Quote from: BitcoinINV on October 19, 2012, 12:34:13 AM

Can't see how bitcoins or credit cards fit in to that at all lol

Have you read the actual definitions of all the terms used on the form and obtained legal advice about whether they would apply to the OP's situation? Because "the people on Bitcointalk didn't see how I could be regarded as a MSB" isn't a legal defence for failing to register (the fine for failing to register within the required 180 days of starting business as a MSB is $5000 per day and that's assuming that you're not violating any other regulations at the same time).

OP needs specific information from FinCEN about which sections of their regulations apply to his proposed business and then he needs to seek expert legal opinion on the information provided by FinCEN and any specific additional requirements in the state where he's planning on operating. OP may, indeed, be exempt from needing to register as a MSB, but he needs that confirmed by the actual regulators, in writing.

The definitions aren't straightforward and they really need to be interpreted by someone who is familiar with past FinCEN rulings and enforcement actions. If you're going to argue that they don't apply to your particular business, you need to have a legal argument to that effect which would stand up in court.

http://www.shajlaw.com/moneyservicesbusiness_faq.html