Licensing
Licensing insights: Common Renewal Mistakes, Q4 Reporting Deadlines, Mortgage & Crypto
September 25, 2025
Most Common MTL Renewal Mistakes (And How to Avoid Them)
Maintaining a Money Transmitter License ("MTL") is a continuous obligation that requires Licensees to timely and accurately renew filings with state regulators. As the renewal process differs from state to state, Licensees often make mistakes that can lead to penalties, license suspensions, or delays in operations. Outlined below are some of the most common MTL renewal mistakes and some strategies for avoiding them.
1. Missing Renewal Deadlines Many Licensees fail to track the varying renewal deadlines across states. Some renewals are due by November 1, others by December 31, and some, well after the new year. Missing a deadline may result in late fees, administrative penalties, or temporary license suspension.
How to Avoid It:
- Maintaining a compliance calendar with all state-specific renewal deadlines.
- Using automated reminders at least 60, 30, and 7 days before each due date.
- Assigning responsibility to a specific team member to monitor deadlines
2. Not Knowing Where to Renew
Not all states process renewals through the Nationwide Multistate Licensing System (“NMLS”). A common mistake is assuming every state uses NMLS (e.g., Florida and New Jersey are non-NMLS), which can result in missing direct submission obligations.
How to Avoid It:
- Identifying which of your licensed states use NMLS for renewals and which require direct filings with the state regulator.
- Maintaining a state-by-state matrix that notes the renewal platform, deadlines, and required documentation.
- Regularly checking regulator websites for updated instructions, as some states periodically transition into (or out of) NMLS.
3. Submitting Incomplete or Inaccurate Reports
During renewals, state regulators often require submission of updated permissible investments, compliance attestations, and activity reports. Errors in data, unsigned documents, or misaligned reporting are fairly common.
How to Avoid It:
- Conducting an internal pre-filing review of all reports, including reviewing recently submitted financial statements.
- Creating and using a standardized checklist tailored for each state’s renewal package.
4. Not Satisfying Net Worth or Surety Bond Requirements
Net worth calculations and surety bond amounts vary by state and may change year to year depending on transaction volumes. Licensees sometimes fail to maintain sufficient coverage or miscalculate their obligations.
How to Avoid It:
- Regularly reviewing each state’s minimum net worth and bonding requirements.
- Recalculating bond coverage annually based on transaction volumes.
- Working proactively with bond providers to ensure adjustments are completed well before renewal deadlines.
5. Providing Outdated Documentation
Regulators often require up-to-date supporting documents such as Certificates of Good Standing, AML/BSA Policies, Cybersecurity Programs, and FinCEN MSB Registrations. Submitting expired or outdated versions is a common reason renewals are delayed or rejected.
How to Avoid It:
- Tracking expiration dates for corporate documents (e.g., Certificates of Good Standing must often be dated within 30–90 days of submission).
- Refreshing AML, cybersecurity, and other policies annually (make sure they are board approved)
- Verifying that FinCEN MSB registrations and renewals are current before attaching them to filings.
6. Failing to Pay Fees
Renewal fee amounts and sometimes even the method of payment can vary by state. Incorrect payments or failure to pay any additional assessment fees can create problems with the submission of the renewal.
How to Avoid It:
- Always review the fee amounts and the method of payment when renewal checklists come out.
- Retain proof of payment for each renewal.
MTL State Filing Calendars: Key Q4 Reporting Deadlines You Shouldn't Miss
Because annual renewal season on NMLS (November – December) overlaps with quarterly reporting deadlines (November 14), money transmitter licensees should approach the fall season with careful preparation. Q4 is typically the busiest time of year, with overlapping requirements and multiple moving parts.
Licensees who fail to report accurately and on time risk penalties such as fines, examination findings, and—at worst—license suspensions, revocations, or failure to renew.
Below are practical steps and obligations to keep top of mind this quarter.
Quarterly Reporting
Quarterly reporting—due 45 days after the end of each fiscal quarter—remains a frequent challenge because requirements and submission platforms vary by state (e.g., FL REAL System, NMLS, Dropbox, email). During Q4, maintain organized practices to submit every report on time and in compliance with state regulations.
Ways to stay on track:
- Maintain a regulatory reporting calendar with all relevant state-specific quarterly obligations.
- Set automated reminders at least 7, 14, and 30 days before each due date.
- Assign clear responsibility to team members for monitoring deadlines and coordinating with internal and external contacts.
- Review regulator notices, NMLS updates, and FS Vector Licensing Insights to identify any changes in reporting rules or formats.
Annual Renewals
Annual renewals can feel burdensome without a solid plan. While the NMLS renewal window runs November 1 – December 1, states differ in what they require, when they require it, and which platform they use. Some states even renew outside NMLS or outside the November - December window altogether.
Tips for a smoother renewal season:
- Identify the renewal method in each licensed state (NMLS, state portal, or direct regulator filings).
- Complete all open license items before renewal season, as some states will not renew licenses with pending license items.
- Maintain a regulatory calendar with renewal obligations and update it annually when NMLS releases requirements (typically by October 1).
- Check regulator websites and communications regularly for updated instructions.
Other Ongoing Requirements
During Q4, regulators also evaluate the overall health and compliance of a licensee. Key items include monthly reports and license items (as applicable), surety bonds, tangible net worth, and foreign registrations.
Steps to stay compliant:
- Reassess each state’s minimum tangible net worth and surety bond requirements regularly.
- Update surety bond coverage promptly based on transaction volume or outstanding liability as applicable to each state.
- Communicate proactively with bond providers to finalize adjustments well before renewal deadlines.
- Track expiration dates for corporate documents (e.g., Certificates of Good Standing, often required within 30–90 days of submission).
- Verify that FinCEN MSB registrations and renewals remain current.
Ensure that all applicable monthly reports and license items are complete prior to renewal submission.
Simplify the Season
One effective way to manage the busy fall/winter cycle is by using FS Vector’s APPROVED Platform - our tool for tracking filings, deadlines, and renewals in one place. We’d be happy to provide a demo.
Please reach out with any questions or to schedule a walkthrough.
Crypto-Backed lending Moves into Mortgages
The crypto-backed lending market has experienced tremendous recent growth, with new use cases rapidly emerging. One of the most notable trends is the rise of crypto-collateralized mortgages. Interest in this space has accelerated following FHFA Director William J. Pulte’s directive for Fannie Mae and Freddie Mac to prepare plans to integrate crypto holdings into mortgage underwriting. Using crypto assets as collateral allows, for example, “crypto-rich, cash-poor” borrowers unlock value without disposing of their assets.
Providers of crypto-backed loans should carefully assess state requirements across traditional mortgage licensing regimes and lending frameworks, with heightened expectations around consumer protection, liquidation thresholds, LTV monitoring, collateral volatility, and disbursement practices.
Service Spotlight: Government Relations
FS Vector’s Government Relations team consists of professionals with decades of advocacy experience. FS Vector helps our clients identify critical policy makers and strategic partners and structure interactions that yield results. The team works with clients to build stronger brands + public profiles, deftly manage threats, and capitalize on opportunities via traditional and nontraditional channels. The goal is to position clients as conveners, innovators and thought leaders in a rapidly developing industry. FS Vector provides real-time political intelligence to help clients anticipate and mitigate risks and realize opportunities while adjusting priorities on the fly. Our relationships with key policy makers allow us to develop and execute strategic advocacy roadmaps that pair priority needs with concrete methods to achieve them.
Connect with our Government Relations experts today.
FS Vector Calendar
Events FS Vector Licensing Team is attending
- Money20/20 | Oct 26-29 | Las Vegas, NV
- RegList on the Ocean | Nov 4-5 | Huntington Beach, CA - Contact us for a discount code to attend!
Upcoming FS Vector Webinars
FS Vector Licensing Lunch & Learn: 2026 NMLS Renewals Prep for Success - October 8, 2025
With autumn approaching, it's time to start preparing for the NMLS renewal season.
To help you navigate the NMLS Renewal Season with confidence, we invite you to join our upcoming session. We'll discuss essential strategies and practical tips to ensure you're fully prepared for a smooth and successful renewal.
FS Vector Licensing Lunch & Learn: Real Talk: Real Estate licensing & More - November 5, 2025
FS Vector and a guest from Rocket Homes/Redfin will lead a discussion on Real Estate Licensing, including reciprocity requirements and considerations. The session will also cover common license violations and share practical strategies to prepare for and mitigate potential compliance issues before they arise.