My understanding is that banks need not register with the states.  Dwolla tried the registration route and as I understand it abandoned the effort when association with another was easier, cheaper, etc.  They focus on thier core business while the bank addresses compliance.

Now if I were to guess Milne is after market share at this point, so profit is a longer term proposition and I can't say the association with the bank fits the model, but the idea is pretty solid and money is willing to follow.....

And yes, BCB, I have chatted with Silicon Valley Bank and they are very aware of their position here......