FINAP USA × IPSI Inc. (OTCQB: IPSI)
FINAP USA LLC · Engineered for USA

Where compliance-first
meets growth.

A closed-loop financial operating system being built for cannabis, gaming, and other compliance-intensive US industries — engineered to operate under a sponsor financial institution Program Partner umbrella.

CLOSED LOOP PAY EWA BNPL IPAY
A different kind of financial infrastructure
04
Launch Products
Wallet, EWA, BNPL, and merchant network — engineered as one closed loop. The foundation for an open banking and neobanking future.
1
Operating System
A unified compliance, ledger, and risk architecture spanning all four products from day one.
0
MSB / MTL pursued
Designed to operate under sponsor FI licensure as a Program Partner — purpose-built for that structure.
SOC 2
Compliance by design
Engineered to AICPA Trust Services Criteria from line one of code — not bolted on at audit time.
01 — PLATFORM

Four products. One closed loop.

The Champion 4 — CIXOR Pay, CIXOR PayDay, iPayLater, and the iPay merchant network — are engineered to launch as a single closed-loop ecosystem with shared identity, shared compliance posture, and shared liquidity backing. The foundation for an open banking and neobanking platform serving compliance-intensive markets.

Consumer Wallet
01 — Closed-Loop Wallet

CIXOR Pay

The consumer-facing wallet and credential. Designed for employees of CIXOR PayDay employers and approved consumers, with acceptance across the iPay merchant network. The CIXOR Card RFID credential is planned to extend acceptance to physical retail in a future release.

Mobile-first wallet with QR and NFC acceptance
Real-time closed-loop transfers between participants
KYC and OFAC screening engineered into onboarding
Earned Wage Access
02 — Employer-Integrated EWA

CIXOR PayDay

Employer-integrated earned wage access, structured so the employer carries the credit relationship with FINAP USA. Employees draw earned-but-unpaid wages into their CIXOR wallet on demand, with the employer reimbursing FINAP USA at pay cycle end.

No employee-side fees · No payroll deduction by design
Employer credit underwriting drives cap allocation
Aligned to state EWA carve-out frameworks
Buy Now, Pay Later
03 — Closed-Loop Instalment Financing

iPayLater

Closed-loop instalment financing engineered for iPay merchants. Consumers split eligible purchases across instalments repaid from their CIXOR wallet — keeping repayment rails internal to the network. Designed to TILA / Reg Z disclosure standards with state-by-state configuration.

TILA / Reg Z disclosure framework · CFPB BNPL Rule alignment
Wallet-funded repayment (closed loop)
Risk-priced for compliance-intensive verticals
Merchant Network
04 — Acceptance Network

iPay

The merchant side of the closed loop. Designed for cannabis dispensaries, gaming operators, and adjacent merchants accepting CIXOR Pay and iPayLater inside the network. Engineered with configurable per-merchant risk parameters — hold time, reserve, payout velocity — calibrated to vertical and merchant tier.

Two-account model — Ledger (suspense) + Available
Configurable risk tiers (T1–T5) per merchant
Real-time settlement inside the closed loop
THE LAUNCH FOUNDATION

The Champion 4 today.
Open banking and neobanking tomorrow.

The Champion 4 is the launch product set. Each of the four is engineered as a standalone product and as a component of one closed-loop ecosystem. Together, they form the foundation for the next phase of FINAP USA's ambition: extending the same closed-loop architecture into a full open banking and neobanking platform purpose-built for compliance-intensive US markets.

The closed-loop architecture, the operator-funded sub-ledger model, the multi-FI capability, and the SOC 2-grade compliance posture are not features bolted onto a wallet. They are the foundations of a financial operating system designed to scale.

PHASE I
The Champion 4
CIXOR Pay · CIXOR PayDay · iPayLater · iPay Merchant Network — at launch.
PHASE II
Open Banking Layer
Embedded finance orchestration, AIS / data aggregation, cross-bank rail connectivity.
PHASE III
Neobanking Platform
Full-stack neobanking purpose-built for compliance-intensive verticals.
VERTICALS

Designed for the industries traditional banking won't bank.

Compliance-intensive sectors face structural barriers in conventional payment infrastructure. FINAP USA is being purpose-built for these markets — combining closed-loop architecture with sponsor FI partnership to deliver financial services that scale.

VERT 01

Cannabis

State-licensed dispensaries, cultivators, processors. Aligned with FinCEN 2014 Cannabis Banking Guidance.

VERT 02

Gaming

Tribal and commercial gaming operators. Cashless wagering and player wallet infrastructure.

VERT 03

Sports Betting

State-regulated sports wagering operators. Player onboarding, deposits, and winnings disbursement.

VERT 04

Adjacent Verticals

CBD, hemp, and other compliance-intensive sectors with structural barriers in conventional rails.

02 — HOW IT WORKS

A closed-loop financial
operating system.

Three structural design choices distinguish FINAP USA's engineered architecture from a conventional US fintech build. Each is deliberate. Together they describe a system that is capital-efficient, compliance-clean, and engineered to scale.

i.

Closed-loop circulation

Internal transfers between participants — employee, merchant, supplier — are designed to move value inside the system without touching external payment rails. Real money movement is engineered to occur only at deliberate boundary events.

ii.

Operator-funded value backing

Unlike a traditional neobank where customer deposits fund the FBO 1:1, FINAP USA's working capital is engineered to back sub-ledger positions. The FBO is structured as consistently over-funded against active wallet balances.

iii.

Sponsor FI Program Partner

FINAP USA is designed to operate without an MSB registration or state Money Transmitter Licenses. The sponsor financial institution holds the licensure, holds the FBO, originates ACH. FINAP USA is engineered to operate the programme inside the FI's regulatory umbrella.

LAYER 1 · CREDIT ACCOUNTING Receivable from Employer (asset) Wallet IOU to Wallet Holder (liability) No money moves here — pure accounting DRAWDOWN EVENT REIMBURSEMENT EVENT LAYER 2 · SUB-LEDGER & FBO Wallet sub-ledger position Merchant Available sub-ledger position Merchant Ledger suspense (unbacked) FBO at Sponsor FI operator-funded buffer
Two layers, designed to connect only at deliberate bridging events. Closed-loop transfers move sub-ledger positions; the FBO balance is unchanged.

Inside the loop

When a wallet holder pays a merchant, when one merchant pays another on the network, when an iPayLater repayment runs from the wallet — sub-ledger positions are designed to move atomically. No FBO movement. No external payment rail touched. Real-time settlement at zero marginal rail cost.

This is where the capital efficiency lives. Value is engineered to circulate inside the loop without burning float.

At the boundary

Real money is engineered to move only at the loop edge. Two events bring real money in: employer reimbursement at pay cycle end, and consumer wallet top-up. Two take it out: merchant withdrawal to external bank, and external bill payment.

Each boundary event is designed to be operated by the sponsor FI under its licensure. FINAP USA is structured so it never originates external money movement directly.

03 — WHY FINAP

The verticals others
won't bank, served right.

Cannabis, gaming, and other compliance-intensive sectors are systematically underserved by conventional payment infrastructure. The opportunity is structural — and the solution we are building is structural.

A market gap defined by regulatory friction.

The US cannabis industry alone is projected to surpass $40 billion in legal sales annually. Tribal and commercial gaming generates over $100 billion in gross gaming revenue. Sports betting is growing faster than any vertical in financial services. And yet — these markets remain structurally underbanked, locked out of card networks, dependent on cash, and exposed to operational risk that conventional fintechs cannot absorb.

The friction is not technological. It is regulatory. Card networks restrict cannabis. Money transmitter licensing is prohibitively expensive at programme launch. State-by-state compliance overhead is unmanageable for individual operators. The structural gap will remain until somebody builds infrastructure designed for it.

FINAP USA is being built to be that infrastructure. The closed-loop architecture draws on lessons from advanced international payment markets — including European-style consumer credit frameworks, real-time payment infrastructure, and open banking architectures — and is being implemented natively for the US context. The design is calibrated to BSA/AML, CFPB, FinCEN, and state-by-state regulatory requirements from line one of code, not retrofitted from a generic global codebase.

$40B+
US Cannabis Market
Projected legal sales — operating largely outside conventional payment infrastructure.
$100B+
US Gaming Revenue
Tribal and commercial gaming GGR — cashless wagering infrastructure adoption accelerating.
38
States with Sports Betting
Regulated sports wagering markets — the fastest-growing vertical in US financial services.

Capital efficiency by design

Closed-loop transfers are engineered to move sub-ledger positions, not money. Float is consumed only when value crosses the loop boundary externally. Internal value circulation is structurally free.

Compliance integration

BSA/AML, KYC, OFAC screening, and SOC 2 controls are being built into every workstream. No bolt-on. No after-the-fact remediation. Audit-ready by design.

Vertical-aligned architecture

FinCEN 2014 cannabis tier framework, state EWA carve-outs, gaming-specific compliance overlays — engineered into the operating model rather than retrofitted.

04 — COMPLIANCE

Compliance, by design.

FINAP USA is being engineered to satisfy the full US regulatory regime — BSA/AML, CFPB, FinCEN, state-by-state. Compliance posture is a foundational architectural choice, designed in from the first line of code rather than added at audit time. The work is to build to satisfy these obligations before launch, not to operate around them.

REG 01

BSA / AML

Customer Identification Programme, Customer Due Diligence, Enhanced Due Diligence, ongoing transaction monitoring, suspicious activity reporting, and currency transaction reporting — all engineered to sponsor FI standards.

REG 02

FinCEN 2014 Cannabis Guidance

Tier 1, Tier 2, and Tier 3 classification of cannabis operators with appropriate due diligence and monitoring overlays. Marijuana-specific SAR filing pipeline designed to align with sponsor FI cannabis banking framework.

REG 03

State EWA Frameworks

Employer-integrated EWA designed to align with state-specific carve-outs in Nevada, Missouri, Wisconsin, Kansas, and other states. State-of-residence drives jurisdiction-specific rule application throughout the system.

REG 04

Reg E · Reg Z · CFPB BNPL

Electronic Fund Transfer Act dispute and error resolution. Truth in Lending Act consumer credit disclosures. CFPB 2024 BNPL Rule dispute resolution and billing rights — engineered into iPayLater from the foundation.

REG 05

SOC 2 Built-In

Engineered to AICPA Trust Services Criteria from line one of code — Security, Availability, Processing Integrity, Confidentiality, and Privacy. The audit becomes documentation review, not control implementation.

REG 06

Sponsor FI Program Partner

The structure inherits BSA/AML obligations from the sponsor FI under joint and several liability principles, with FINAP USA engineered to deliver operational compliance to FI standards. The FI holds the licensure; FINAP USA is built to operate the programme.

PHILOSOPHY

Compliance as architecture, not afterthought.

Most fintechs treat compliance as a downstream operational discipline — apply controls after the system is built, retrofit policies, scramble for evidence at audit time.

FINAP USA inverts this. SOC 2 controls are being designed into every workstream as engineering requirements, not bolted on. KYC, KYB, OFAC screening, transaction monitoring, audit trails, encryption, access controls — engineered alongside business logic.

The objective: a system where audit becomes a documentation walkthrough rather than control discovery. And a sponsor FI partnership the FI can welcome, not endure.

AUDIT POSTURE

Annual cadence, evidenced continuously.

SOC 2 Type II attestation planned with US-recognised audit firm. Annual penetration testing. Quarterly access reviews. Quarterly disaster recovery testing. Annual security awareness training. Evidence collection designed to be continuous through observability platform — not scrambled-for at audit time.

VENDOR DILIGENCE

Every counterparty, vetted and on file.

Every third-party integration is to carry a current SOC 2 (or equivalent) report on file before integration begins. Annual vendor reviews documented. Sub-processor list maintained in compliance platform. Data Processing Agreements current and enforceable.

05 — PARTNER BANKS

For sponsor banks: capability without the build.

Compliance-intensive verticals are an underserved opportunity for sponsor financial institutions — but capturing them requires platform infrastructure that takes years and significant capital to build internally. FINAP USA is engineered to deliver that capability, ready to partner.

THE BUILD-VS-PARTNER MATH

What FINAP USA brings that takes years to build internally.

A sponsor financial institution that wants to serve cannabis, gaming, sports betting, and adjacent compliance-intensive verticals at scale faces a substantial internal build requirement. The capability spans closed-loop architecture, Program Partner programme management, BSA/AML monitoring infrastructure, FinCEN cannabis tier framework operationalisation, state-by-state EWA compliance configuration, SOC 2-grade controls, multi-product ledger architecture, and merchant network development.

The internal build path typically requires three to five years of platform development effort. The capital commitment exceeds the seven-figure mark in technology investment alone, before considering the team, the regulatory consulting, the SOC 2 audit cycle, and the vertical-specific operational expertise. Most sponsor FIs that have attempted this internally have produced incomplete platforms, missed launch windows, or deferred the strategic opportunity.

FINAP USA is engineered to be the partner that closes that gap. The platform is being purpose-built to operate inside a sponsor FI Program Partner umbrella, with the FI holding licensure and the FBO, and FINAP USA delivering the technology, programme management, vertical-specific compliance, and operational expertise the FI needs to capture these markets.

3–5
Years of build effort
Typical internal platform build timeline for sponsor FIs entering compliance-intensive verticals at scale.
7-Fig+
Capital commitment
Technology, regulatory consulting, SOC 2 audit, and vertical operational build — before launch readiness.
04
Products at launch
Closed-loop wallet, EWA, BNPL, and merchant network — engineered as one ecosystem, ready for FI partnership.
SOC 2
Audit-ready architecture
Engineered to AICPA Trust Services Criteria from line one — your audit posture is protected.

What a sponsor FI partnership looks like.

01

Programme economics, not flat fees

Configurable Program Partner economics across float income, transaction fees, and product-specific revenue lines. Per-FI splits, per-revenue-line, configurable in commercial negotiations — not hardcoded into the technology.

02

Multi-FI capability from day one

The platform is being engineered to support multiple sponsor FIs simultaneously, with traffic-light liquidity-driven routing across FIs. A partner FI is never locked into a concentration risk position.

03

Vertical compliance, operationalised

FinCEN 2014 cannabis tier classification, state EWA frameworks, gaming regulator overlays — engineered into the platform, not added by the FI. Your compliance team inherits a system that already speaks the language.

04

BSA / AML programme infrastructure

Customer Identification Programme, Customer Due Diligence, Enhanced Due Diligence, transaction monitoring, SAR / CTR pipeline — designed to deliver to FI standards under your joint and several liability framework.

05

Merchant network in flight

iPay merchant network development is part of FINAP USA's operating responsibility. Cannabis dispensaries, gaming operators, sports betting platforms — all onboarded with KYB, license verification, and configurable per-merchant risk parameters.

06

Strategic optionality forward

The Champion 4 launch is the foundation. The architecture is being designed to extend into open banking and full neobanking — meaning the FI partnership grows in scope and value over time, not just transaction volume.

SPONSOR FI ENGAGEMENT

Considering a Program Partner relationship?

FINAP USA is in active dialogue with prospective sponsor financial institutions. Detailed platform documentation, programme economics frameworks, compliance architecture briefings, and integration planning materials are available to qualified FI partners on request.

Engage with our partnership team
06 — INVESTORS

Built for institutional growth.

FINAP USA represents a strategic opportunity to back a US venture being engineered to capture the structurally underserved compliance-intensive financial services market — built on technology proven across advanced international payment markets, structured for US regulatory requirements, and aligned with a US public-market platform.

STRATEGIC PARTNERSHIP

FINAP × IPSI Inc.

The Term Sheet between FINAP and IPSI Inc. (OTCQB: IPSI) was executed on 31 March 2026, establishing FINAP USA LLC as the US operating venture for the closed-loop financial operating system.

The structure brings together FINAP's proprietary product portfolio — CIXOR Pay, CIXOR PayDay, iPayLater, and the iPay merchant network — with IPSI's US public-market presence on OTCQB and existing fintech partnerships.

The underlying product technology is the result of years of international platform development across advanced payment markets. Lessons from European-style consumer credit frameworks, real-time payment infrastructure, and open banking architectures are being implemented natively for the US context — calibrated to BSA/AML, CFPB, FinCEN, and state-by-state regulatory requirements.

The Asset
Years of build, ready to launch

Platform technology that would take a US fintech 3-5 years and significant capital to build internally — being adapted natively for the US market.

The Market
$140B+ underserved opportunity

Cannabis ($40B+) and gaming ($100B+) are the largest verticals systematically underbanked by conventional infrastructure. Sports betting is the fastest-growing.

The Structure
Capital-efficient by design

Closed-loop architecture means float capital scales with peak outstanding sub-ledger balances — not transaction volume. Engineered economics, not legacy economics.

The Forward Arc
Foundation for open banking

The Champion 4 launch is Phase I. The architecture is being designed to extend into open banking and full neobanking — long-term value compounding on the same foundation.

INVESTOR INQUIRIES

Detailed investor materials available on request.

Qualified institutional investors and strategic partners can request access to the FINAP USA LLC investor pack — including the Strategic Execution Strategy, Valuation Memorandum, financial projections, and detailed JV structure documentation.

Request investor materials
07 — LEADERSHIP

Built and led by US operators.

FINAP USA is being led by a team combining deep US fintech experience, public-market platform execution, regulatory expertise, and proprietary technology ownership — bringing lessons from advanced international payment markets to bear on the US opportunity.

A purpose-built US venture for compliance-first growth.

FINAP USA LLC is a US operating venture combining FINAP's closed-loop financial technology with IPSI's US public-market platform and partner network. Formed in 2026 through the strategic partnership Term Sheet, FINAP USA exists to bring purpose-built financial infrastructure to American compliance-intensive industries.

The technology foundation has been refined across advanced international payment markets — including European-style consumer credit frameworks, real-time payment infrastructure, and open banking architectures. Those lessons are being implemented natively for the US context, calibrated to BSA/AML, CFPB, FinCEN, and state-by-state regulatory requirements.

Track Record
10+
Years operating
Proprietary closed-loop payment technology platform development across regulated international markets.
5+
Markets entered
Operating experience across advanced payment regimes — informing the US implementation.
100K+
Wallets provisioned
Across the platform's international deployments — demonstrating production-grade scale.
4
Product portfolio
Wallet, EWA, BNPL, and merchant network — proven as a unified closed-loop ecosystem.
WC
PRESIDENT

William Corbett

President, FINAP USA LLC

President of FINAP USA LLC. Chairman and Chief Executive Officer of IPSI Inc. (OTCQB: IPSI), the strategic partnership counterparty in the FINAP USA joint venture. Brings extensive US public-company experience and fintech sector relationships to the FINAP USA leadership team.

KP
EVP · STRATEGY & GROWTH

Kutila Pinto

EVP, Strategy and Growth

EVP of Strategy and Growth at FINAP USA LLC. Architect of the FINAP USA closed-loop operating model and the US market entry strategy. Brings the operating experience from FINAP's international platform development across multiple advanced payment markets to the US implementation.

CP
EVP · BUSINESS DEVELOPMENT

Curtis Pope

EVP, Business Development

EVP of Business Development at FINAP USA LLC. Brings established US merchant network relationships, sponsor FI partnerships, and operational fintech experience to the FINAP USA platform launch. Leads merchant onboarding strategy and partnership development across the iPay network.

FL
LEGAL COUNSEL

Franklin Levy

Legal Counsel

Legal Counsel to FINAP USA LLC. Provides regulatory, transactional, and corporate counsel across the FINAP USA platform — covering the Program Partner FI relationship, BSA/AML compliance posture, consumer credit (Reg Z) framework, state-by-state EWA configuration, and joint-venture documentation.