But the Form 10 stated MYEC does not believe it is subject to Federal Regulation:
Regulation
Since MyECheck processes but does not conduct transactions, and does not directly hold or transfer cash, we are not subject to direct federal, state or local regulations regarding money transfer. We are also not subject to any regulation or law that applies to accessing or conducting Internet commerce. We are only subject to regulations applicable to general business conduct. However, there are no assurances that MyECheck will not be subject to financial regulations in the future.
I would agree that the Money Transmitter Licenses are required for those money transfer apps.
So, in the foreseeable future, people should forget about GreenPay or any other MYEC apps. since they won't have the required surety bonds for the application of these licenses.