This definitely raises more questions than it answers. Can a typical money transmitter just pretend to handle Bitcoin as well and magically exempt itself from the state money transmission framework? Do other states consider this kind of trust company to be a bank or a money transmitter? What does FinCEN think?

>>Can a typical money transmitter just pretend to handle Bitcoin as well and magically exempt itself from the state money transmission framework?

It has restrictions and depending on how the Trust was constructed, it may not be applicable in other states for certain transmission activities.

>>Do other states consider this kind of trust company to be a bank or a money transmitter?

They evaluate what the Trust was built for,and what the company wants to do in their state, and evaluate whether there is a delta or overlap.

>>What does FinCEN think?

no diff, still have BSA/AML obligations and commitments.