• This page, Summary of Selected Opinion 98-089, is offered by
  • Division of Banks

Opinion Summary of Selected Opinion 98-089

Date: 04/02/1998
Organization: Division of Banks
Docket Number: 98-089

This opinion was issued in the second quarter of 1998.

Table of Contents

Licensing For Agents Of Licensed Foreign Transmittal Agencies and Check Sellers

Other than a state- or federally-chartered bank, any person or entity in the Commonwealth engaged in the business of receiving deposits of money for the purpose of transmitting the same or equivalents thereof to foreign countries, requires a foreign transmittal agency license pursuant to Mass. Gen. Laws chapter 169. Licensees "shall not authorize the transaction of business at any place other than that described in the license" unless the Division approves a transfer of locations for that particular license pursuant to M.G.L. ch. 169 § 3. It is the Division's position that non-bank agents of a foreign transmittal agency, intending to engage in foreign wire transmittal, need foreign transmittal agency licenses for each location at which such agents intend to do business.

Mass. Gen. Laws chapter 167F, section 4 governs the business of selling, issuing or licensing checks within the Commonwealth. Said chapter requires a licensed check seller to file a list of names and business addresses of agents "other than a bank, a national banking association or savings and loan association, authorized to receive money and transact business on [its] behalf." An entity need not file such information if the agents selling foreign drafts are banks or savings and loan associations. Agents which are credit unions must be included on said list.