The FinCEN guide indicates that
"An administrator is a person who, as a company, issues
(putting into circulation) a virtual currency, and which has the
power to redeem (withdraw from circulation) these virtual cards
"a administrator or convertible virtual currency exchanger
who (1) accepts and transmits a convertible virtual currency or (2)
buy or sells convertible virtual currency in exchange for money
legal tender or another convertible virtual currency for any
reason (including the intermediary between a user and a seller of
goods or services that the user buys on his behalf) is a
issuer of funds according to FinCEN regulations"
From what I understand, Ripple and Stellar are money marketers because they are administrators and sell convertible virtual currency in exchange for money. BUT, as I have seen so far, Ripple is registered with FinCEN as an ESM, but not specifically. as a money issuer.
In addition, as the issuer of funds, it is also necessary to obtain licenses in each state.
Am I missing something?
Thanks in advance!