It has restrictions and depending on how the Trust was constructed, it may not be applicable in other states for certain transmission activities.

>>Do other states consider this kind of trust company to be a bank or a money transmitter?

They evaluate what the Trust was built for,and what the company wants to do in their state, and evaluate whether there is a delta or overlap.

>>What does FinCEN think?

no diff, still have BSA/AML obligations and commitments.