If you are an MSB that is exempt from MTLs – that exemption would apply on a state by state basis. So for the states you are exempt, you are exempt, but others may require you to obtain a license.

As far as FinCEN registration is concerned, if you are deemed to be an MSB, you are required to be registered with FinCEN.

FinCEN is not a license granting institution. Registration with FinCEN is mandatory for all MSBs for purposes of federal reporting.

Two important (short) videos on this subject: