Stablecoin backing

… is a hot topic full of claims, counter claims and clarifications. Tether’s USDT token has been getting the bulk of the attention to date but questions are now being asked about Circle’s USDC token (a cryptographic stored value token or stablecoin that allows users to trade crypto assets).

My understanding is that USDC is one of the better (in relative terms) stable coins regarding backing and disclosure but this analysis from Amy Castor argues that is still not especially good and may be getting worse. The Financial Times makes a similar argument.

The broad problem they outline

  • Stablecoins generally start out with a promise that each coin is backed 1:1 with fiat currency (typically USD) or fully reserved
  • Ideally those fiat currency reserves are held on deposit in a bank on a custodial basis
  • Over time that simple promise becomes more nuanced with qualifications that dilute the fiat currency component and introduce concepts like “approved investments”
  • The location of the deposit may also become ambiguous
  • Not always clear if the backing itself has evolved or the disclosure evolves in response to questioning

USDT has been the most high profile example of asset backing being understood to be USD cash but evolving into something USD based but not always 100% cash or necessarily liquid. The two sources cited above suggest that USDC backing may also be less than 100% USD.

Amy Castor points to the change in USDC disclosure between February and March 2021 as evidence of an apparent change in (or clarification of?) the composition of the reserve backing.

Source: Amy Castor, “What’s backing Circle’s 25B USDC? We may never know”

As always I may be missing something, and maybe this is just my traditional banking bias, but Amy poses what seem to me to be pretty reasonable questions like “what are those approved investments? Who approves them? What percentage of assets are in that category?” that Circle is yet to answer.

Tony – From The Outside

The meltdown of IRON

Kudos to “Irony Holder” for a great title to an equally interesting post exploring what went wrong with the IRON stablecoin. My last post “A bank run in CryptoLand” flagged a short summary of the demise of IRON in Matt Levine’s Money Stuff column in Bloomberg and Matt’s latest column put me onto Irony Holder for a more detailed account of what went wrong. I suspect that I will be returning to the stablecoin topic many times before I am done.

One of the challenges in banking and finance is figuring our what is “new and useful” versus what is simply a “new way of repeating past mistakes” and stablecoins offer a rich palette for exploring this question. I remain open to the possibility that stablecoins will produce something more than a useful tool for managing trading in cryptoassets. The potential to make low value international payments cheaper and faster seems like one of the obvious places where the existing financial system could be improved on.

However, it seems equally likely that stablecoin innovation will repeat mistakes of the past so these post mortems are always useful. I recommend reading Irony Holder’s account in full (especially for the code error in the smart contract) but this is what I took away:

  • Part of the problem with IRON seems to be that the developers prioritised “efficiency”. In my experience the pursuit of efficiency has an unfortunate tendency to result in systems that are neither robust nor resilient – two highly desirable qualities in anything that facilitates the transfer of value. That observation (“efficient is rarely if ever resilient”) is of course based on the hard lesson that the conventional financial system learned from way it operated in the lead up to the Global Finance Crisis.
  • Algorithmic stablecoins like IRON appear to down play, or avoid completely, the need for high quality collateral. Experience in the conventional financial system suggests that collateral (ideally lots of it) is a feature of robust and resilient payment systems.
  • Yield farming around the IRON-USDC pair was producing extraordinary returns. High returns are a feature of the crypto asset world but maybe high returns on a stablecoin should have been a red flag?

I have over four decades of experience in the conventional financial system but I am a “noob” in this space (crypto-DeFi-digital) so the observations above should be read with that caveat in mind. It also important to remember that the issues above do not necessarily extend to other types of stablecoin. My understanding is that the algorithmic approach has not achieved as much traction as fiat and crypto collateralised approaches.

Hopefully you find the links (and summary) useful but also tell me what I am missing.

Tony – From the Outside

A bank run in CryptoLand

In my last post I flagged a great article from Marc Rubinstein using MakerDAO to explain some of the principles of Decentralised Finance (DeFi). One of the points I found especially interesting was the parallels that Rubinstein noted between 21st century DeFi and the free banking systems that evolved during the 18th and 19th centuries

I wound up confessing that while I am a long way from claiming any real DeFi expertise, I did believe that it would be useful to reflect on why free banking is no longer the way the conventional banking system operates.

In that spirit, it appears that the IRON stablecoin has the honour of recording the first bank run in cryptoland.

We never thought it would happen, but it just did. We just experienced the world’s first large-scale crypto bank run.

No doubt there will be plenty written on this but Matt Levine’s Bloomberg column offers a quick summary of what happened.

The core of an algorithmic stablecoin is that you have some other token that is not meant to be stable, but that is meant to support the stablecoin by being arbitrarily issuable. It doesn’t matter if Titanium is worth $65 or $0.65, as long as you can always issue a few million dollars’ worth of it. But you can’t, not always, and that does matter.

Money Stuff by Matt Levine 18 June 2021

Algorithmic is of course just one approach to stablecoin mechanics. I hope to do a deeper dive into stablecoins in a future post.

Tony – From the Outside

Money and banking in CryptoLand

Marc Rubinstein (Net Interest) recently wrote an interesting post titled “My Adventures in CryptoLand” that I found very helpful in helping me better understand what is going on in this new area of decentralised finance (DeFi). He has followed up with a post titled “Reinventing the Financial System” which explores how MakerDAO is building a “decentralised bank”. I am a bit uncomfortable with applying the term “bank” to the financial entity that MakerDAO is building but I don’t want to derail the discussion with what may be perceived as semantics so I will run wth the term for the purposes of this post.

What is interesting for students of banking is the parallels that Rubinstein notes between MakerDAO and the free banking systems that evolved during the 18th and 19th centuries. Scotland is one of the poster children of this style of banking and we can see a legacy of that system (albeit much more regulated and so not true free banking) in the form of the private bank notes that the three Scottish banks still issue in their own name. He quotes Rune Christensen (founder of MakerDAO) describing the way in which his project accidentally developed a form of fractional reserve banking”

In the very beginning of the project, I remember we didn’t even realise, in the beginning of Maker, that we were essentially just building a protocol that did the same things as fractional reserve banking, did something very similar to how a banking balance sheet works and we were just implementing that as a blockchain protocol. We thought we were doing something completely, totally different from how money usually worked in the traditional sense.” (source)

“Reinventing the Financial System” Marc Rubinstein Net Interest Newsletter, 12 June 2021

This statement should be qualified by the fact that they can only do this (i.e. replicate fractional reserve banking) because the currency of the decentralised bank is a form of money called Dai. Fractional Reserve Banking has proved to be a risky form of financial technology in the conventional banking system which has developed a range of tools to manage that risk (e.g. capital adequacy and liquidity requirements, deposit preference arrangements often coupled with deposit insurance to insulate the “money” part of the bank balance sheet from risk, high levels of supervision and other restrictions on the types of assets a bank can lend against).

MakerDAO has a stabilisation mechanism that employs “smart contracts” that manage the price of Dai by managing its supply and demand. The pros and cons of the various stabilisation mechanisms that underpin stable coins like Dai is a topic for another day.

Rubinstein describes the MakerDAO lending and “money” creation process as follows:

The bank he devised to create his money … works like this:

An investor comes into Maker DAO for a loan. He (yep, usually he) has some collateral he’s happy to keep locked in a vault. Right now, that collateral is usually a crypto asset like Ethereum. For every $100 worth of crypto assets, Maker is typically prepared to lend $66 – the gap adding a buffer of protection against a possible fall in the value of the collateral. Maker accepts the collateral and advances a loan, which it does by issuing its Dai money. 

So what?

At this stage I am not sure where this is headed. It is not clear, for example, if the purpose of this “bank” is simply to create more Dai via trading in crypto-assets or to build something that translate outside CryptoLand. Rubinstein quotes Rune Christensen himself stating that

I don’t think that it will necessarily replace everything… The traditional financial system will actually largely remain the way it is. It will just replace certain parts of it that right now are really bad and really old… those things will be replaced with DeFi and blockchain, but the actual bank itself probably will remain.”

I am a long way from figuring this out but Marc’s post is I think worth reading for anyone who want to understand where these new (or possibly reinvented) forms of finance are heading. To the extent that DeFi is reinventing things that have been tried before, I suspect it would be useful to reflect on why free banking is no longer the way the conventional banking system operates. That is another topic for another day.

Tony – From the Outside

The Basle Committee consults on bank cryptoasset exposures

The Basel Committee on Banking Supervision (BCBS) yesterday (10 June 2021) released a consultative document setting out preliminary proposals for the prudential (i.e. capital adequacy) treatment of banks’ cryptoasset exposures. A report I read in the financial press suggested that Basel was applying tough capital requirements to all cryptoassets but when you look at the actual proposals that is not correct (credit to Matt Levine at Bloomberg for picking up on the detail).

The BCBS is actually proposing to split cryptoassets into two broad groups:

  • one which looks through the Crypto/DLT packaging and (largely) applies the existing Basel requirements to the underlying assets with some modifications; and
  • another (including Bitcoin) which is subject to the new conservative prudential treatment you may have read about.
The proposed prudential treatment is based around three general principles
  • Same risk, same activity, same treatment: While the the BCBS does see the “potential” for the growth of cryptoassets “to raise financial stability concerns and increase risks face by banks”, it is attempting to chart a path that is agnostic on the use of specific technologies related to cryptoassets while accounting for any additional risks arising from cryptoasset exposures relative to traditional assets.  
  • Simplicity: Given that cryptoassets are currently a relatively small asset class for banks, the BCBS proposes to start with a simple and cautious treatment that could, in principle, be revisited in the future depending on the evolution of cryptoassets. 
  • Minimum standards: Jurisdictions may apply additional and/or more conservative measures if they deem it desirable including outright prohibitions on their banks from having any exposures to cryptoassets. 
The key element of the proposals is a set of classification conditions used to identify the Group 1 Cryptoassets

In order to qualify for the “equivalent risk-based” capital requirements, a crypto asset must meet ALL of the conditions set out below:

  1. The crypto asset either is a tokenised traditional asset or has a stabilisation mechanism that is effective at all times in linking its value to an underlying traditional asset or a pool of traditional asset
  2. All rights obligations and interests arising from crypto asset arrangements that meet the condition above are clearly defined and legally enforceable in jurisdictions where the asset is issued and redeemed. In addition, the applicable legal framework(s) ensure(s) settlement finality.
  3. The functions of the crypotasset and the network on which it operates, including the distributed ledger or similar technology on which it is based, are designed and operated to sufficiently mitigate and manage any material risks.
  4. Entities that execute redemptions, transfers, or settlement finally of the crypto asset are regulated and supervised

Group 1 is further broken down to distinguish “tokenised traditional assets” (Group 1a) and “crypto assets with effective stabilisation mechanisms” (Group 1b). Capital requirements applied to Group 1a are “at least equivalent to those of traditional assets” while Group 1b will be subject to “new guidance of current rules” that is intended to “capture the risks relating to stabilisation mechanisms”. In both cases (Group 1a and 1b), the BCBS reserves the right to apply further “capital add-ons”.

Crypto assets that fail to meet ANY of the conditions above will be classified as Group 2 crypto assets and subject to 1250% risk weight applied to the maximum of long and short positions. Table 1 (page 3) in the BCBS document offers an overview of the new treatment.

Some in the crypto community may not care what the BCBS thinks or proposes given their vision is to create an alternate financial system as far away as possible from the conventional centralised financial system. It remains to be seen how that works out.

There are other paths that may seek to coexist and even co-operate with the traditional financial system. There is also of course the possibility that governments will seek to regulate any parts of the new financial system once they become large enough to impact the economy, consumers and/or investors.

I have no insights on how these scenarios play out but the stance being adopted by the BCBS is part of the puzzle. The fact that the BCBS are clearly staking out parts of the crypto world they want banks to avoid is unremarkable. What is interesting is the extent to which they are open to overlap and engagement with this latest front in the long history of financial innovation.

Very possible that I am missing something here so let me know what it is …

Tony – From the Outside

JP Koning – What Tether Means When It Says It’s ‘Regulated’ – CoinDesk

Useful article on Coindesk discussing what underpins the integrity of one of the more popular forms of Stabecoins

“Newcomers to the crypto space are quickly confronted with a popular distinction between regulated stablecoins and unregulated stablecoins. But what is the difference? Tether, the largest of the stablecoins, is often described as unregulated. But Tether executives and supporters disagree with this claim. Who is right?”
— Read on

I don’t profess any real insight or expertise in this space but it does feel to me like a question that any serious student of banking needs to come to terms with.

Tony – From the Outside