As a general rule, if you are collecting monies for providing goods and services to customers, you do not need a MSB license. If however, you are collecting monies, not as revenue, but as an intermediary to disburse monies to third-parties, you may need to be registered as a MSB. For example, you are a Real Estate development company. You wish to disburse monies from your balance sheet on debit cards to contractors for services provided. This should be ok. But, if you want to build a Real Estate development platform for other developers, and you collect money on their behalf for disbursement to their contractors, you likely need a MSB license.