Have you ever seen a MSB offer Euros, Yen, or Dollars in random amounts as a product? Does not seem like the actions you list are similar at all to this situation.

I think this list of ETN/ETFs behave pretty similarly: https://money.usnews.com/funds/etfs/rankings/multicurrency

Based off that list are you saying companies like T. Rowe Price and Citigroup are offering ETNs and ETFs that have fund compositions that are random for each customer?

Obviously the value proposition is a little bit different but it seems close enough to rhyme. T. Rowe Price and Citigroup aren't saying "the best part about these funds is that you have no idea whats in them!" but in practice these funds behave similarly to the crypto flash drives.

I don't think that the etfs disclose which assets are held on any given day. From the consumers perspective they are buying some mix of currencies, although they don't know exactly which ones. It seems pretty random to me, just not different from the other note holders.

How about a fruit basket? I buy that without knowledge of what I am getting. But I think the sellers have badly communicated what they are selling. I don't think random applies to the amount. I think they might mean to say a collection of a bunch of currencies, funded with whatever amount it takes to get you in to that currency. There isn't really a way to know until they get a product page up.

So now you are comparing global mediums of exchange to fruit? Before you go too far maybe consider why we have FinCEN, FDIC, FTC, SEC, etc.