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For example it could say that in effect each person using Bitcoins to buy something issues the coin because any transfer of a coin creates a new need to get it incorporated into blocks and accepted by the system. That would mean that those who make a business of buying and selling Bitcoins would be issuing a payment instrument. There might also be an argument that anyone creating a new block issues value for the same reason even if no coins are generated.
I don't think such an argumentation could hold up in court: there is no issuing of a payment instrument when you make a Bitcoin transaction. You just transfer the control over some funds to another address - no new value is created.Maybe somebody with a better understanding of financial law can shed some light on this, but if anybody can be called a Bitcoin issuer, then it's the miners.
From now on you have to be very careful when you tell somebody the solution to a math problem - it might require you to get a bank license first
