Levine says anyone can be a member bank

The overhead involved in serving a retail customer base would be higher than if TNB served a purely institutional clientele, notes Levine: "you’d need at least a website, a customer service department, ATM cards—but the opportunity is intriguing."

The stuff you need is cheap, cheap enough that any customer could afford it.  

So, Matt, let's extend.  If its that cheap, and I pay for it, and I pay my proportional Fed fee and obey the reserve rules, then I can be my own member bank.    If the Fed loses the suit, then this is the likely outcome.

The accounts are ledgered by the trusted miner, so this is all pure bearer notes.

All the sandbox stuff is coming to a conclusion in 2018, the year of singularity 1.0.