For multi-state money transmitters
Quarterly state reporting, without the scramble.
Connect read-only to the warehouse you already run. Every Call Report figure arrives with its source columns, its citation and the election a named person signed — reproducible years later.
- 8,858
- state money transmitter licences, held across 599 companies (NMLS, 2024)
- NMLS — 2024 NMLS Money Services Businesses Industry Report (US)
- 45 days
- after each quarter end to file the MSB Call Report
- CSBS — Money Transmission Modernization Act § 7.01 (MODEL)
- 31
- states have enacted the Money Transmission Modernization Act in full or in part (CSBS, September 2026)
- CSBS — CSBS, "Money Transmission Modernization Act" page (dated 2026-09-03) and "Current MTMA Introductions & Enactments" (updated August 2026) (US)
What we heard
Two jobs, one deadline
The quarterly scramble
Four systems and a workbook
The exam, later
A number nobody can derive twice
The gap
No column in any of those systems is named outstanding transmission obligation.
The translation from your tables to what each state asks for — carrying its lineage — is the product. A wrong figure here is not an audit finding to remediate; it is a misfiling.
Our core principle
Your data never leaves your warehouse. We bring the logic to it.
Read-only, always
Your rows never leave
No model computes a number
What we will not do. File on your behalf, pick your state-attribution methodology, or give legal advice. We do not say you are compliant; we show what the data says and which requirement it maps to. The judgment stays with your compliance officer and counsel.
Step 1 · map once
We map your warehouse to a compliance model
| Your tables (examples) | Mapped to | Used for |
|---|---|---|
| transactions, transfers | Money received for transmission | FC200, PI120, state volumes |
| settlements, payouts | Obligations discharged | the daily outstanding series |
| refunds, reversals | Obligations extinguished | the same series, netted |
| customers, agents, addresses | State attribution facts | ST361, CA and NY splits |
| instruments, stored value | Instrument type | FC210, FC220, NY by instrument |
Mappings are reviewable definitions a named person confirms. When a table changes, we update the map, not the report.
Step 2 · the flow
From your tables to the figure, every step on the record
Step 01
Connect
Step 02
Confirm
Step 03
Compute
Step 04
Project
Step 05
Pack
Rulebooks and elections
Each figure is judged by the rule that asks for it
Three regimes, one daily series. Every line item cites the document it comes from.
NMLS MSB Call Report (FV4)
FC200/FC210/FC220/FC230 itemise by instrument; PI120, PI130 and ST361 aggregate. FC200 is money transmission alone; PI120 adds instruments and stored value.
NMLS — MSB Call Report Field Definitions (updated 2/25/2025) (US)
California Fin. Code § 2039(d)
Volumes, counts and outstanding obligations for California and the United States, plus two average-daily figures — filed through NMLS.
CA DFPI — California Financial Code § 2039(d) (as amended by Stats. 2023, Ch. 463, Sec. 4 (AB 1116), effective January 1, 2024) (CA)
New York 3 NYCRR § 406.10
Instrument-level outstanding liabilities and monthly sales split New York versus the rest of the US — a parallel regime on the same series.
NY DFS — 3 NYCRR § 406.10(d) (NY)
State attribution — your election
NMLS does not prescribe how a transaction is attributed to a state. Sender, beneficiary, agent location or your documented methodology: an election a named person signs, disclosed on every pack.
NMLS — MSB Call Report FAQ — payment processing and bill paying transaction reporting (US)
What we look for
Line items, patterns and the traps underneath them
The traps the primary sources exposed — each one produced a wrong number before we read the document.
| Pattern | What it looks like in the data |
|---|---|
| FC200 ≠ PI120 | FC200 is money transmission alone; PI120 adds monetary instruments and stored value. Report one as the other and the balance sheet disagrees with the permissible-investment section. |
| California reports two averages | A transmission ADTL, and a separate combined payment-instrument-and-stored-value ADTL — not stored value alone. |
| Fiscal versus calendar quarter | New York's § 406.10(b) runs on the fiscal quarter; § 406.10(d) on the calendar quarter. Same data, two windows. |
| Calendar days in the denominator | ADTL divides by every day in the quarter, not business days — confirmed three times over. |
Step 3 · the output
Every line arrives with its trail
Short sentences instead of query output. Every figure links back to the rows in your warehouse that produced it, the rule it maps to, and the person who signed the interpretation.
- PI120 Total outstanding transmission liability — $41,207,318.52 — as of 2026-09-30 — 3 source columns — cited
- PI130 Average daily outstanding transmission liability — $38,944,110.07 — 92 calendar days — cited
- ST361 Average daily liability, Texas — $2,118,406.90 — attribution: sender location, elected by J. Doe (CCO) 2026-08-14
- Caveats — 1 material: ST361 depends on the elected attribution rule; every caveat listed, none suppressed
Step 4 · your team decides
The system drafts. People approve.
Chief Compliance Officer
Which state-attribution methodology do we use, and has it survived an exam?
Head of Licensing, with data
Which columns mean what — confirmed, not auto-promoted
CCO, per jurisdiction
Does virtual currency count in the average daily liability for this state?
CCO or CFO
Who approves the pack before it leaves?
Nothing reaches a regulator or an authority without human approval. Every release records who asked, what was shared, who approved it, and when.
Security and control
Built for data that cannot move
Read-only, always
Your rows never leave
No model computes a number
A person confirms every mapping
Where the rules disagree, we say so
Proposed pilot
Eight weeks, measured by hours and traceability
Weeks 1–2
Weeks 3–6
Weeks 7–8
How we will measure it
- · Analyst hours per report or request
- · Time from period end, or from request, to an approved pack
- · Share of reported figures traced to source rows
Pilot terms: the pilot fee is credited against a first year signed within 30 days. Every pack carries its own caveats on its cover; nothing is suppressed to make a figure look cleaner.
Talk to us
Quarterly filings without the scramble
If this is on your desk, tell us what you are dealing with and we will reply within one to two business days.