"Operations of non-bank financial institutions are often still covered under a country's banking regulations."
"Non-banking financial companies (NBFCs) are financial institutions that offer various banking services but do not have a banking license. Generally, these institutions are not allowed to take traditional demand deposits—readily available funds, such as those in checking or savings accounts—from the public"
That eliminates the Costello weed bank - can't take deposits - is a killer for a weed bank.
Plus, I am certain a non-bank financial institution would have to register with FinCEN.
IG
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