The FinCEN guide states that
"An administrator is a person dedicated to the issuance of
(put into circulation) a virtual currency, and who has the
authority to exchange (withdraw from circulation) virtual sayings
"a administrator or convertible virtual currency exchanger.
that (1) accepts and transmits a convertible virtual currency or (2)
purchase or sells convertible virtual currency in exchange for currency
of legal tender or another convertible virtual currency for any
reason (even when the intermediation between a user and a seller of
goods or services that the user is buying on behalf of the user) is a
Money transmitter under the FinCEN regulations."
As I understand, Ripple, like Stellar, are money transmitters because they are administrators and sell convertible virtual currency in exchange for currency, BUT, as I have seen so far, Ripple has registered with FinCEN as MSB, but not specifically as a money transmitter.
In addition, as a money transmitter, you also need to obtain licenses in each state.
Am I missing something?
Thanks in advance!