Thus by the letter of the guidance above this would be a regulated entity
BTC: Person A -----> Exchanger ----> Person B
USD: Person B -----> Exchanger ----> Person A
Here there is an acceptance of BTC from on person and transmission of BTC BTC to another person.
However by the guidance as written above, the following would not be regulated entity:
BTC: Person A ----> Buyer
USD: Buyer ----> Person A
There is acceptance of virtual currency by the buyer but no transmission to another person. If this looks familiar to a certain company business model well that is the point.
So if it's confirmed this would basically mean that if and exchange become a market maker instead of just facilitating exchange p2p I would not require any kind of regulation ?