Dear canth,

It's very refreshing to answer your logical questions, most people don't care about doing their homework, we really respect the time you have spent in digging out the legal facts here.

1. Sub section (b) is not applicable to our RPs or Trestor Foundation because of 2 reasons:
 
   a. There is no administrator
   b. RPs don't qualify as receiving financial institution

Reference: https://www.law.cornell.edu/cfr/text/31/1010.100

2. Sub section (c) is not applicable to our RPs, but may be applicable to Trestor Foundation, however,  we are very confident that our compliance   narrative is bullet-proof

Most important thing to understand here is what FinCEN thinks about its own guidance: 

This guidance explains only how FinCEN characterizes certain activities involving virtual currencies under the Bank Secrecy Act and FinCEN regulations. It should not be interpreted as a statement by FinCEN about the extent to which those activities comport with other federal or state statutes, rules, regulations, or orders.

FinCEN recognizes that the actual indictment probability arising from these guidance is low, not only because of overlapping laws but also because of definition complexity.

Trestor Team
@trestorconnect
www.trestor.org