This question is in regards to what qualifies(i.e. criteria) as a Informal Money/Value Transfer System and using an auto pgm interface to execute txns

Does using a interface program to auto login to a customer''s online bank account and execute a transaction(transfer money from one account to another) considered an Informal Money Tranfer System(IMTS). Our company will not take ownership of any money and will get a electronic signed consent from the user to use thier user id and password to login. Once logged in to thier online banking system/account, this interface program will execute transactions(send money to someone). The Banks will be a certified commerical bank i.e (BOA, Wells Fargo, PayPal, etc.). Our company will charge a potential fee for this service. I believe this is not considered a IMTS because our company will not take ownership of any customer''s money. A company called Mint.com already uses customer''s login information to retrieve customer reports from thier on line bank accounts.