Not so sure. The authorities are in charge of determining the bank reserve requirements. The fact that they allowed zero reserves at these institutions is troubling and deserves to be discussed. This is like the Free Banking Era, except back then the States were in charge of enforcing reserve requirements.

If you search online for the Fed's own explanation for these policies, they make some overconfident assertions about "ample reserves" and how their policy assumes there are now "ample" reserves, so they can just set the reserve requirements at zero. Seems to me some political doublespeak in order to provide the unprecedented level of Keynesian stimulus that was planned to be released.