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Opinion

Opinion Summary of Selected Opinion 98-026

Date: 01/05/1998
Organization: Division of Banks
Docket Number: 98-026

Scope Of Statute Governing Electronic Funds Transfer Systems - M.G.L. Chapter 167B

Mass. Gen. Laws chapter 167B § 14 prohibits the use of a consumer's social security number as a central information file number, personal identification number, primary financial account number or subpart thereof. The consumer's social security number shall not be used to electronically identify the consumer to any financial institution or organization. Chapter 167B is the Commonwealth's self-contained comprehensive statute governing electronic fund transfer systems. It is the position of the Division that Section 14 is applicable only to electronic banking. However, as a practical matter, the Division does not believe that an institution could differentiate a customer's accounts between those governed by electronic banking and other deposit accounts of the same customer.

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