ODFI Is Not Your Custodian — Mapping Bank Roles Before You Draft Fintech Terms
Bank partners move money, hold money, or both — and the roles drive your fintech terms. Here is how to map ODFI, custody, Reg E, NACHA, and sponsor-bank flow-downs.
Bank partners move money, hold money, or both — and the roles drive your fintech terms. Here is how to map ODFI, custody, Reg E, NACHA, and sponsor-bank flow-downs.
When there is no separate custody agreement, your user terms must create the custodial relationship. Here is how to draft custody, segregation, security interests, and remedies.
FBO pass-through FDIC coverage has two conditions most fintech disclosures forget. Here is what the terms and the marketing can and cannot say.
The March 17, 2026 SEC/CFTC joint interpretation sorts crypto assets into five categories. What it means for Florida operators raising, building, and exiting.
An anonymized walkthrough of a real foundation-led crypto acquisition we papered — the term sheet, the prior-investor cleanup, the token warrants, and the closing mechanics.
We work with multiple crypto teams that are physically based in Florida. Florida adds a layer to the standard DE C-corp + protocol playbook that founders sometimes miss.
Adding a foundation to a protocol structure is not automatic. We walk multiple clients through the decision each year — here is the framework we use.
Token warrants and governance commitments don’t sunset on their own. When the next round demands a clean cap table, we untangle the prior commitments first.
How a crypto-native startup raises both equity and the right to future tokens — without violating securities law or burning the cap table.
The GENIUS Act stablecoin rules face a July 18, 2026 deadline. A crypto lawyer explains issuer licensing, reserves, the yield ban, and what to do now.