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This opinion was issued in the first quarter of 1998.
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.