[alexmccain6]

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.

[openspend]

I believe these companies are already doing it and charging a fee because they provide compliance and have required MSB licenses.

1. https://plaid.com/products/transfer/

2. https://www.flinks.com/products/pay

3. https://paytm.com/online-payments

OpenSpend should be open-source and free, unlike the companies mentioned above.

The idea is not only to provide the software but also legal templates like cancellation policy, refund policy, dispute resolution, etc., for different jurisdictions.

[openspend]

For users/customers to make an effort to complete an online e-transfer, the incentive is to purchase the product or service with -2.9% + -$0.30 OFF or similar.