In the more than 170 pages of Snap’s IPO draft, its P2P payments service, Snapcash, received a mere paragraph.

Snapchat’s parent company will look to apply for a payments license in order to “mitigate regulatory uncertainty,” according to an S-1 filing.

Although we currently use the service of a third party to provide the Snapcash feature, these laws may apply to us in some jurisdictions. To increase flexibility in how our use of Snapcash may evolve and to mitigate regulatory uncertainty, we may be required to apply for certain money-transmitter licenses in the United States, which may generally require us to demonstrate compliance with many domestic laws in these areas.

Moreover, Snap said it has not “recognized revenue related to Snapcash to date.” The company launched the Venmo-like free P2P payments service in 2014, through a deal with Square Cash (the “third party” referred to in the S-1.) Back then, the company also filed for trademarks around merchant payments: “Electronic transfer of money for others; providing electronic processing of electronic funds transfer, ACH, credit card, debit card, electronic check and electronic, mobile and online payments.”

The company noted that it generated 96% of its total revenue in 2016 from third-party advertising. It seems that the increased ad interest could serve as a potential monetization route, with merchants posting “stories” featuring products that could be purchased on the spot. But just like with Facebook Messenger’s payments feature, Snapcash is likely to remain free for person to person payments.

Diana, great question! At some point they will need to take payments in-house like Facebook. Many ways to remain free.

— Brian Roemmele (@BrianRoemmele) February 3, 2017

Snapchat’s parent company filed for an IPO on Thursday, looking to raise $3 billion, with valuations reported to be as high as $25 billion. The app reported 158 million active users globally in 2016.

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