The flow of funds, as the ledger shows it.
We review the fintech opinions your bank relies on, and test every fact against the company’s own code and ledger.
Example data: invented bank, people and figures. Not a client or a result.
Three regimes, one question each
States · FinCEN
Money transmission
Is it transmitting money, and where?
The opinion says
- Funds stay in the bank’s FBO account
- An agent-of-payee exemption
We test
- The ledger’s sweeps and settlement paths
- Who can move balances overnight
SEC · states
Securities
Is it selling an investment?
The opinion says
- No expectation of profit
- Rewards aren’t a return on balances
We test
- The rewards and yield code
- What the marketing promises
CFTC · state gaming
Event contracts
Is it a swap, and on whose venue?
The opinion says
- Listed on a registered exchange
- One disclosed settlement source
We test
- Order routing
- The settlement code path
Priced the same as gaming
First review
$50,000per client
Later reviews
$20,000per review, same client
Included
- Hourly monitoring
- Same-day notice of law and code changes
Flat legal fees, billed by Apparently Law PLLC. Extra attorney time is billed as the engagement letter sets, and only the engagement letter binds the firm. No fee depends on the outcome of the review. Full terms.
Attorney advertising. This site is informational and is not legal advice. Using it, or sending information through it, does not create an attorney–client relationship. That relationship begins only when a written engagement letter is signed by both sides. Every engagement is performed by an attorney licensed in the relevant jurisdiction.