Answer:
Probably not. Under ยง 1020.315(e)(8), certain businesses are ineligible for exempt status, including a business engaged primarily in a specified activity which includes serving as a "financial institution." The definition of a financial institution can be found in 31 U.S. C. Sec. 5312(2). Section (N) lists a dealer in precious metals, stones, or jewels, so if the dealer in your question is primarily engaged in precious metals, stones, or jewels, you should not exempt them.