Hi All,

I have a customer that buys Virtual Currency as an investment opportunity. He does not purchase anything with the currency (per the Customer). The customer just buys and sells currency for personal use. This is not a business for him, per the customer. I looked at FINCEN definitions of User, Exchanger, and Administrator and having a hard time putting the customer into one of the categories. Does any one have a customer like this? Any thoughts on what this customer is of the three? Thank you.

As long as the customer is not purchasing or transmitting virtual currency on behalf of a third party, he is a user.

Thank you