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This opinion was issued during the fourth quarter of 1998.
Mass. Gen. Laws chapter 140, section 96 requires that persons seeking, directly or indirectly, to engage in the business of making small loans must obtain a license to carry on the business "in the town where the business is to be transacted." In order to conduct business at a location other than the address indicated on the license, the licensee must get the prior permission of the Division, according to 209 CMR 12.07(1). It is the Division's position that a separate license is required for each location within the Commonwealth from which the business of a small loan agency will be conducted. If a licensee's employees do not have contact with prospective consumer borrowers or with the general public from the premises on which they do business, a separate license may not be required for each premises.