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  • Division of Banks

Selected Opinions of the Division of Banks related to consumer virtual currency

Through these opinions the Division of Banks (DOB) offers perspective on current issues and questions in the financial services industry.

Table of Contents

2023

  • Opinion 23-001
    • Licensing requirements to offer cryptocurrency over the counter trading services, as described – June 28, 2023.

2022

  • Opinion 22-004
    • Licensing requirements for the purchase and trading of fractional interests in real estate through an online platform, as described – February 21, 2023.

  • Opinion 22-002
    • Licensing requirements for a platform to purchase virtual currency for fiat or sell virtual currency for fiat, as described – November 1, 2022.

2021

  • Opinion 21-008
    • Licensing requirements to provide cash management services to cryptocurrency kiosk operators, as described – April 25, 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

2020

  • 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 020-003
    • Does providing the specified services involving virtual currency through a mobile application and website, require a foreign transmittal agency license – May 22, 2020

2019

  • Opinion 19-008
    • Licensing requirements for the buying and selling of virtual currency through a website – January 17, 2020
  • Opinion 19-007
    • Licensing requirements for the sale of virtual currency through a kiosk – December 6, 2019

2018

  • Opinion 18-003
    • Do business activities, as described, for purchase, sale and exchange of virtual currency require a license from the Division of Banks - June 14, 2018
  • Opinion 18-002 
    • Do business activities involving the sale of cryptocurrency, as described, require licensure from the Division of Banks - March 9, 2018

2017

  • Opinion 17-007
    • Can a service fee be charged by third party payment processor for payments by credit card for insurance premium payments – October 24, 2017

2014

Past opinions of the DOB

You can get copies of past opinions by submitting a Public Records Request to the DOB's Records Access Officer.

The DOB's Regulations, found in the Code of Massachusetts Regulations (CMR - agency code number 209), are available through the State House Bookstore.

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