Wait a minute... So by that same logic. If I buy coins on coinbase today, then sell them back to coinbase a month later at a profit(assuming btc price rises) I would be classified as an exchanger?
Isn't this the goal of most people buying bitcoins? Is there currently no legal way for a "user" to speculate on the price of BTC without Fincen and state government approval?
What if my s-corp pays me for my services in BTC via coinbase? I'm I only allowed to buy products and services with this btc and not eligible as a "user" to convert it back to USD?