The capitalization requirement doesn’t exist to make it an exclusive club. It makes it so the potential regulatory fines have teeth because you can’t just fold

The capitalization requirement doesn’t exist to make it an exclusive club. It makes it so the potential regulatory fines have teeth because you can’t just fold on the first one received. The bank offers to cover your fines (with your entire business as collateral), for a fee. You can think of hat fee as the interest rate on a loan, which it basically is because the money is put into an escrow account with the government. In my own market it was $10M usd required to become a payment services provider (e.g. Venmo). But you could get someone to offer the bond for a few hundred thousand dollars a year, the price depending on how comfortable they were with you and your business. That’s within the realm of doable for a startup.