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This opinion was issued in the second quarter of 1999.
Regulatory Bulletin 3.3-101 provides the Division's interpretation of Mass. Gen. Laws chapter 167D, section 2, the "18-65" law, so-called. Section 1 of said chapter 167D defines a "bank" as " ... a savings bank, cooperative bank or trust company incorporated as such in the commonwealth." It has been the Division's longstanding position that the definition of bank in said section 1 governs only state-chartered banks. Accordingly, it is also the Division's position that the "18-65" law is applicable only to state-chartered banks, not national banks.