[Can] Corn be a "store of value". What about gold? Or oil?
It doesn't matter.
The whole point of the 'Money Services Business' designation which Bitcoin just ran into is to enforce standard regulations for all 'Financial Institutions'. The definition of 'Financial Institutions' already includes brokers, broker-dealers, exchanges, etc.[1]
So [is] a corn broker considered a money exchanger/transmitter?
No. They are considered brokers. Brokers and commodities exchanges are regulated separately by FINRA and the CFTC/NFA and therefore are not considered MSBs. From the regulation: The term “money services business” shall not include: .... A person registered with, and ... regulated by, the SEC or the CFTC. [2]
It's all there. The concept of a 'bitcoin' isn't actually very original, people have invented dozens of currencies and other schemes to launder money and avoid taxes. Whether or not that was Bitcoin's intent, it's going to have to play by the rules as if it were.
The whole point of the 'Money Services Business' designation which Bitcoin just ran into is to enforce standard regulations for all 'Financial Institutions'. The definition of 'Financial Institutions' already includes brokers, broker-dealers, exchanges, etc.[1]
No. They are considered brokers. Brokers and commodities exchanges are regulated separately by FINRA and the CFTC/NFA and therefore are not considered MSBs. From the regulation: The term “money services business” shall not include: .... A person registered with, and ... regulated by, the SEC or the CFTC. [2]It's all there. The concept of a 'bitcoin' isn't actually very original, people have invented dozens of currencies and other schemes to launder money and avoid taxes. Whether or not that was Bitcoin's intent, it's going to have to play by the rules as if it were.
[1] - http://www.fincen.gov/financial_institutions/msb/definitions... [2] - http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=b49834e1...