DFC

Circle's Chief Financial Officer explains the difference between stablecoin audits and attestations. An audit is an assurance engagement that verifies the accuracy of financial statements and is typically performed annually by a public accounting firm. The audit verifies the accuracy, completeness and composition of the reserve and tests the internal controls over financial reporting that ensure financial statement accuracy. In an attestation – the accounting firm “attests” to the accuracy of a set of statements. It is different from an audit (it makes little sense to test financial controls monthly, for example), but it provides the same standards of assurance over the statements.

"Created as an algorithmic stablecoin, Justin Sun’s Terra-like stablecoin USDD is now shifting gears towards a hybrid model with improved transparency. USDD is now reportedly over-collateralized with a collateral ratio of 226.1%, according to data from Tron DAO, the organization responsible for maintaining the collateral of USDD."

"In addition to a difference in asset quality, I'd argue that USD Coin and Binance USD have better legal protections for users in the event of failure. Binance USD in particular operates under the New York stablecoin regulatory framework, which obliges Binance USD's issuer, Paxos, to operate as a trust. Trusts are effective mechanisms for ring-fencing customer funds from an issuer's other creditors."

The New York State Department of Financial Services (DFS) issued new Regulatory Guidance, setting foundational criteria for USD-backed stablecoins issued by DFS-regulated entities. Such stablecoins will have to be fully backed by reserves consisting only of U.S. Treasury securities and deposits at U.S. federal or state chartered banks,  held in segregated accounts and marked to market daily. Also, redemption at par must be guaranteed for all stablecoin holders.

"The Federal Reserve Bank of Kansas City revoked the so-called master account of a payments firm that came to prominence earlier this year when Republican senators raised questions over how that account had been granted, according to a letter sent by Sen. Pat Toomey (R., Pa.). In that letter, obtained by The Wall Street Journal, Mr. Toomey asked for more details about the Kansas City Fed’s decision to terminate the account for the Colorado-based Reserve Trust. The decision to grant that account had faced scrutiny earlier this year after Mr. Toomey and other Republicans questioned Sarah Bloom Raskin, then President’s Biden nominee for a seat on the Fed’s board of governors, over her possible role in helping Reserve Trust to secure the master account when she served on its board."

MoneyGram launched its stablecoin-powered payment channel, giving users the ability to send USD Coin (USDC) payments worldwide that can be withdrawn as cash by recipients. The service is being rolled out across several key remittance markets, including Canada, the United States, Kenya and the Philippines. Global cash-out functionality will be available by the end of June. To encourage adoption, the USDC transfer service will carry zero fees for the first 12 months. The new transfer service was built on the Stellar (XLM) blockchain and allows Stellar wallet users to send USDC to recipients around the world.

"Design flaws in the no-arbitrage mechanism contributed to the failure of the IRON stablecoin. That said, the design flaws we uncover in this paper are not easily fixed. For instance, using the spot price as opposed to the ten-minute weighted-average price of TITAN in the creation of IRON is susceptible to manipulation of the spot price. It remains to be seen whether future generations of algorithmic stablecoins can improve these issues. For now, our results serve as useful reminder that some stablecoins are not stable at all, particularly for the users of smaller accounts who bought into the falling knife when IRON was tumbling."

Tether pushed back on rumors that the commercial paper held as USDT stablecoin reserves is 85% comprised of paper backed by (mostly shaky) Chinese or Asian firms. As of the most recent attestation report commercial paper made up about 25% of USDT's backing, and Tether is gradually switching maturing paper into short-maturity U.S. Treasury securities. Also, Tether's Celsius position has been liquidated with no losses to Tether, and Tether has currently zero exposure to Celsius apart from a small investment made out of Tether equity in the company.

"Stablecoins, why do they exist? What purpose do they serve? Are they a necessary evil? How do they work? Let’s explore!"

Circle, the issuer of the USD Coin (USDC) dollar-pegged stablecoin, is launching a EUR-backed stablecoin (EUROC) on June 30. EUROC will be 100% backed by euros held in euro-denominated banking accounts so that it’s always redeemable 1:1 for euros. Businesses will be able to mint EUROC straight from the source by depositing euros into their Circle Account using Silvergate’s Euro SEN network, after which it will be available to non-Circle Account users via digital asset exchanges and DeFi protocols. Additional deposit options are expected to be available later this year. EUROC will be issued as an ERC-20 token on the Ethereum blockchain, with support for additional blockchains expected later this year.

Tether will be launching Tether tokens (“GBP₮”) pegged to British Pound Sterling in July. No further details were provided, such as how and where it will be backed. It will join four other fiat-currency pegged tokens Tether has in the market: the U.S. dollar-pegged USD₮, the Euro-pegged EUR₮, the offshore Chinese Yuan-pegged CNH₮, and MXN₮, the Mexican Peso-pegged stablecoin.

ANZ customer Victor Smorgon Group successfully purchased tokenized Australian carbon credits (BCAU) using the ANZ-issued stablecoin A$DC. This transaction is an important step for ANZ as the bank explores greater circulation of the stablecoin. In this transaction, Victor Smorgon Group used A$DC as a medium of exchange to purchase the BCAU carbon tokens from Zerocap, an Australian crypto asset investment platform.

The Basel Committee on Banking Supervision has published a second public consultation on the prudential treatment of banks' crypto-asset exposures. It builds on the preliminary proposals set out in the June 2021 consultation and the responses received from stakeholders. The basic structure of the proposal in the first consultation is maintained, with crypto-assets divided into two broad groups; Group 1 including those eligible for treatment under the existing Basel Framework with some modifications, and Group 2 including unbacked crypto-asset and stablecoins with ineffective stabilization mechanisms,  which would be subject to a new conservative prudential treatment including an overall gross limit on such holdings. The updated proposals provide more detail on the proposed standard and include new elements such as an infrastructure risk add-on to cover the new and evolving risks of distributed ledger technologies.

The Basel Committee on Banking Supervision suggested during its second consultation on the prudential treatment of crypto-asset exposures that banks limit their exposure to so-called Group 2 crypto assets to just 1% of their Tier 1 capital. Group 2 digital assets include major non-stablecoin, non-tokenized cryptocurrencies like Bitcoin and most altcoins. Therefore, banks would only be able to commit 1% of their total equity or net asset value in either long or short positions toward Group 2 digital assets. Moreover, the Basel Committee is considering banks adopting a 1,250% risk premium for Group 2 digital assets. In comparison, stocks typically have a 20% to 150% risk premium attached to their nominal values, depending on the company's credit rating. Under Basel III, a bank's risk-weighted assets must not surpass 10.5% of its Tier 1 capital for prudent leverage.

Coinbase announced that the platform will be “unifying USD and USDC order books,” adding that “USDC order books will be merged under USD order books to create a better, more seamless trading experience with deeper liquidity for USD and USDC.” USDC (aka USD Coin) is the stablecoin issued by Centre, a consortium of Circle and Coinbase. This may provide a ‘more seamless’ experience, but it also gets Coinbase out of a potential fiat liquidity crunch, in the wake of massive customer USD withdrawals during the current crypto crash.

"To fully qualify as a lower risk stablecoin, the price cannot go below 99.9 cents on more than three days in 12 months. A stablecoin outright fails the test if it drops below 99.8 cents more than ten times during a year. We assume this is at any point during the day, but that’s unclear. Using data from Messari, USDC, considered higher quality than Tether, would have failed both tests intraday every day during the past month. Tether managed to pass on six out of 30 days. However, at ‘close’ USDC would have failed the first test just four times compared to 16 times for Tether. But extrapolating to a year, that’s enough for both to be classed as a pure cryptocurrencies."

Tether announced further progress towards reducing its commercial paper portfolio. As of July 1, Tether had 8.4 billion of these holdings, of which 5 billion will expire on July 31. The goal remains to bring commercial paper holdings down to zero, switching them into short-term U.S. Treasury securities.

"Many questions are yet to be answered and many avenues to be explored as part of the financial landscape’s digital revolution. But stablecoin insurance could provide a boost of confidence as more and more regular consumers take part in the blooming digital currency market."

FDIC insurance only protects customers in the event of the insolvency of the bank holding the deposits. That leaves open the question of where stablecoin holders rank in the event of the stablecoin issuer's insolvency. This was recently discussed in a Twitter thread launched by JP Koning to which George Selgin and Dan Awry contributed. According to my read of the thread, which focused specifically on the Circle-issued USDC stablecoin, the answer seems to be "maybe" but the question could be tied up in courts for a long time.

This article from the Richmond Fed dives into potential answers to these questions about the failed Terra UST stablecoin. UST was backed by LUNA, but the price of LUNA was backed by its option value of converting to UST. When the confidence of this circular backing is shaken, the liquidity of algorithmic stablecoin becomes flighty. In this case, the algorithm does not fully function because Terra needs to (but can't always) defend both UST and LUNA. When market liquidity evaporated, UST and LUNA ultimately relied on the issuer's equity to support the prices, similar to the backing of a more traditional currency as seen in the Asian Financial Crisis. It is the part of economics cannot be replaced by technology.

Paxos will now disclose on a monthly basis the specific financial instruments backing its USDP and BUSD stablecoins, in addition to its attestations. These reports will provide the CUSIP numbers of all instruments backing USDP and BUSD, showing that Paxos only backs its stablecoins with cash, overnight loans secured only by US Treasuries, and US Treasuries with a less than 90 day maturity. As a Trust Company chartered by the New York State Department of Financial Services (“NYDFS”), Paxos is legally required to hold all regulated stablecoin reserves in bankruptcy remote, fully-segregated accounts and in only cash and cash equivalents.

Matt Taibbi asks some tough questions about the sanctity of the reserve assets that back Circles USDC stablecoin, and the issue of bankruptcy remoteness. Circle is unlike some competitors, whose user agreements specifically spell out that reserves are, say, “fully backed by US dollars held by Paxos Trust Company, LLC,” or “custodied pursuant to the Custody Agreement entered into by and between you and Gemini Trust Company, LLC.” Those describe trust agreements, which are truly bankruptcy remote. However, Circle is not a trust, so customers  are guarded only by protections afforded under state money transmission laws. However, Circle is only regulated  as a money transmitter in the states where Circle has licenses, and the firm has obtained licenses only in those states were licenses are required. There are other reasons to be concerned as a USDC hodler, and I recommend reading the whole post.

"The same question could be directed at other well-known money transmitters like PayPal, Square, and Western Union... and my guess is that their answers would be equally unclear."

The Financial Stability Board (FSB) announced that it will submit to the October meeting of G20 finance ministers and central bank governors a public consultation report on its review of its high-level recommendations for the regulation, supervision and oversight of “global stablecoin” arrangements, including how existing frameworks may be extended to close gaps and implement the high-level recommendations. The FSB will also submit a public consultation report that proposes recommendations for promoting international consistency of regulatory and supervisory approaches to other crypto-assets and crypto-asset markets and strengthening international cooperation and coordination.

The Committee on Payments and Market Infrastructures (CPMI) and International Organization of Securities Commissions (IOSCO) published their final “same risk, same regulation” guidance on regulating stablecoin arrangements (SAs). The guidance highlights that the transfer function of an SA is comparable to the transfer function performed by other types of financial market infrastructure (FMI). As a result, an SA that performs this transfer function is considered an FMI for the purpose of applying the Principles for Financial Market Infrastructures (PFMI) and, if determined by relevant authorities to be systemically important, the SA as a whole would be expected to observe all relevant principles in the PFMI.

Circle Internet Financial released a detailed – though unaudited – breakdown of its reserve assets for the firm’s USD coin (USDC) that showed $42.1 billion in short-term U.S. government bonds and $13.6 billion in cash. The breakdown also listed the bonds’ individual CUSIP number identifiers. The cash was comprised of deposits at Bank of New York Mellon, Citizens Trust Bank, Customers Bank, New York Community Bank, Signature Bank, Silicon Valley Bank, Silvergate Bank and US Bancorp.

This European Central Bank (ECB) article analyses the role played by stablecoins for everyday payments. Transaction speeds differ by blockchain but are slow for stablecoins issued on the predominant blockchain. As an example, during testing for a central bank digital currency, the Federal Reserve Bank of Boston showed that a non-blockchain payment technology can perform ten times more transactions per second than a high-performance blockchain technology. Transaction costs of stablecoins vary depending on a number of factors, such as the complexity of a transaction or the congestion of the network, leading to higher fees. Analysis of stablecoin transaction fees by Mizrach (2022) shows that, for a large portion of stablecoins, the transaction costs are higher than those of ATM transactions or the average costs of Visa or Mastercard schemes in Europe.