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.
US Code:
31
USC 5330 Name of Law: Money and Finance
Per OIRA’s 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 MSB’s 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 (“ICRs”), 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 FinCEN’s 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.