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These fee credits sound a little like eCash tokens. Or like they could be. And aren't you going to be custodians of the fee credits?
They aren't money and can't be withdrawn. They can only be paid to us. Custody implies the thing in question has external value, that they'll leave the "closed loop," and these cannot. They are like Starbucks points.
I'm sure you've talked to attorneys but man does this sound like the regulations of the state forcing weird work arounds.
The weirdness is pretty intuitive here. We can't take custody of funds or take control of funds on transit from one person to another ... unless, we KYC AND spend millions of dollars and several years getting licenses.

We might eventually do something like Fountain or Primal and white label a licensed custodian offering a built-in custodial service on an opt-in basis. But, they can't serve most of the world, several US states, and have soft KYC and tons of monitoring. We're trying to do the bitcoin friendly thing here. I seem to have more faith in bitcoin than most people do though.
Thanks @k00b I was missing some dots probably because its Monday. Makes sense. Been testing out the external wallet options. Seem to work for me so far.
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