It is worth pointing out that the conclusion and the settlement covers a time before Tether did a massive 10× growth in total circulating currency, and the reserves accounting of the latter phases are not well-established. By Tether's own (very sparse, compared to standards in the financial industry) reporting, ~75% of its reserves are "commercial paper," without any further identification of what commercial paper its holding. And if true, this would make it one of the largest holders of commercial paper, and yet no one has come forward to corroborate transacting commercial paper with Tether.

Since there's no information on what it's holding, it has fueled suspicion that a lot of the holdings are in things like cryptocurrency scam-like companies, or as another theory holds, invested in Evergrande property notes. Tether hasn't released any information that would favor or disfavor these hypotheses.