This seems to be intended to apply to people operating exchanges like Mt.Gox, not lay consumers and merchants. Of course, it's possible they've drafted it, but

This seems to be intended to apply to people operating exchanges like Mt.Gox, not lay consumers and merchants. Of course, it's possible they've drafted it, but this part of page 6 seems pretty clear: Section 200.3 License... (c) Exemption from licensing requirements. The following Persons are exempt from the licensing requirements otherwise applicable under this Part: (1) Persons that are chartered under the New York Banking Law and are approved by the superintendent to engage in Virtual Currency Business Activity; and (2) merchants and consumers that utilize Virtual Currency solely for the purchase or sale of goods or services or for investment purposes. We should get an actual lawyer to evaluate this, which I am not.