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find a bank or credit union willing to work with us #3322

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chadwhitacre opened this Issue Apr 9, 2015 · 7 comments

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chadwhitacre commented Apr 9, 2015

Reticketed from #3321:

There is, in fact, a way to service US customers and avoid these burdens.

Namely, you can become the agent of a Bank or Credit Union, as existing MSB Certified agents of banks, credit unions and money services businesses are typically exempt from registration and licensure requirements.

Functionally, becoming an agent means hiring an attorney to negotiate and execute an agreement with the bank, credit union or MSB (called the “principal”) setting forth your relative rights and obligations.

Becoming an agent implies two important consequences. First, you will lose some control over your business. As the agent, you will act at the principal’s direction. The principal will likely possess more leverage in the negotiation of the agreement and its performance.

Second, you will not avoid the compliance requirements altogether. To be sure, your business won’t need to seek out state licenses or to register with FinCEN, but it will still have to comply with any anti-money laundering and know your customer (KYC) requirements put in place by the principal.

Furthermore, your business will need to implement those requirements in the way the principal wants them implemented – which may or may not map onto your business plan.

http://www.coindesk.com/bitcoin-law-money-transmission-compliance-avoidance/

@chadwhitacre chadwhitacre added this to the Balanced shutdown milestone Apr 9, 2015

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chadwhitacre commented Apr 9, 2015

We already have an account with http://newalliancefcu.com/. I think I'll stop down there to see if I can talk to someone ...

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chadwhitacre commented Apr 9, 2015

If not New Alliance, maybe https://internetcreditunion.org/?

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chadwhitacre commented Apr 9, 2015

Dwolla has a partnership with a credit union. Linked from their footer:

Dwolla operates a software platform that sends your payment instructions to our financial institution partner, Veridian Credit Union. Your Dwolla balance, if any, is held in a pooled account at this financial institution. Please note that Dwolla balances are not insured. Dwolla is an agent of its financial institution partner.

https://legal.dwolla.com/about-our-financial-institution-partner/

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chadwhitacre commented Apr 9, 2015

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chadwhitacre commented Apr 30, 2015

Closing this out. We're going to try to not be money transmitters at all (gratipay/inside.gratipay.com#192).

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chadwhitacre commented May 8, 2015

I reached out to IAFCU in the context of #3372, and have not heard back.

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chadwhitacre commented May 8, 2015

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