A recent trend that we are encountering frequently is software and internet-based platform providers (“providers”) venturing into the world of payments—sometimes unwittingly. A typical scenario looks something like this: A provider develops a platform that assists merchants (such as hair salons, utility providers, or medical offices) accept electronic payments from the merchant’s customers. Most commonly, the providers’ software or technology offerings assist these merchant businesses with virtually every aspect of their operations. So it seems only natural for the providers to offer a payment solution through the platform.