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BUSD is a security?

I was not entirely surprised to see BNB as an unregistered security — lots of reasons why! — but BUSD is theoretically at least a stablecoin. And yet:

From September 2019 through February 2023, Binance offered and sold BUSD to U.S. investors as part of a profit-earning scheme within the Binance ecosystem, touting returns for investors from simply buying BUSD or deploying it in Binance profit-generating programs.

Since its inception, BUSD has been offered and sold as an investment contract and, therefore, as a security.

Uh oh, Paxos!