My complaint involves XXXX XXXX XXXX XXXX XXXX XXXX and application filed with Bank of America ( BOA ) for a corporate business bank account. It was alleged by BOA that XXXX was a wire transfer service, resulting in bank account denial. 

XXXX XXXX ... is a XXXX Provider and reserves the right to create an entity to drive its XXXX services. As provided XXXX was created to XXXX XXXX XXXX XXXX XXXX XXXX XXXX consisting of but not limited to XXXX search, XXXX invoicing, and XXXX proxy functionality to enable alternative ( cash ( and debit ) ) payment for XXXX when booked online. 

Generally, the process is as follows : 1. User search and book flight at XXXX ( currently in XXXX at XXXX ) and 2. Opt to pay cash ( or debit ) offline, user has the option to pay cash/debit offline or credit/debit online 3. User is invoiced for booking ( see step XXXX ) and is instructed how to pay offline at XXXX 4. The user transacts accordingly at XXXX with cash ( or debit ) 5. Based on amount user transacts ( for XXXX ) at step XXXX XXXX makes ACH deposit into XXXX 's bank account. 
6. XXXX notifies XXXX that payment has occurred and ACH initiated 7. In the capacity of XXXX proxy XXXX purchase airfare electronically with debit card on behalf of user and 8. Sends flight confirmation code and further instructions via email, text or voicemail to user XXXX ( XXXX ) such as, XXXX. technically do the same as XXXX, enable travelers to search and book flights online and subsequently transact payment offline, but at XXXX XXXX in contrast to XXXX, with cash ( or debit ). However, said XXXX 's in contrast to XXXX have not been singled out for unfair and unfavorable treatment, ( re ) classified by financial institution ( BOA or otherwise ) as a wire transfer service, resulting in denied corporate banking account. 

On another note, XXXX gift cards ( not limited to XXXX and XXXX XXXX XXXX ) are sold offline at major retail locations and payment is transacted with cash ( or debit ), same as XXXX. On the same token, XXXX XXXX XXXX XXXX and XXXX prepaid debit cards are sold offline ... and payment is transacted with cash ( or debit ), same as XXXX. XXXX and XXXX prepaid debit cards in are commonly purchased offline used to purchase airfare online, or electronically. 

Technically, XXXX, XXXX XXXX, XXXX and XXXX does what XXXX does but differently : 1. XXXX XXXX XXXX XXXX : Initially cash/debit transacts offline at retailer prior to booking flight 2. XXXX, XXXX XXXX debit card : Also initially transacts cash/debit offline at retailer prior to booking flight 3. XXXX : Initially books flight online ( at cashairfare.com ) and subsequently transact cash ( or debit ) payment offline ( at XXXX ) At bottom, airline stored value gift cards sold offline ... and XXXX, XXXX prepaid debit cards sold offline ... technically do the same as XXXX with few exceptions. 

Our business model ; our competitive advantage is to provide a streamlined, secure process enabling travelers ( not limited to those with online security concerns ) to search airfares online, book, and then transact payment using cash ( or debit ) offline at XXXX. Technically, we are a biller similar to the XXXX billers using XXXX ( likely some are BOA clients ). XXXX-categories for a list of XXXX billers including BOA listed under Consumer Loans and Collections.