Keeping up with money transmitter license regulations and deadlines is stressful on it’s own without the added stress of the holiday season. It’s easy for renewals to get left ’til the last minute, forgotten or not submitted in their entirety; so here are four tips to keep you ahead and ready for the MTL renewal season.
TIP 1: Plan Ahead
Understanding what regulatory requirements and expectations are in every state where you conduct business can be overwhelming in itself. Add in an annual reporting requirement for nearly every state that so happens to fall in the middle of the holiday vacation season and you have a stressed out compliance team on your hands.
If that weren’t enough, the specific requirements, expectations, and processes could very well have changed since the prior renewal period. That’s not the sort of thing one could afford to contend with as deadlines approach and your team is scheduling time off for the holidays. That’s why it’s important to plan ahead by coordinating calendars, and making sure you know and understand what is required of your institution from each state regulator. Pay careful attention to the deadlines and how they reasonably align with your team’s calendar and available resources
That’s why it’s important to plan ahead by coordinating calendars, and making sure you know and understand what is required of your institution from each state regulator. Pay careful attention to the deadlines and how they reasonably align with your team’s calendar and available resources.
TIP 2: Be Proactive
Don’t wait until the day before or even a week before the deadline, start your preparations early. Even if the submission window is not yet open with the regulator, you should begin the process. Compile the necessary information, coordinate and marshal internal resources, and ultimately prepare the renewal paperwork even if it’s an internal draft copy.
Remember, deadlines vary state-to-state, so be sure to prioritize those due first, while also beginning to work on those that may require more of your time, resources, and attention. Bottom line, the sooner you jump in and the more proactive you are, the greater control you will have over renewal season. It’s best to have this under control, before it controls you.
As compliance professionals, we’re all super busy and it’s easy to set aside seemingly “administrative” tasks when your work queue is already full. But an ounce of prevention (and preparation) can go a long way to saving you time (and regulatory headaches) in the long run.
Finally, it’s worth noting that this is a busy time of year for regulators as well. Like you, they have a long list of important tasks to accomplish and only so many hours (and days in the year) to accomplish them. As well, the number of MSB licensees has climbed dramatically in recent years, so there very well could be a long line. Demonstrate some patience and (renewal season) holiday cheer.
TIP 3: Stay Up-to-Date
requirements and reports that may be due early in the year or just after renewals are submitted. These again vary by state, but knowing and understanding what is needed from you and your business is one way to stay ahead of the curve. Allow for extra time to be given in the event that any requirements change or you receive a request from regulators to provide additional or other pieces of information. This will keep you from frantically trying to get last minute reports together to meet requirements and possibly miss a deadline.
In addition to recurring reports that are due throughout the year, don’t forget about those advance change notifications (also known as extraordinary reporting requirements). Each state has a series of events that they consider material and in turn need an advance notice of those changes. These vary by state and could include a change of ownership or even something as seemingly benign as a change of office address.
So, yes, take the time to take that victory lap around the office after making it through renewal season, but stay up-to-date and dialed-in as we enter the new year.
TIP 4: Avoid Fines
As we said, planning ahead will help you stay on time and task, and lessen the stresses of renewal season. There is also an important monetary incentive to planning your work and working your plan. Late or incomplete renewals and other regulatory requirements can result in fines, which can reach into the hundreds and even thousands of dollars per day.
Importantly, several states generally do not consider an annual renewal (or other reports throughout the year) to be submitted on time until it is “completed.” A completed report means no errors and that all required or requested information is provided. Considering how requirements can and have changed and increased over the years, this leaves a lot of room for potential errors, oversights, or incomplete reports.
With this and the other tips we’ve shared, it is our hope that you are able to mitigate the potential for any late or incomplete reports this renewal season.
BONUS TIP: Put An Ace Up Your Sleeve
Don’t you just love bonus tips? We sure do! ComplyFit is the ace up your sleeve you’ve been looking for. It is a groundbreaking SaaS tool designed to help you to accomplish tips 1-4 for each state or territory in which your business has a state money transmitter license. With it’s easy to use dashboard and email reminders, you know exactly what quarterly, annual, and ad hoc reports are coming due.
You can plan ahead by looking into each state’s requirements and sync your favorite calendar with the individual tasks. Gone are the days of spending hours scouring statutes and regulatory websites to spot reporting changes. ComplyFit takes care of all this and more, which in turn, will help you to reduce the chances of fines for late or missing reports. (Yay!)
We would be happy to show you a quick demo so you can see how ComplyFit can save you time, precious resources, and headaches during the holiday reporting season and beyond. Schedule a demo today!
