By the Division of Banks

Approval & Licensing Requirements For Check Cashing ATM's

An entity, which sells automated check cashing machines and performs the check cashing functions in their entirety without any function being performed by the machine owner, would require a check casher's license pursuant to Mass. Gen. Laws chapter 169A. A separate application would be required for each machine location. Such an entity would not be required to file an application pursuant to Mass. Gen. Laws chapter 167B §§ 4 and 5, when such machines are also programmed as ATM's at the request of the owner. However, the owner of such a machine would be required to file an application pursuant to both Mass. Gen. Laws chapter 167B §§ 4 and 5. Under Mass. Gen. Laws chapter 167B § 5, however, the owner would only have to file an application for the first ATM. In addition, an abbreviated version of subsequent applications may be filed under Mass. Gen. Laws chapter 167B § 4.