You're not reading my replies. First, you based all your points on the basis that you have to have an MSB, I showed you one way that's not true. Now you're assuming that the only two ways are obtaining MSBs or getting a bank charter. The thing you're missing is that there are multiple (as in more than two) ways of being compliant with fincen, as I said in my first and second comment (apparently you glossed over both) not just MSB or a banking charter. Your entire argument is based on flawed assumptions.