The fincen guidance from march 18th says:
' A person that creates units of this convertible virtual currency and uses it to purchase real or virtual goods and services is a user of the convertible virtual currency and not subject to regulation as a money transmitter. By contrast, a person that creates units of convertible virtual currency and sells those units to another person for real currency or its equivalent is engaged in transmission to another location and is a money transmitter. In addition, a person is an exchanger and a money transmitter if the person accepts such de-centralized convertible virtual currency from one person and transmits it to another person as part of the acceptance and transfer of currency, funds, or other value that substitutes for currency.'
I'm an LTC miner, and i convert LTC to BTC and I'm thinking of selling that BTC for USD thru campbx.
If I do that, I'm thinking I'm a user of the currency, and the exchange (campbx) is the money transmitter.
I'm not selling them to another person, I'm using an exchange to convert BTC to USD.
What do you guys think?