In addition, a person is an exchanger and a money transmitter if the person accepts such de-centralized convertible virtual currency from one person and transmits it to another person as part of the acceptance and transfer of currency, funds, or other value that substitutes for currency.
You can speculate in real currencies without adhering to any special regulations, so there is no reason to think they would try to twist the word 'exchange' here to mean that.
As I said, you can buy real currency as a speculator and you aren't required to follow any regulations. Forcing speculators in digital currencies to meet the same requirements as financial institutions would be absurd.
I realize one could make a case that that is what they mean here but common sense dictates that was not the intent, and it is extremely unlikely speculators have anything to be concerned about.
