Edit: I think I figured out the answer. Giga has to become a barter exchange (threshold is 100 barters in a year)
I strongly suspect this isn't the case. There are lots of examples out there where organizations make payments to individuals or other entities in a noncash manner, but they aren't considered barter exchanges. While I can't name the proper form, I'm sure it can be reported more simply than what you're describing.
It occurred to me that using an exchange may get you out of the 1099-B requirement. Since the threshold for having to issue a 1099-B is the number of barters (trades) and when you use an exchange your trades are greatly reduced, you may get in under the 100. For example:
I think the situation in the past was something like this: when the exchange was handling the actual processing of dividends, the responsibility was on the exchange, not Giga. Now the responsibility shifts. What you say might be correct, but I think it's more or less moot now given that there really is no viable exchange alternative for him to move to at the moment.