The prohibition on paying interest in the GENIUS Act surprises some people because they THOUGHT it was intended to prevent the transmission of economic value to holders. But the language is very clear, that is not the intent. The intent was to separate out functions so that issuers are essentially a limited purpose bankrupt-remote SPV, limited to issuance/redemption of dollar tokens and reserve management backing those on at least a 1:1 basis. To the extent "interest" liabilities are created, they need to be structured under another entity without recourse to the underlying reserves and under a separate regulatory regime. It's that simple folks, and it doesn't involve a conspiracy about "loopholes". Sorry that banks didn't keep their eye on the ball, or at least failed to make a counterargument during drafting negotiations.