Custodia applied the same month as Kraken — October 2020 — built a purpose-built Wyoming bank from scratch, got denied, and is still fighting in court. Kraken walks in and gets the skinny account. No interest on reserves, no discount window, but direct Fedwire settlement is the only part that matters — zero need for correspondent banking on USD flows. ABA calling this "cart before the horse" while every stablecoin issuer quietly lines up behind Kraken for the same template.

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