I'm not US-legislation expert, but similar legislation with similar intent applies here in EU - and it's quite clear.
Payment processor and/or agent status should apply if you are handling data and information only and not for a moment become 'holder' of the money - i.e., if the money passes directly to, say, a bank account held by the recipient company based on your data.
If the money at any time held in your name and you just have data saying that $X belongs to A, $Y belongs to B - then even according to common sense you should be licenced and post the bonds. And to the extent that banks are exempt in payment regulations, they have the same (or stricter) requirements in their regulation as credit institutions - i.e., they don't put bonds based on payment volumes but they have capital requirement regulation that provides a similar assurance of solvency.
Payment processor and/or agent status should apply if you are handling data and information only and not for a moment become 'holder' of the money - i.e., if the money passes directly to, say, a bank account held by the recipient company based on your data.
If the money at any time held in your name and you just have data saying that $X belongs to A, $Y belongs to B - then even according to common sense you should be licenced and post the bonds. And to the extent that banks are exempt in payment regulations, they have the same (or stricter) requirements in their regulation as credit institutions - i.e., they don't put bonds based on payment volumes but they have capital requirement regulation that provides a similar assurance of solvency.