Any time that a bank is reputed to be in trouble, if that bank has substantial uninsured deposits, it is likely to fail. There is no reason for uninsured depositors to stick around. We don't live in a world of small towns where depositors have any cause for loyalty to the bank.

If banking regulators expect bank depositors to bear some risk of failure, then it would seem that banking regulators should require banks to be far more transparent about problems, along the line of what the…

On jurisdiction, the Complaint attempts to create as many links between Binance and the United States as is possible. Many of the links alleged do not raise any obvious U.S. legal issue; e.g., hiring U.S. service providers. Likewise, it is not inherently problematic that Binance would have non-U.S. customers that are subsidiaries of U.S. holding companies. Presumably the question of what creates jurisdiction for purposes of the CEA and CFTC Rules will be better and more narrowly defined in…

The macroeconomic modeling used in the analysis is well beyond anything taught in law school, but the conclusion seems fairly common-sensical: at a time when banks are failing, investors could bail out of bank deposits and hold central bank digital currency representing a direct claim on the government. Under the current circumstances, given the general anxiety as to the safety of bank deposits, it seems reasonable that investors would move cash out of banks if there were an easy alternative…

The inclusion of the CFPB as being subject to the IG seems an interesting element of this, though neither of the Senators mentions the CFPB in his/her press release.