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Fair point, and you are probably right. I don't know much about custody law.
Ignorant thought experiment: what is the difference between selling users "points" (for sats or dollars) and then later letting them buy sats or dollars with these points and just plain custody?
The former sounds a little like gift cards where users give merchants money in return for a balance of what are essentially meaningless points secured only by the merchant's good name and then spend those points in return for a good or a service.
Couldn't the product im buying with points be sats or the service of using points for a while in a very low fee way or in some other manner that benefits from ecash's properties (bearer instrument perhaps?) and then converting to some real money like dollars or sats?
That's not a bad idea tbh. There's lots of schemes that rely on changing the definition of what's being exchanged and how, to get around different regs. It's kind of like how Bull Bitcoin sticks vouchers between their trades for e.g.
Would be interesting to see if anyone tries that approach instead, and how they'd smooth over the UX of that.
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