This has all been covered before. No McExchange franchise 4 U.
Piggybacking your ridiculousness on top of another one simply doesn't work.
TY Crypto Capital. This brings me back to my original question, which banks are you working with?
For a real-world example:
I live in US, NY, NYC, which bank would I be dealing with? I'd like to contact that bank and verify your involvement with it.
TY again.
Re. "no need to trust or provide your information to the trading software provider, they are a software company, not a financial one":
An exchange operator is an exchange operator, a software provider is a software provider. If the software provider happens to also be running the exchange, he becomes both. I'm afraid you've been mislead by your legal counsel.
We currently do not work with a Bank in the U.S, but we will provide a funding option directly to US customers in the near future and will update our customers as soon as it is setup.
OK, no US banks. Any banks I could contact?
We act as exchange operators, and the "exchange" companies are software providers to our financial company. If you used trading software, is your agreement with the software company that made the software or the broker that provides the software to you as a client. If you use online banking software provided by your bank to handle your banking needs do you interact directly with the software company that wrote the software for the banking platform? Of course not.
This is getting a bit silly. When I use my bank's software, I'm dealing with my bank. The [outside] firm providing banking software to my bank is not opening bank branches and calling itself "bank," while the exchange software providers are not starting their own exchanges while playing licensed brokers. No parallels whatsoever with your DIY exchanges functioning on open-source software (which you provide along with your "bank - escrow" service).
McExchange Franchise model is amusing as a thought exercise, but I'm afraid no more than that.
We provide exchange software developers to option to engage customers without holding money in their own account, but in an escrow account. An exchange software provider manages the software, they do not need to physically handle your money, they only need to run and manage the matching engine software.
"Physically handle [my] money"?! Unless you are expecting my bank to send used, nonsequential tens and twenties, you won't be physically handling it either. An exchange is an exchange, and the person selling unregistered securities on an unlicensed exchange is selling unregistered securities while running an unlicensed exchange. Regardless of who "escrows" the money.
I don't particularly care if you break every law on the books, but don't kid your "clients."
Think about coinfloor, a UK exchange that uses a money transmitter to hold the funds in escrow and receive and send them back and forth on behalf of their customers. We do the same thing, but on a global multi-currency platform.
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No. From a cursory look at the website, Coinfloor appears to be no different from other exchanges, it does not farm out AML requirements to third parties, or claim to be just a "software provider." Again, no parallels with what you are proposing.
As I said, McExchange is an interesting hypothetical, and clever in a geeky, literalist sort'a way, but it's simply a nonstarter as a working, IRL proposition. Financial regulators simply don't share our sense of humor.
