So some kind of aggregator/software product? If you are not taking or even touching user funds in the process, you can probably avoid regulation, but in that case I do not see why you need a C2B account and cannot use a physical bank or low-risk EMI showing them the technological services you provide that do not involve working with client funds.It depends on what you call unregulated and jurisdictions of context. For instance in my case, I plan to conduct my activities solely within a regulated exchange in the jurisdiction. Therefore I do not necessarily have to be regulated if I'm only acting on behalf of the exchange and within the exchange framework. This is simple as abc, people are just dumb or not understanding what the law says.
And if you are taking custody of user funds or processing them through yourself, you are undertaking a regulated activity, maybe even as a small payment institution if receiving fiat and forwarding to an exchange. Or you are registered in a jurisdiction with little-to-no crypto regulation, in which case I would not be surprised EMIs reject it.
Btw, @Forester, I think it would make sense to branch off this part of content regarding @jellea's account opening options into a new thread as it does not really relate to Bankera scam/not scam status.