This is an interesting point. Could've placed EPB in Miami and it still would've been non-CRS. At the time, FATCA reciprocity was basically non-existent.If you don't trust PR and you say PR is bankrupt why did you relocate the bank to PR and not to US mainland or another Caribbean Island? Because the PR licence was easy and cheap for you and PR is NON- CRS!
It would've required complying with state and federal banking regulations, though, and increased costs.
This horse is already dead, though. Beating it further does nothing. The liquidation will take the time it takes, which unfortunately seems to be many years still.