Does Colorado require MSBs to register with the state as well as with FinCEN?

Colorado does not require MSBs to register with the state. Division of Banking Operating Memorandum issued 2-13-02 indicates that MSBs must register with FinCEN, and that the state will obtain a list from them. The OM is here: http://www.dora.state.co.us/banking/operatingmemos/opermemo.htm

Colorado requires "money transmitters" and "money order companies" to be licensed, but it does not require MSBs who aren't operating in that capacity to be licensed or to register with the state.

Here's a link to the Money Order/Money Transmitter regulations.