Is Starbucks a Bank or an MSB?

5,000 community banks in the US with less than $1B in assets.

Starbucks took $2.2B in deposits for gift cards and mobile payments.

Is your Starbucks account a DDA? Is Starbucks a bank? Should Starbucks be an MSB or a Money Transmitter (I can send you a gift card, you can exchange gift card for cash.)

The questions make my head spin. No wonder it is so hard to deal with a fintech startup.

(Stats from http://www.bankdirector.com/board-issues/retail/the-battle-for-the-bank-account)