The real meat in this letter is under Section C for "stored value." The Bitcoin Foundation says that Bitcoin is not stored value. This directly contradicts U.S. Department of Treasury FinCEN statements which say that the reason why Bitcoin operators need money transmitter licenses (or MSB licenses) is because BTC is stored value.
When did FinCEN state that bitcoin is stored value? Since 2011, FinCEN regulations have referred to "prepaid access" rather than "stored value", and they have never claimed that bitcoin is prepaid access either.
In a letter to Tangible Cryptography LLC, the State of Virginia did claim that bitcoin was stored value. However, the definition of stored value in the Virginia law is somewhat different than the California law and the former federal regulations.
FinCEN's March 18 guidance specifically said virtual currencies are not prepaid access.