Have you considered your activities as compared to the discussions by Grist and Zaibatsu (where is Z any way?) and 12 CFR ยง7.1012 Messenger service, as well as 12 USC 36(j)?
In an issue this important, if you have any doubts and this is your responsibility, consult counsel.
What you describe is picking up deposits. I have not researched the finer points of this or looked for legal opinions. But this can be dangerously close to a branch without the right mechanisms in place. And while I hold the highest respect for my BOL peers, I will not go to court and log on to this forum as evidence of legal facts.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell