That’s roughly the direction I’m thinking as well. Bank-to-bank transfers (e-transfers, ACH, SEPA, UPI, etc.) are already legal and widely used for paying businesses directly, without card networks or pooled balances.
The idea isn’t to change that, but to provide a self-hosted, non-custodial orchestration layer around those rails. The software wouldn’t hold funds or act as a counterparty....it would just help merchants initiate and observe transfers using their own bank relationships, with clear settlement and no payout abstraction.
Where things get tricky is cards, which are a very different model. But for bank rails, I agree the legal foundation already exists, and the question is more about how much orchestration you can provide before it’s considered intermediation.
Happy to be corrected if I’m missing something.
The idea isn’t to change that, but to provide a self-hosted, non-custodial orchestration layer around those rails. The software wouldn’t hold funds or act as a counterparty....it would just help merchants initiate and observe transfers using their own bank relationships, with clear settlement and no payout abstraction.
Where things get tricky is cards, which are a very different model. But for bank rails, I agree the legal foundation already exists, and the question is more about how much orchestration you can provide before it’s considered intermediation.
Happy to be corrected if I’m missing something.