In my research, I am coming to the conclusion that pretty much any precious metals dealer in the US is an MSB, and I don't think any of them are registered. At Wells Fargo, on a list of ten questions, the last question relates to being an MSB: Do you accept wires from one place and send them to another? All the other questions are about cashing checks. That is the last one. That is what precious metals dealers do. That means that GSBTC, Amagi, Agora, AK Coins, etc. are MSBs...
No, can't equate these with an "=", and certainly not categorically.
For example my legal counsel opines otherwise, given our facts and circumstances, as does the bank manager at our local Wells Fargo.
Furthermore, by your reasoning if it were to be held as such, than most any merchant / manufacturer could also be drawn in.
There may be some who are (maybe if they provide for inter-customer payments within their system), but it comes down to "facts and circumstances" anyway.
There is an odd predilection for suggesting further extensions to a compliance regime presumably in order to show how it is already over-extended and how slippery the slope may be, but maybe this is not so useful of an effort?
