I think its unlikely that any agency in the review

I think its unlikely that any agency in the reviewing and approving business would consider the Citibank thing to be a test or a trial. I haven’t seen anything to suggest it has any of the controls in place necessary to have any scientific legitimacy. It’s not worthless because it means something to laypeople and has PR value (which explains the repeated references to it on this board), but I doubt it can serve as the basis for agency approval.