I am not an expert, this is just my opinion and only for your consideration. The guidance is quite broad and overreaching in my opinion.
"An administrator or exchanger that (1) accepts and transmits a convertible virtual currency or (2) buys or sells convertible virtual currency for any reason is a money transmitter under FinCEN's regulations, unless a limitation to or exemption from the definition applies to the person."
Here is a link to FinCEN's guidance on virtual currencies:
http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.htmlThis is why I chose to suspend Bitcopia's service. While the regulation is somewhat unclear, there are possible harsh penalties for non-compliance, especially if you are not making any effort to prevent money laundering i.e. Liberty Reserve.