They create a virtual currency, even if it is decentralized. This includes creating altcoins. In fact, Satoshi would have commited a crime creating Bitcoin without registration. (200.2n5)
I don't agree with this interpretation.
200.2m: Virtual Currency means any type of digital unit that is used as a medium of exchange or a form of digitally stored value or that is incorporated into payment system technology.
200.2n5: controlling, administering, or issuing a Virtual Currency.
So, by their definition, VC is the currency, not the protocol. Satoshi has published Bitcoin the protocol, but he has never "issued" Bitcoin the currency.
Mastercoin and Ripple could be in trouble, though.And Nxt, NEM, any coin that IPO'd and possibly any coin that was instant/ninja mined.
I would also say that ALL proof-of-stake coins are "controlled and administered" by the developers in order to bypass the nothing-at-stake problem therefore giving them administrator privileges over the blockchain (
for example, Vericoin devs just forked their blockchain to undo the theft from Mintpal).
Legitimately mined coins would be fine IMO. I expect sidechains and spinoffs would be fine too. I'm not sure about proof-of-burn coins (e.g., Counterparty).