How to renew your MSB registration in BSA E-Filing

Step 1: fix your due date

Renewal timing comes from 31 CFR 1022.380(b) (eCFR text read 2026-08-25, current through 2026-08-24): “Each two-calendar-year period following the initial registration period is a renewal period,” and “The registration form for a renewal period must be filed on or before the last day of the calendar year preceding the renewal period.” In practice every due date is a December 31, and FinCEN’s instructions work the arithmetic for you: “if an MSB registered on October 15, 2003, it must file a renewal by December 31, 2004, and then every 24 months thereafter (on or before December 31, 2006, then December 31, 2008, etc.).”

Note the trap in that example: after an initial registration the first renewal is due the very next December 31, not two years out. The two-year rhythm starts only after that first renewal. If you are unsure which December 31 is yours, the lookup at msbrenew.com/check shows what the public register has on file for your business and the renewal date that filing computes to; your own records decide, because the register does not say whether your last filing was an initial registration or a renewal.

Step 2: enroll in BSA E-Filing, once

Filing is electronic. FinCEN’s instructions: “Mandatory E-filing requires the electronic filing of the Registration of Money Services Businesses (RMSB) using the BSA E-Filing System.”

If your business already has a BSA E-Filing account from the last cycle, skip ahead. If not, the instructions say to visit the system’s site, click “Become a BSA E-Filer,” and enroll as an “Institution,” then complete the four enrollment steps. Enrollment is free: FinCEN’s announcement of MSB e-filing (news release of July 18, 2011, retrieved 2026-08-25) describes BSA E-Filing as “a free, web-based electronic filing system.”

Step 3: open a new RMSB and mark it a renewal

From the instructions, verbatim path: “At the ‘Welcome to the BSA E-Filing System’ home page, click on File FinCEN RMSB found under ‘New Reports’ on the left-hand side of the screen.” Part I of the form asks for the filing type; check the renewal box, not initial registration, and enter your existing registration number (BSA ID) where the form asks for the prior filing’s number. The instructions provide for the worst case: “Enter ‘00000000000000’ in 1e if the registration number is unknown.”

Complete every part of the form fresh, as if registering: registrant information, owner or controlling person, activities and states, the primary transaction account, and the location of supporting documentation. FinCEN’s own burden estimate for the whole exercise, from the Paperwork Reduction Act notice in the instructions, is “45 minutes per response.”

Step 4: validate, sign, save, submit

The instructions give the exact sequence: click “Validate” to surface incomplete required fields, then “Sign with PIN,” then “Save” a copy of the completed RMSB locally, then “Submit.” Saving before submitting is not optional housekeeping; the copy feeds the retention obligation in step 6.

On submission you should see a Submission Confirmation page with a Tracking ID. Keep it. It is the only artifact you hold at this point that proves the filing left your hands.

Step 5: watch for the acknowledgement, then verify in public

Two confirmations follow, on two clocks. Within roughly two business days, per the instructions, “filers should receive an acknowledgement e-mail to the ‘Secure Messaging Inbox’ within their BSA E-Filing System account indicating their registration has been accepted and processed,” carrying the MSB Registration number (BSA ID). Within roughly two weeks, the registration surfaces publicly: FinCEN’s Registrant Search Q&A (read 2026-08-25) states “MSBs will be added to the Web page within approximately two weeks of electronically filing their Registration of Money Services Businesses (RMSB) (Form 107),” and the search page lets you print an “MSB Registration Status Information” letter.

Do not plan on confirming by phone. The same Q&A page: “FinCEN will not provide registration confirmation via the Regulatory Helpline or the E-Filing Help Desk.”

Step 6: retain the paperwork for five years

The filed form and its supporting documentation must stay at a location in the United States. FinCEN’s registration guidance page (read 2026-08-25) lists what that documentation is: a copy of the filed form, an estimate of business volume for the coming year, ownership or control information, and the agent list. The retention period comes from 31 CFR 1010.430(d) (read 2026-08-25): “All records that are required to be retained by this chapter shall be retained for a period of five years.”

The agent list has its own clock inside the cycle: under 31 CFR 1022.380(d)(1) it “is not filed with the registration form but must be maintained at the location in the United States reported on the registration form,” and must be revised each January 1 for the preceding twelve months.

When to do all this

Earlier than your cohort does. Among the 9,690 registrants whose renewal falls due 2026-12-31, counted on the FinCEN export read 2026-08-21, 2,288 (23.6%) filed the registration currently on record in December 2024, against the December 31 wire (counted on our extraction of the public register, 2026-08-21). The deadline is the last day of the calendar year, the regulation’s own words quoted in step 1, and nothing in the rule rewards waiting for it. An e-filed renewal in October costs the same 45 minutes and leaves eleven weeks of margin for a rejected validation, a lost PIN, or an enrollment that lapsed since 2024.