"Because of Tether’s inability to conduct significant banking activity during this time, it could not itself hold dollars sufficient to back the hundreds of millions of new tethers that had entered the market."

The word "itself" is doing heavy duty in this sentence. Was there another entity holding dollars in this period? Did Tether issue USDT without a corresponding inflow of USD? We don't know. One would hope that the transparency agreement actually answers these questions for its future operations. It's those questions that matter, after all, not Ms. Letitia James' "efforts".