calendar year preceding the 24-month renewal period and is accomplished by filing the Registration of Money Services Business Form, FinCEN Form 107. Thereafter, registration renewal must be filed every 24 months by December 31.

Their own information seems to conflict and I just want to be sure I am clear as to registration period requirements.

ABC Inc - New business - Registration date - 6/1/2020.... We should see a renewal before 12/31/21?
XYZ Inc - Renewal - Registration date on FinCEN's website of 8/30/20 - When is the renewal due?

Of course the renewal calculator was taken off their website....

An initial registration is good until two years after the following December 31st after registration and then every two years after that by December 31st. So, if the original registration was in 2019, they must renewal by Dec 31st, 2022.

Once a year, FinCEN will delete from the MSB Registrant Search Web page any entities that did not renew their MSB registration by their renewal deadline. So, if they are on the list, then I think most banks assume they are properly registered.

If you have questions, just make the customer produce their registration records for the last five years, as a. copy of the filed registration form and other supporting documentation must be retained at a location in the United States by the MSB for a period of five years.

The initial registration period is the two-calendar-year period beginning with the calendar year in which the money services business is first required to be registered.

"Beginning with the calendar year" Isn't that directly contrary to your response? Not trying to be smart here, I just want to be 100% sure.

You failed to quote the rest of 31 CFR 1022.380: " However, the initial registration period for a money services business required to register by December 31, 2001 (see paragraph (b)(3) of this section) is the two-calendar year period beginning 2002. Each two-calendar-year period following the initial registration period is a renewal period."

That is the initial registration rule, so you get two full years and the rest of the year in which you originally register. If you do a random search on the FinCEN website, the only MSBs that I think you will find that last registered in 2019 that are still on the list are ones that had just filed their initial registration.