Permissibility Of Bank Using Customer's Social Security No. As A Central File No.
Any financial institution subject to the provisions of Mass. Gen. Laws ch. 167B, governing electronic branches and electronic funds transfers, is prohibited from using a consumer's social security number as a central information file number, personal identification number, primary financial account number or subpart thereof pursuant to Mass. Gen. Laws ch. 167B § 14. However, it has been the position of the Division of Banks that said section 14 only applies to electronic banking and its applicability is therefore limited to electronic fund transfers. See Opinion # 98-026. It is the position of the Division that a financial institution subject to the provisions of Mass. Gen. Laws ch. 167B would not be prohibited from using a customer's social security number as a central file number for the purpose of customer identification in internal non-electronic banking matters.