Does this make them a broker dealer because they are approving a securities transaction and receiving securities-based compensation? But if these miners are manufacturing securities or participating in securities transactions and must be registered as broker-dealers, the ramifications may be profound. In the filing, they say miners are not Broker Dealer's, no Transfer Agent is required, no clearing agency functions are being performed. This is largely due to the focus on "salesman's stake" functionality of Broker Dealers absence in this case. However, the SEC has said before that Broker Dealers do not have to have human involvement.
Source: Forbes May 02, 2019 17:48 UTC