https://bitcoinmagazine.com/articles/fincen-bitcoin-users-not-regulated-exchanges-are-1363675774

he clearly did not read this properly. so will quote the relevant parts for him to read here.

quote;                                  (tiny vern/cryptsy)
         The definition of exchangers is simple: “An exchanger is a person engaged as a business in the exchange of virtual currency for real currency, funds, or other virtual currency.” Finally, a user is simply someone who uses virtual currencies to buy and sell goods and services.   

quote;
          The major boon from the document for Bitcoin is this: users get off lightly. In fact, FINCEN does not intend to touch mere users of virtual currency at all; the document states, “a user who obtains convertible virtual currency and uses it to purchase real or virtual goods or services is not an MSB under FinCEN’s regulations. Such activity, in and of itself, does not fit within the definition of “money transmission services” and therefore is not subject to FinCEN’s registration, reporting, and recordkeeping regulations for MSBs.