Regulatory model
Treat NorthRail as a checkout software layer and provider-orchestrated payment facilitator until counsel maps whether MSB, RPAA, privacy, and consumer protection obligations apply.
- Written counsel memo on RPAA/payment service provider classification.
- MSB analysis for fund handling, merchant settlement, and refund flows.
- Provider contract language showing who performs regulated payment functions.
MVP control: Fake adapter only; no production debit, credit, settlement, or merchant onboarding credentials.
Founder + Canadian payments counsel