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2021: Tether's reserve representations face an enforcement finding
The CFTC order concerned historical statements about backing, with a defined period and a defined penalty.
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The statement investors relied on
On 15 October 2021, the CFTC announced a $41 million penalty against Tether over misleading statements concerning USDT's backing. A separate $1.5 million Bitfinex penalty brought the combined announcement to $42.5 million. These were distinct findings, not one interchangeable fine against every related entity.
The reserve question is more precise than whether a token can usually trade at $1. It concerns the assets supporting redemption, where they are held, their liquidity and the accuracy of the issuer's description during the relevant period.
Preserve the date of the evidence
A historical enforcement order does not establish the composition of reserves today. A recent attestation does not erase a historical finding either. Both should retain their reporting dates and scopes so that a reader can see what changed.
This is particularly relevant to stablecoin comparisons and reserve-versus-liability analysis. Cash, government debt, loans and other assets do not have identical liquidity or risk. The phrase fully backed is incomplete until the underlying assets, obligations and redemption process are specified.