Under 31 U.S.C. 5330 and its implementing regulation (31 CFR 1022.380), money services businesses (MSBs) must file an initial registration report with FinCEN, renew their registration every two years, re-register under certain circumstances, and maintain a list of their agents.
Per OIRAâs recommendation, FinCEN divided the registration process into three categories (i) initial registration, (ii) registration renewal, and (iii) re-registration. FinCEN also incorporated the estimated burden of maintaining and updating a MSBâs agent list. For each of the four categories, FinCEN looked at the total number MSBs for calendar years 2015 through 2019, and identified an average for each category. FinCEN also re-evaluated its estimate of burden for recordkeeping and reporting on the RMSB Report 107 for each type of report. In prior information collection requests (âICRsâ), FinCEN estimated it would take a MSB 30 minutes to complete the RMSB Report 107 and file it, and 30 minutes to maintain a record of the report. In light of BSA E-filing, FinCEN reduced the estimate of recordkeeping burden per type of registration. FinCEN also revised its estimate of reporting burden, which varies by type of registration.
In the 2018 ICR, the estimated number of respondents was 42,000, and the estimated total annual burden hours was 42,000 (30 minutes recordkeeping plus 30 minute reporting). In this ICR, FinCEN identified 12,381 registration responses and 24,027 MSBs that must maintain and update an agent list annually. The reduction in the number of MSBs since 2018, in combination with the revisions to FinCENâs estimates of burden broken down into various categories, is the reason for the reduction in total annual burden to 22,007 hours in this ICR.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.