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The FIO Protocol can enable exchanges to transfer funds between themselves without ever having to do the transfer on chain. It can do this because a FIO Request initiated by a user on one exchange is cryptographically signed by that exchange uses a private domain which only that exchange can create addresses on.
We need to model the business op according to the number of transactions per inter exchange withdraws and deposits. Also, we need to consider for popular assets (e.g. BTC, ETH).
Lastly, it would be worthwhile to consider how we model settlement and reconciliation to aggregate tier2 exchanges and wallets (with FIO send).