According to CoinMeta, Wu said that bitcoin, policy, and institute ( BPI ) believe that although the revised Blockchain Regulation Certainty Act ( BRCA ) removes the explicit exclusion of non-control developers from 18 U.S.C § 1960, this does not mean that § 1960 applies to non-hosted software developers. The revised version still explicitly excludes developers who cannot control user assets or initiate transactions unilaterally from federal funds transfer registration, FinCEN requirements, and related Bank Secrecy Act provisions. It also limits state governments from imposing similar regulations based solely on software development, self-hosting, and infrastructure activities. Therefore, this could weaken the basis for state licenses and federal registration on which some of the charges in § 1960 rely. BPI believes that although the new text is not as clear as the earlier versions, it still provides more legal grounds for non-hosted developers to argue that they should not be considered as fund transferors.