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Banking Interpretations

NYSBL 131(1) and 640(1)

April 21, 2005

Steven Barras/legal/NYSBD

To [ ]

cc Sara Kelsey/legal/NYSBD@NYSBD, Cheryl
Lewis/legal/NYSBD@NYSBD

Subject Licensing Question

You have asked whether a Pennsylvania chartered bank requires a license or needs to be qualified to do business in New York to provide ACH services for money transmitters (presumably licensed if required by law). Specifically, the bank intends to offer bill payment services for money transmitters by transferring their customer bill payments from the transmitters' operating accounts to the payee. Based on the foregoing facts, the bank will not need to obtain any license under the New York Banking Law to engage in the contemplated activities. Questions concerning the need to qualify to do business in New York as a foreign corporation should be addressed to the New York Secretary of State's Office in Albany.

Steven Barras
First Assistant Counsel