Doesn't it cost like $10 million or something to get started and you have to register in every state?
Well that's what I've been researching, and the fees and state-by-state registration is for actual exchanges. Since I will not be selling or exchanging coins, Im not sure this would apply.
You are ABSOLUTELY correct that this can totally be seen as a true exchange - but operations like LocalBitcoins seems to be doing just fine.