Last month the Biden administration issued an executive order outlining some priorities and aspirational goals regarding government initiatives and future regulations regarding cryptocurrencies.
These goals may be summarized as:
1. Protect Investors in the Crypto Space
2. Mitigate Systemic Risks from Innovations
3. Provide Equitable Access to Affordable Financial Services
4. Ensure Responsible Development of Digital Assets
5. Limit Illicit Use of Digital Assets
6. Research Design Options of a U.S. Central Bank Digital Currency (CBDC)
7. Promote U.S. Leadership in Technology
These positions seem generally reasonable and moderate, and were welcomed by the cryptocurrency community, which had feared a more restrictive stance. (China, for instance, has banned cryptocurrency use altogether).
Why Fear Stablecoins?
Here I’d like to focus on #2, “Mitigate Systemic Risks from Innovations”. Although so-called stablecoins are not explicitly mentioned in the executive order, it is understood that they represent a key area of concern for regulators.
A stablecoin typically has its value pegged 1:1 to a leading national or international currency such as the U.S. dollar or the euro, or to some commodity like gold, or even to other cryptocurrencies. In practice, most of them have generally held pretty well to their pegs. So what’s not to like about them? Why would they be perceived as more of a threat that, say, bitcoin, whose dollar value is all over the map?
I think the reason is that market participants count on them maintaining their (say) dollar peg. These coins are used as dollar substitutes in billions of dollars’ worth of transactions and are depended on to hold their value.The total value of stablecoins in use is nearly $200 billion and is growing fast. If a major stablecoin crashed somehow, it could lead to significant instability, which regulators don’t like.
Four Major Types of Stablecoins
Stablecoins may be classified according to how their “tether” is maintained:
( 1 ) Pegged to fiat currency, maintained by a central stablecoin issuer
The biggest U.S.-based stablecoin is USD Coin (USDC), which is backed by significant financial institutions. There is every reason to believe that there is in fact a dollar backing each USDC. Gemini Dollar (GUSD) is smaller, but also takes great pains to garner trust. Its issuer, Gemini, operates under the regulatory oversight of the New York State Department of Financial Services (NYDFS). It boasts, “The Gemini Dollar is fully backed at a one-to-one ratio with the U.S. dollar. The number of Gemini dollar tokens in circulation is equal to the number of U.S. dollars held at a bank in the United States, and the system is insured with pass-through FDIC deposit insurance as a preventative measure against money laundering, theft, and other illicit activities.”
So far, so good. The huge stinking elephant in the room here is a stablecoin called Tether. Tether is the largest stablecoin by market capitalization (at $79 billion), and is heavily used as a dollar substitute, mainly in Asia. It has been widely criticized as a shady, unaudited operation, operating from shifting off-shore locations to avoid regulation (and prosecution). There are justified doubts as to whether the claimed 1:1 dollar backing for Tether is really there. Tether sort-of disclosed its backing reserves in the form of a sparse pie-chart. Very little was in the form of cash or even “fiduciary deposits”. Some was in the form of “loans” to who-knows-what counterparties. The majority of their holdings were “commercial paper”; but nobody can find any trace of Tether-related commercial paper in the whole rest of the financial universe (it has become a sort of game for financial journalists to try to the be first one to actually locate any legitimate Tether assets).
So, Tether by itself may justify concern on the part of regulators. Also, without diving too deeply into it, a plethora of financial institutions and tech companies are starting to issue their own stablecoins, which again are purported to be as good as cash, and so are vulnerable to abuse.
( 2 ) Stablecoins backed by commodities
Tether Gold (XAUT) and Paxos Gold (PAXG) are two of the most liquid gold-backed stablecoins. Other coins are tied to things like oil or real estate. The holder of these coins is depending the coins issuer to actually have the claimed backing.
( 3 ) Cryptocurrency Collateral (On-Chain)
It is hard to explain in a few words how this type of coin works. A key point here is that your stablecoins are backed by other, leading cryptocurrecies (such as Ethereum), with the process all happening on the decentralized blockchainvia smart contracts. A leading coin here is DAI, an algorithmic stablecoin issued by MakerDAO, that seeks to maintain a ratio of one-to-one with the U.S. dollar. It is primarily used as a means of lending and borrowing crypto assets without the need for an intermediary — creating a permissionless system with transparency and minimal restrictions.
Unlike with the two types of stablecoins discussed above, you are not dependent on the honesty of some central issuer of the stablecoin. On the other hand, Wikipedia notes:
The technical implementation of this type of stablecoins is more complex and varied than that of the fiat-collateralized kind which introduces a greater risks of exploits due to bugs in the smart contract code. With the tethering done on-chain, it is not subject to third-party regulation creating a decentralized solution. The potentially problematic aspect of this type of stablecoins is the change in value of the collateral and the reliance on supplementary instruments. The complexity and non-direct backing of the stablecoin may deter usage, as it may be difficult to comprehend how the price is actually ensured. Due to the nature of the highly volatile and convergent cryptocurrency market, a very large collateral must also be maintained to ensure the stability.
( 4 ) Non-Collateralized Algorithmic Stablecoins
The price stability of such a coin results from the use of specialized algorithms and smart contracts that manage the supply of tokens in circulation, similar to a central bank’s approach to printing and destroying currency. These are a less popular form of stablecoin. The algorithmic coin FEI proved unstable upon launch, although it has since achieved an approximate parity with the dollar.
Stablecoins are a big and fast-growing piece of practical finance.
These coins bring a different kind of risk, because (unlike Bitcoin or Ethereum), users depend on them holding a certain value.
For the coins backed by major fiat currencies or commodities, risk is introduced by the need to depend on the honesty and competence of the centralized coin issuers.
For the non-centralized stablecoins like DAI and FEI, there are risks associated with proper automatic functioning of their protocols.
One can understand, therefore, the urge of the federal government to impose regulations in this area. That said, it does not seem to me that the existing system is broken such that the feds need to come in to fix it in a major way. The main shady actor in all this is Tether, which everyone knows to be shady, so caveat emptor (and the vast majority of Tether transactions occur outside the West, in the East Asian shadowlands).