Can MSB registration let us hold customer funds?

Do not assume that registration alone settles the question. Assess the exact activity you want to perform and who will be responsible for the customer assets.

Start with the flow of funds. Who receives the payment? Who converts fiat into stablecoins? Who controls the wallet or can move the assets? Which entity owes the customer their balance?

The structure needs to establish how customer entitlements are recorded, what protections apply and which permissions are required. FINTRAC registration concerns anti-money-laundering obligations; FINTRAC does not issue licences or supervise businesses beyond that statutory framework. (Source: FINTRAC guidance)

Merchant-of-record status and card acceptance are separate questions. Offering Apple Pay also requires the appropriate payment-processing setup. Do not assume that an MSB registration obliges a processor to accept your business, approve every app you introduce or let you onboard merchants without review. Apple's implementation guidance directs businesses using payment platforms to work with their providers on the setup. (Source: Apple Pay guidance)

Have qualified counsel assess the proposed funds flow and ask your partners to confirm the roles they will accept. That will tell you whether to operate through your own regulated entity, an appropriately structured partner arrangement, or a combination.