2023 Opinions
- Opinion 23-003
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Licensing requirements for cryptocurrency exchange services through mobile application, as described – November 29, 2023.
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- Opinion 23-002
- Whether an individual who holds an ownership interest in a mortgage broker may also hold an ownership interest in a real estate brokerage, under the facts described – July 20, 2023.
- Opinion 23-001
- Licensing requirements to offer cryptocurrency over the counter trading services, as described – June 28, 2023.
2022 Opinions
- Opinion 22-004
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Licensing requirements for the purchase and trading of fractional interests in real estate through an online platform, as described – February 21, 2023.
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- Opinion 22-002
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Licensing requirements for a platform to purchase virtual currency for fiat or sell virtual currency for fiat, as described – November 1, 2022.
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- Opinion 22-001
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Licensing or registration requirements for servicing a branded credit card issued by a bank, as described – August 19, 2022.
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2021 Opinions
- Opinion 21-006
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Licensing requirements for financing of time share interest in property, as described – June 22, 2022
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- Opinion 21-008
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Licensing requirements to provide cash management services to cryptocurrency kiosk operators, as described – April 25, 2022
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- Opinion 21-005
- Whether a convenience fee may be charged to make a payment by telephone on a retail installment agreement, as described – April 12, 2022
- Opinion 21-009
- Licensing requirements for digital currency trading and custody services and certain liquidity services – March 2, 2022
- Opinion 21-004
- Licensing requirements for online platform enabling the creation and sale of digital assets representing interest in physical metals, as described – August 6, 2021
- Opinion 21-003
- Licensing requirements for individual automobile dealerships for activities described - May 7, 2021
- Opinion 21-002
- Mortgage loan originator licensing requirements for financial advisor employees, as described – April 16, 2021
- Opinion 21-001
- Licensing requirement for business providing data processing and payment processing services, as described - March 26, 2021
2020 Opinions
- Opinion 020-005
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Permissibility of charging a GAP waiver cancellation fee, on facts as described – February 10, 2022.
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- Opinion 020-006
- Licensing requirements for a foreign transmittal agency to issue funds to consumers by paper check, as described – February 16, 2021
- Opinion 020-004
- Licensing requirements for interactive games using distributed ledger technology – November 3, 2020
- Opinion 020-002
- Licensing requirements for virtual currency exchange services through a kiosk or website – August 13, 2020
- Opinion 020-001
- Applicability of Massachusetts General Laws chapter 244, section 35B to certain agency and GSE loans – July 1, 2020
- Opinion 020-003
- Does providing the specified services involving virtual currency through a mobile application and website, require a foreign transmittal agency license – May 22, 2020
2019 Opinions
- Opinion 19-008
- Licensing requirements for the buying and selling of virtual currency through a website – January 17, 2020
- Opinion 19-010
- Is a processing fee for customer credit card payments, charged and collected by a third-party payment processor, permissible under G. L. c. 140D, § 28A – January 3, 2020
- Opinion 19-009
- Confirmation that a Massachusetts-chartered financial institution's donation to HOME is a qualified investment under CRA – December 11, 2019
- Opinion 19-007
- Licensing requirements for the sale of virtual currency through a kiosk – December 6, 2019
- Opinion 19-006
- Licensing requirements for a real estate conveyance attorney providing mortgage information and assistance to clients – November 8, 2019
- Opinion 19-002
- Questions regarding credit union real estate loan purchases and real estate loan participations – September 10, 2019
- Opinion 19-003
- Clarification on Vendor Single-Interest Insurance (VSI) – October 15, 2019
- Opinion 19-005
- Does providing the specified products and services, as described, require a foreign transmittal agency license – September 26, 2019
- Opinion 19-004
- Do payment processing services using the ACH network, as described, require a foreign transmittal agency license - August 13, 2019
- Opinion 19-001
- Request for interpretation of MGL chapter 167I, section 14 governing changes in control of Massachusetts stock banks – June 5, 2019
2018 Opinions
- Opinion 18-006
- Do business activities, as described, require a debt collector license - December 13, 2018
- Opinion 18-005
- DOB licensure requirement for the servicing activity of commercial transactions, as described – September 4, 2018
- Opinion 18-004
- Mortgage brokers preparing and providing certain disclosures required under MGL c. 140D and TRID – August 6, 2018
- Opinion 18-003
- DOB licensure requirement for activities, as described, for purchase, sale and exchange of virtual currency – June 14, 2018
- Opinion 18-002
- DOB licensure requirement for business activities involving the sale of cryptocurrency, as described – March 9, 2018
2017 Opinions
- Opinion 17-003
- Small loan licensing requirement for licensed motor vehicle sales finance company financing “negative equity” as part of motor vehicle sales finance contract – January 8, 2018
- Opinion 17-009
- Licensing requirement for an entity operating a mobile application that facilitates payments between homeowners and home improvement contractors – December 19, 2017
- Opinion 17-005
- Does acquiring a mortgage as a result of a defective foreclosure require a debt collector license – October 24, 2017
- Opinion 17-007
- Does the business of selling and buying bitcoin through kiosks require licensure by the Division – October 24, 2017
- Opinion 17-008
- Can a service fee be charged by third party payment processor for payments by credit card for insurance premium payments – October 24, 2017
- Opinion 17-001
- The use of professional employer organization services - May 10, 2017