Jered, how will the latest guidance from FinCEN affect your plans?  While limiting participation to accredited investors overcomes risks associated with offering unregulated securities, the FinCEN guidance statement makes pretty clear that Bitcoin exchanges operating within the US will be regarded as both exchangers and money transmitters and subject to the regulatory requirements which apply to those types of financial services providers.  This obviously imposes a significant financial and administrative burden on any US exchange as neither licensing nor compliance are cheap.  Is Prime in a position to meet those additional burdens?