@honesty I'm glad to see an addendum is being considered. Personally, I don't believe the US regulatory environment would make the United States the best choice for a crypto bank. That being said FATCA regulations would still overshadow a foreign bank with customers in the US in most cases.

Regarding the comment about not understanding how a profit can be made, I would suggest to you that the plan you currently have outlined weighs heavily upon SBDs maintaining an annual return of 10% APR. I do not believe it adequately addresses potential negative swings of STEEM or STBs, nor how it will impact real returns of loans whose real value could be impacted by cryptocurrency swings. It does not address fees which will arise for foreign currency translations into other currencies, nor does it address costs of insuring depositor funds (unless there will be no insurance). I don't see an adequate projection of what sort of loan loss provisions need to be in place, regulatory fees, nor a host of other normal operating expenses a bank would incur (even virtual banks) which will be deducted from the bank's gross profits before any profit will be recognized.

I would suggest you may want to look into Neo & Bee and understand why that Bitcoin bank failed in Cyprus despite having the perfect environment to succeed once the EU refused to bail them out.

I wish you and your investors luck on your future endeavors.