FinCEN MSB activity codes, the full key with live counts

The key, verbatim

FinCEN titles the block “* NEW KEY-Form 107 (effective on 3/2012)”. Sixteen codes:

Full-export counts are over all 33,288 registrant rows of the raw export downloaded 2026-08-25, before deduplication, so a registrant with several filings on record is counted per row. Cohort counts are over the deduplicated 9,690-registrant renewal cohort extracted 2026-08-21. A registrant declaring several activities is counted once per code in both.

Six codes in the key, zero in the register

Codes 403, 406, 407, 410, 411, and 412 appear on no row of the 33,288-row export. The key carries them anyway. For four of the six, the current regulatory definitions explain the emptiness:

• 403 and 406, the redeemer codes. The MSB definition at 31 CFR 1010.100(ff)(3) (eCFR text read 2026-08-25, current through 2026-08-24) covers an “Issuer or seller of traveler’s checks or money orders”. Redeeming, on its own, is no longer one of the listed capacities, so nothing maps to these codes.
• 407, currency dealer or exchanger. The current definition at 1010.100(ff)(1) names the capacity “Dealer in foreign exchange”, which the key carries as 415. The 8,210 rows sit there.
• 412, U.S. Postal Service. The USPS is listed as an MSB capacity at 1010.100(ff)(6), but the registration rule exempts it: 31 CFR 1022.380(a)(1) states “This section does not apply to the United States Postal Service, to agencies of the United States, of any State, or of any political subdivision of a State.” An exempt filer produces no rows.

For 410 and 411, the combined sales-and-redemption codes, we found no FinCEN document stating their status; their wording overlaps codes 401 to 406 and they read as legacy entries. That is a reading, not a sourced fact, and we flag it as such.

What the thresholds behind the codes mean

A code on a registration means the filer declared the activity. Whether an activity makes a business an MSB in the first place carries thresholds, set in 31 CFR 1010.100(ff) (read 2026-08-25):

• Dealing in foreign exchange (415), check cashing (408), issuing or selling traveler’s checks or money orders (401, 402, 404, 405): the definition applies above $1,000 per person per day. The check casher wording is representative: a person that accepts checks “in an amount greater than $1,000 for any person on any day in one or more transactions.”
• Money transmission (409): no threshold. FinCEN’s registration guidance page (read 2026-08-25) is explicit: “No activity threshold applies to the definition of money transmitter. Thus, a person who engages as a business in the transfer of funds is an MSB as a money transmitter, regardless of the amount of money transmission activity.”
• Seller of prepaid access (413): defined by conditions at 1010.100(ff)(7), including sales of prepaid access to funds exceeding $10,000 to any person in a day without preventive policies.
• Provider of prepaid access (414): the program participant with “principal oversight and control over the prepaid program” under 1010.100(ff)(4). At 153 rows in the whole register, it is the rarest declared activity.

Reading a registrant’s code list

Three usage notes, each observable in the FinCEN export read 2026-08-25. First, most registrants declare few codes: in the renewal cohort, 7,750 of 9,690 registrants (80.0%) declare one, two, or three activities, and the single most common declaration is 408 alone, check cashing, on 1,844 registrants. Second, codes describe declared capacity, not verified conduct; the declaration is self-reported on the registration form. Third, dense code lists cluster: 1,086 cohort registrants declare the identical eight-code set 401, 402, 404, 405, 408, 409, 413, 415, a concentration analyzed separately in the Colorado data note. To see which codes a specific registration declares, the lookup at msbrenew.com/check reads the same export this table was counted from.

Method and sources

The key is transcribed from the trailing legend block of the FinCEN bulk export (the literal form submission of the Export to Excel button on the public MSB Registrant Search page), downloaded 2026-08-25. Counts were computed the same day with a script over that file, and over the deduplicated cohort file extracted 2026-08-21. Regulatory definitions: 31 CFR 1010.100(ff) and 31 CFR 1022.380(a)(1), eCFR full text read 2026-08-25, current through 2026-08-24. The current electronic form does not display these numeric codes to the filer; it presents activities as named checkboxes (Item 36 of the Registration of Money Services Business per FinCEN’s RMSB Electronic Filing Instructions, July 2014, retrieved 2026-08-25). The codes are how the public register encodes those answers.