Specifically, under the BSA, financial institutions include a broad array of financial intermediaries such as banks, securities and exchange commission, registered brokers or dealers, money service businesses, telegraph companies, casinos, and anyone subject to federal or state bank supervisor or authority. In its 2019 guidance application of FinCEN's regulations to certain business models involving convertible virtual currencies, so this is the 2019 FinCEN guidance, the regulator states that its regulations exempt from the definition of money transmitter, those persons providing the delivery, communication, or network access services used by a money transmitter to support money transmission services. So that's an important point. They exempt from the definition of money transmitter, those persons providing the delivery, communication or network access services used by a money transmitter to support money transmission services. So not the services themselves, but those tools used to support that. And this is because the suppliers of tools, communications, hardware, software that may be utilized in money transmission are engaged in trade and not money transmission. Now, 2019 was not the first time that FinCEN made this claim. An earlier FinCEN administrative ruling had stated that the production and distribution of software in and of itself does not constitute acceptance and transmission of value, even if the purpose of the software is to facilitate the sale of virtual currency. Once again, the production and distribution of software in and of itself does not constitute acceptance and transmission of value, even if the purpose of the software is to facilitate the sale of virtual currency. And that was from an earlier FinCEN administrative ruling from 2014, titled, an application application of FinSEN's regulation to virtual currency software development and certain investment activity. That builds on even earlier guidance before FinSEN ever publicly discussed cryptocurrencies where FinSEN distinguished the provision of software and hardware services as not money transmission, even where the software and hardware services were used by others to conduct regulated transmission services. It has always been that under the BSA, persons engaged solely in software development activity are not financial institutions under the BSA, nor are the software providers who simply offer services for communication or network access, even if those services are used by financial institutions for regulated activity. And that makes sense. Just because you use a certain internet provider to conduct money transmission should not implicate that service provider, and that would have huge ramifications for the ability of a competitive market, frankly, to exist when you'd only have the biggest entities being able to afford to pay the fees that would have to be put on to them after a regime like this was set up.