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.