I'm sorry, but your response is a strong indicator that anyone and everyone needs to stay as far away as humanly possible from your company in its current form because:
1) company's leadership does not understand how FDIC insurance works -- trusts have their own tax ID which are not customer's tax id. Trusts cannot currently be created in real time.
2) company's leadership does not know what they are getting from a "partner" -- some random person who ran a couple of companies and consulted for some financial institutions should not know more about what is and what is not possible than a leadership of a company in a space
3) there's a lack of understanding among the leadership what are the implications of customer account being insured by FDIC.
4) leadership does not understand that ACH credit has a liability attached to it which needs to be managed very carefully ( especially with points 1-3 )
5) In no even should the points 1-4 stand should a company ever trade from its own inventory to satisfy customer's order.
Drop whatever you are currently doing and immediately hire a compliance person from a large commercial bank that does not have any reason to leave his or her position i.e. overpay for one of 100-200 experts that exist in this field so you can at least ensure that you don't blow up in the most spectacular fashion with a potential criminal prosecution.
This is not an Uber or AirBnB. If you mess up you will create potentially criminal problems not just for yourselves but for your customers.
1) company's leadership does not understand how FDIC insurance works -- trusts have their own tax ID which are not customer's tax id. Trusts cannot currently be created in real time.
2) company's leadership does not know what they are getting from a "partner" -- some random person who ran a couple of companies and consulted for some financial institutions should not know more about what is and what is not possible than a leadership of a company in a space
3) there's a lack of understanding among the leadership what are the implications of customer account being insured by FDIC.
4) leadership does not understand that ACH credit has a liability attached to it which needs to be managed very carefully ( especially with points 1-3 )
5) In no even should the points 1-4 stand should a company ever trade from its own inventory to satisfy customer's order.
Drop whatever you are currently doing and immediately hire a compliance person from a large commercial bank that does not have any reason to leave his or her position i.e. overpay for one of 100-200 experts that exist in this field so you can at least ensure that you don't blow up in the most spectacular fashion with a potential criminal prosecution.
This is not an Uber or AirBnB. If you mess up you will create potentially criminal problems not just for yourselves but for your customers.