https://www.dwolla.com/tos#conduct
I guess your idea would qualify as "money service", as you do not decide where you actually send the transaction to, but let others decide on that and act on their behalf.
It would be a neat service idea and probably needed and so on, BUT (and that's a big but!) it is impossible to do this on a larger scale (meaning above a few hundred USD per year) without drawing attention from Dwolla. You need their approval to act against their TOS, so probably you should start founding a company instead of asking as a "regular user" in the first place, to be taken a bit more serious.
I guess your idea would qualify as "money service", as you do not decide where you actually send the transaction to, but let others decide on that and act on their behalf.
It would be a neat service idea and probably needed and so on, BUT (and that's a big but!) it is impossible to do this on a larger scale (meaning above a few hundred USD per year) without drawing attention from Dwolla. You need their approval to act against their TOS, so probably you should start founding a company instead of asking as a "regular user" in the first place, to be taken a bit more serious.
I think we already mentioned you would need "written consent to operate or engage in any business regulated by FinCen, including the money service business" as in their ToS. Once you had that written consent you would not have to worry about Dwolla coming after you.
Framing this as a business would be the best way to do it. That would allow raising of capital, making things more liquid. Having a business set up would also allay some of the trust issue; people understand they have to send first to a business, but many people are reluctant to send first when dealing with some random guy on the internet.
