Great service but I think not being registered with the state of North Carolina as a MSB is going to cost you your business and investments. The Gov is no longer watching to see if people will comply they are forcing people to comply. Paypal had the same problems when they first started and had to go state by state to get the MSB, green dot when through the same process.
Next time CoinRNR is in a gas station in NC I suggest he looks at the door and see that they even had to register with NC as a MSB just to sell green dot and other stored value.
The Federal MSB does not protect you from each state, you are in violation of each state that requires MSB if you accept payments from the customers in that state. So you could be charged by each state you accept payments as being a unlicensed MSB/MT
http://www.fincen.gov/financial_institutions/msb/pdf/msbstatecontactsfinal.pdfNorth Carolina listings of money transmitters
https://www.nccob.org/Online/MTS/MTSCompanyListing.aspxWhat you need to be a Money Service Transmitter in NC
https://www.nccob.org/Online/MTS/MTSCompanyListing.aspx53-208.5. License qualifications.
(a) Each licensee shall have at all times a net worth of not less than one hundred thousand dollars ($100,000) calculated in accordance with generally accepted accounting principles. Licensees engaging in money transmission at more than one location or through authorized delegates shall have an additional net worth of ten thousand dollars ($10,000) per location in this State, as applicable, to a maximum of five hundred thousand dollars ($500,000). Licensees with neither locations nor authorized delegates in this State shall have an additional net worth as established by the Commissioner in an amount not to exceed a maximum of five hundred thousand dollars ($500,000).
Great business, Great idea, legal suicide......
I'm familiar with the MTA in NC. I don't, however, agree with you that what we are providing is 'stored value' or a 'payment instrument' and therefor our activities are not money transmission by the NC definition. Without further clarity from state level regulators (honestly, the only state really to provide true clarity on bitcoin money transmission licensing thus far has been Texas), it's impossible to assume how they will define bitcoin in their laws. If a state were to follow in the footsteps of the IRS for example, and declare bitcoin as property, none of the current money transmitter laws would apply. We do not hold customer funds nor do we do not conduct remittances. Instead, we only provide a retail USD to bitcoin transaction with verified individuals (no 3rd parties) who adhere to strict transaction limitations. Gas stations offering prepaid cards, western union, or other money transmissions, are of course required to be licensed as is any check casher or exchanger of foreign currency.
In the interested of keeping this thread on topic, feel free to PM me to discuss this more.
