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Banks are regulated the way they are because of what banks do: lend, transform maturities, run roughly 10:1 leverage, and create credit. GENIUS issuers cannot do any of those things. By statute, they hold cash and short-dated US Treasuries 1:1 against on-demand claims. No loans. No leverage. No fractional reserve. The free-banking analogy doesn't hold. Pre-1863 notes were backed by speculative state bonds under inconsistent state rules, with no federal floor. GENIUS imposes exactly the floor that era lacked: high-quality liquid assets, segregation, par redemption, monthly attestations, and federal supervision.