Agreed "They are not a bank" that is the issue.
Listen, like I said ad nauseum, I wanted to see this new proprietary "not typical" (as you mention) banking idea for the MJ sector work. And I have know doubt that Costello has acted as a banking mechanism to take funds from some marijuana related companies and deposit them into a real FDIC Bank like he did with CANN into a Chase account. Was Chase aware this was Marijuana money? Remember as of today, Banks are unable to take Marijuana related funds in as liabilities. So did Costello find a legal loophole to become an intermediary?? How does it work, where are the regulating documents? If he has legitimate approval to act in this "new" not typical banking function, why is he not SCREAMING from the rooftops that his plan is legitimate? and if Costello has full approval to operate in this capacity, then when do the Marijuana companies in the LOI become part of a "legitimate Reverse Merger into the shell"
He has not acted like a CEO that has a legitimate company concept and this idea looks to have turned into a potential Monster SEE BELOW a banking pal sent me this. It's real straight forward for those that have desire to become a Bank
The proposed bank must first receive approval for a federal or state charter. The Office of the Comptroller of the Currency (OCC) has exclusive authority to issue a federal or "national bank" charter, while any state (and the District of Columbia, Guam, Puerto Rico, and the Virgin Islands) may issue a state charter. Before granting a charter, the OCC or state must be able to determine that the applicant bank has a reasonable chance for success and will operate in a safe and sound manner. Next, the proposed bank must obtain approval for deposit insurance from the Federal Deposit Insurance Corporation (FDIC). Additional approvals are required from the Federal Reserve if, at formation, a company would control the new bank and/or a state-chartered bank would become a member of the Federal Reserve.
All insured banks must comply with the capital adequacy guidelines of their primary federal regulator (Federal Reserve, FDIC, or OCC). The guidelines require a bank to demonstrate that it will have enough capital to support its risk profile, operations, and future growth even in the event of unexpected losses. Newly established banks are generally subject to additional criteria that remain in place until the bank's operations become well-established and profitable.