Earlier quoted context omitted.
That doesn't sound like a full reserve though as its not 100% cash. It says right there that its partially invested in risky assets. Whether they're low risk is just an opinion. But even assuming it was a full reserve, I don't think its fundamentally different enough to be allowed to skirt the existing laws.
Fair point, its not cash. But generally in banking, cash and cash-like products are equivalent. I think they'll make public the actual investment breakdown. It's different enough from banks because its matched one for one with some asset. It's essentially a passthrough investment. The reason banks are so highly regulated is that they participate in fractional reserve banking where they take in deposits and invest in…
Yes. Including how the funds in the pre-paid card are managed and invested, and certainly including all the rules about when the user is allowed to reclaim their money.