I've taken the holiday seriously...my brain has not tried to remember anything more strenuous than the names of distant relatives for days.
Nevertheless, MSBs that only sell stored value cards (regardless of amount) are not required to register as MSBs. So, they still meet the definition of an MSB, but the primary regulatory requirement is inapplicable. Moreover, FinCEN Ruling
2003 - 4 guardedly opines that "closed system" cards do not meet the definition of stored value cards anyway. Whatever your risk classification might be, you will not enhance it by classifying DD as an MSB.