This is a very good point by Moynihan. Circle should definitely have to meet these requirements to offer yield. Let's see... (1) Scrutinize risks? Here's the reserve report. It's entirely cash deposits, short term treasuries and repo agreements... the safest and most liquid assets on the planet. They literally cannot invest in anything else. And for the banks? I've structured loan facilities for banks that would make even the most seasoned lawyer's eyes bleed trying to understand from scratch the 1000+ pages of loan documents, multiple lien structures, bespoke waterfalls, carveouts, baskets, etc. And they can have exposure to hundreds and thousands of these facilities, each with their own idiosyncratic risks. (2) Hold routine examinations of their operations? Well, GENIUS says they can only issue, redeem, custody and manage reserves, and still undergo examinations re: systems, compliance and BSA. Not a lot of wiggle room. (3) Setting capital aside? Yea, they set aside ALL of it, 100% fully-backed reserves always. What's the reserve requirement for banks set at today? 0%? Anything else? Are we good here then? The real point here is being a bank actually can be extraordinarily complicated, because they serve sophisticated clients with complex deals and finite resources. Liquidity is getting pulled in and out in a million directions. Maximizing capital efficiency is a giant logistical problem with a thousand variables. And yet, none of that is applicable to stablecoin issuers...(Scott Johnsson)