Regardless, there very much is an account but it's transparent to the end user, Nintendo knows damn well what system, what payment and the like each purchase is made from and you can link your club Nintendo purchases together to get "credit" for them so to speak. The problem isn't whether there is an account or not, per-se, but rather that if they plan to keep it hidden away from the user and keep it invisible and give you no control over the account proper then they need to at least give you control over the software, or just go the full fledged user account way and make everyone get a Club Nintendo account and let us move stuff that way.
Nintendo keeping the account hidden wouldn't be that bad if I could take two systems and wirelessly transfer a title between them while there was an active internet connection to inform Nintendo of the transfer so they could change their records. I don't know how the DSi to 3DS transfer tool worked but it was probably something like that, the 3DS can talk to the Wii, I have used the DS demo download service and rated DS titles , so it can at least function as a DSi while connecting to the Wii, having to transfer the game from the Wii to the 3DS and from the 3DS back again would be a bit of a pain but it'd be workable, we don't even have a workable solution lol. But that's probably why these titles aren't out yet for the eShop.