To run a proper Bitcoin exchange in the US, you need to
register with the SEC as a broker/dealer. That lets you accept trading transactions for anything tradeable. A "broker", under US law, is "any person engaged in the business of effecting transactions in securities for the account of others." It includes "persons that operate or control electronic or other platforms to trade securities". There's some argument over whether Bitcoin is a "security", but if you're registered as a broker/dealer, that takes care of that problem. Every brokerage in the US, big or small, has been through this process.
One way to do this is to buy an existing small broker/dealer. Here's a
list of broker/dealers for sale. For $105,000 someone could buy an inactive broker/dealer registered in 19 states. That takes care of most of the registration problems. All the registration info will have to be updated, but that's easier than doing this from a cold start. The name of the company can be changed at this point if desired.
Thanks for the info. It looks like a firm with less than $1Mil can do all of the FINRA filings for roughly $20K. But once you break that $1Mil mark but less than 25Mil gross, you will need to pay up to $3Mil per year and up to 75cents per transaction.
The gentleman in Georgia is using the single state loophole. At least it is a way to get the ball rolling and find out how much volume you will wind up doing. And, of course, build up your funds so you can hire all of the regulatory personnel, etc....
Interesting reading, I appreciated it.