[StellarWind]

This is a dangerous game FirePay is playing. They are implicitly encouraging their account holders to churn deposits through merchant accounts so FirePay can charge the merchants fees.

Many sites seem to barely tolerate FirePay in the first place, imposing restrictons on FirePay withdrawals and setting low deposit limits that seem to be motivated as much by cost control as credit risk. FirePay could start losing key merchant accounts if those merchants perceive they are being abused.

That could trigger a death spiral as lost merchant accounts lead to lost consumer accounts lead to more lost merchant accounts, etc.