120 days is enough for CT to price instant master accounts, but the actual bottleneck is Fed governance: Kraken only got a one-year limited-purpose account from Kansas City after years of SPDI trench warfare. If Circle, Anchorage, Ripple or Wise clear similar access, USDC settlement stops being a bank-partner risk trade and starts looking like regulated dollar plumbing with Fedwire on the back end. Bank lobby litigation is almost guaranteed, because once stablecoin issuers can hold limited balances overnight and bypass correspondent banks, the moat shifts from deposit franchises to compliance, distribution, and redemption speed.

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