MiCAR vs Metamask

Hello /r/Metamask europe citizen here,
is Metamask a Crypto-Asset Service Provider (CASP) in your opinion?

I think the matter is a borderline case, because while we can say Metamask “provides transfer services for crypto-assets on behalf of clients”, the meaning given to the wording “on behalf of” can literally change everything.
In the end Metamask is more of an interface through which operate your wallet, there is not a legal entity that operates directly this transfers.
What do you think?

For more info https://gtg.com.mt/classification-of-crypto-asset-service-providers-casps-under-micar/