Excellent paper and analysis here. A fan of TCH generally, but this white paper was frankly the stupidest and poorly written document I have ever seen. TCH tokens was a complete failure to date, and their answer to that is ..."Eh, more Regulation!!!" Get up and compete TCH...or get the hell out of the way. Or get out of the technology and clearing/ACH business and be a lobbying group only. Because that looks like its the only thing you are doing. As for the comment below, all of the PSP programs do have un underlying merchant account and are subject to the same requments. So your frankly wrong. They take all of the risk, and should frankly be getting thanks from the accquring bank for driving business to them - as opposed to freaking whining. They also run KYC programs and are subject to AML requirements so...wrong again. In summary, wake up TCH....or fire your PR person. You win by competing, not pretending the game doesn't exist.