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Opinion

Opinion Summary of Selected Opinions 97-261 (98-031)

Date: 01/01/1997
Organization: Division of Banks
Docket Number: 97-261 (98-031)

These opinions were issues in 1997 (97-261) and 1998 (98-031), respectively. 

License requirements for sale of electronic traveler's checks

An electronic traveler's check may be in the form of a pre-paid plastic card which provides access to cash and local currency through ATM machines without accessing customers' accounts. Such an electronic traveler's check is handled and processed in the same manner as traditional travelers check and may be protected by a personal identification number ("PIN"), be accompanied by 7 day, 24 hour customer service support, and may be replaced if lost or stolen. It is the position of the Division of Banks that any entity intending to sell or issue electronic traveler's checks meeting appropriate conditions, other than a bank authorized to do business in the Commonwealth, would require a check seller's license pursuant to Mass. Gen. Laws ch. 167F § 4. Because consumer accounts cannot and will not be accessed through ATMs when such electronic traveler's checks used to access cash, no other licensing provisions within the Division's jurisdiction would be triggered.

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