You’re conveniently ignoring what “reserves” means in the GENIUS act. Unlike regular banks, Circle can use US Treasuries instead of cash so that they earn interest and prop up US government debt at the same time. It’s a clever scheme, but not the same as being forced to hold fiat reserves.

Many other banking regulations also don’t apply. No FDIC insurance and most importantly none of the regulations that apply to true fiduciaries since they are only “custodians”.