1/ SOME THOUGHTS on #stablecoins & the #crypto selloff, which are probably connected.

HUGE news last week & it matters far more than @elonmusk or @binance news. A long thread 👇:
2/ First, #Tether finally disclosed how it invests reserves & it was a big negative surprise (not previously knowable at this level of detail). This news probably contributed a lot to #crypto selloff since Wednesday.
3/ Why? Because now risk managers at #crypto hedge funds almost certainly will require haircuts on #Tether, which means traders had to sell #crypto to reduce their total risk exposure.
4/ Example: if risk managers now apply a 5-10% haircut for #Tether & Tether is in a trader’s portfolio, the trader must bring down total exposure by selling other non-Tether #crypto.
5/ Based on Tether’s new disclosure, both #Tether’s probability of default & loss severity in default just went up. Why? Because CREDIT RISK.
6/ There’s now much bigger risk that #Tether may “break the buck” (trade below par to the US dollar) amid a credit market correction. This would prob bring #crypto markets lower with it if (when) that happens. (#DeFi protocols that already haircut Tether were proven right.)
7/ Markets already had independent confirmation that #Tether had very little bank deposits in its reserves, but now we know its reserves are mostly invested in CREDIT ASSETS of who-knows-what quality, not T-bills or other short-term, lower-risk, liquid securities.
8/ Tether's reserve portfolio looks like a credit hedge fund, with some interest rate risk (corporate bonds) & commodities risk thrown in too. Need LOTS more disclosure now. So many new questions.
9/ Big ? is WHY?? Why choose to take so much risk w/ users’ reserves? Tether's reserve issues used to be partly explainable (banking access) but Tether clearly has securities access now. Doing this was a CHOICE.

#Tether is an IMPORTANT pymt technology. Why add more controversy??
10/ Plus, if #Tether stays a de facto credit hedge fund by investing reserves this way, markets now can safely predict that #bitcoin & #crypto prices will likely exhibit high correlation w/ credit markets. They will probably correct together.
11/ I’ve always been challenged by the biz model of some #stablecoin issuers: the ones that keep the float, and especially the ones that use the float as a hedge fund "plaything." BUT RESERVES ARE USERS’ MONEY!!!
12/ That biz model is “heads the #stablecoin issuer wins, tails the stablecoin users lose.”

As Warren Buffett likes to say: when tide goes out you see who’s swimming naked.
13/ #Wyoming law rejects such a biz model. This is why Wyoming law requires #SPDI banks to hold 100% reserves of customer deposits in cash, T-bills etc.
14/ Here’s some math for #Tether’s $58.2bn of reserves. A conservative assumption is that Tether’s reserve portfolio yields at least 1%. That’s $582m of annualized profits(!) going to Tether's issuer.
15/ I can only guess how US regulators reacted to Tether’s announcement. Tread carefully, peeps. I’ve thought for a while that a #stablecoin crackdown is inevitable. Will this trigger it? Dunno
16/ But if/when a crackdown happens, I’ll be shaking my head because some of the fallout will have been ENTIRELY AVOIDABLE had #Tether just invested the reserves in T-bills, for example.

One of basic tenet of US financial regulation is DISCLOSURE of risks.
17/ I regularly defend #Tether (and will continue to) as very important technology and key industry infrastructure as a bridge to the US dollar, and have relationships w/ some of its team going back years.
18/ But I can’t defend #Tether’s choices on asset allocation & making no risk disclosure. What a missed opportunity! SMH. Not helpful to our industry.
19/ Like it or not, one of the best things for industry at present would be getting #stablecoins to be OK w/ US regulators (esp the Fed & the SEC). #stablecoins are very important bridges between #crypto & the US dollar.
20/ Why? bc EVERY US dollar must clear thru a bank & then the Fed. Like it or not US regulators have big power over #stablecoins.

Yep, @AvantiBT plans to help here (when open). Other #SPDIs may do so too--as industry "utilities" to hold #stablecoin reserves on behalf of issuers
21/ #Wyoming #SPDIs by law can’t play shenanigans with reserves backing #stablecoins because SPDIs can’t take risk w/ customer deposits. User money is not an SPDI’s plaything!!
22/ Markets will probably soon have an opportunity to vote w/ their feet & I suspect money will move to #SPDIs, which should become reserve manager "utilities" for the #stablecoin industry.
23/ Folks, balance sheets matter & it's not just whether reserves are 100% or not--it's also RISKS in those reserves (eg, credit, interest rate & other kinds).
#Wyoming #SPDIs were designed as solvency play & this is equally true for #crypto custody as for #stablecoin reserves.
24/ Speaking of regulators, something pretty big happened this week & it got only little attention: a US bank announced it will issue a #stablecoin.
25/ Facebook announced a pilot for #Diem w/ @Silvergate, where Silvergate will be the issuer & Diem will operate its #smartcontract.
26/ It’s a pilot but it’s significant bc #Diem would be a bank-issued #stablecoin. OK OK, yes yes yes there will be @Facebook blowback (probably lots of that). But it’s BANK-issued.
27/ I have a question tho: how well will it work when the #stablecoin issuer is a different legal entity than the operator of the #smartcontract? I can think of MANY risks w/ that.
28/ Hey #smartcontract developers--can you think of another example where a token issuer is separate from the smart contract manager? Pls reply & discuss the risks.
29/ Another question: Will the “rent-a-bank-charter” model used by #fintech lenders will become a “rent-a-bank-charter” model for #stablecoin issuers?
30/ P.S.--there was a big fight in Congress over the “rent-a-bank-charter” model used by #fintech lenders last wk. Guess who swing vote was: @SenLummis.🤠
31/ Here are 10 predictions about #stablecoins (from a speech just released by @CatoInstitute that I gave last Nov): cato.org/cato-journal/s…
32/ The speech is 6 months old but pls read parts about #stablecoins inside the US banking system. It’s happening. THAT is signal thru all the Elon & Binance noise.
33/ And that’s a very big deal. Like it or not, #stablecoins are important bridges btwn US dollars & #bitcoin, #ether, #DeFi & the rest of #crypto.
34/ Someday #stablecoins will be irrelevant, but today they matter a lot. Again--like it or not, US regulators control what touches US banks--yep, including all USD stablecoins.
35/ P.S.--seems cute that 6 months ago I’d predicted only $100bn of USD #stablecoins outstanding by year-end. Ha! 🤣Missed that by a mile. Probably will hit that amount by July, if no crackdown before then
36/ Enjoy the speech. It’s a little light reading for the weekend. Happy Saturday! 🤠

-END-
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More from @CaitlinLong_

21 Apr
AND IT’S OFFICIAL!! 🤠#Wyoming will recognize #DAOs as a new type of LLC, effective July 1! Thank you legislators & @GovernorGordon for building on Wyoming’s history of inventing the LLC, which all other states followed roughly a decade later. We’re doing it again! A thread👇. 1/
What problem does #Wyoming’s #DAO law solve? It’s the prob of joint-&-several liability for all participants in a DAO, if the DAO were ever deemed by a court to be a general partnership 😱New law handles this by applying LLC liab protections to DAOs that meet the requirements. 2/
KEY is that, unlike regular LLCs, #Wyoming Secretary of State can yank the liability protection from a DAO that commits fraud or engages illegal activities (unlike with a regular LLC). So, only use this law for valid projects & get counsel—it won’t be useful for invalid ones. 3/
Read 7 tweets
26 Mar
1/ SOME THOUGHTS on the Texas #blockchain bills. Lots of good stuff here!! But Texans have more work to do. I hope sharing these thoughts helps you!

First, IT'S AWESOME that Texas is likely to become 2nd state to treat #bitcoin the same as money under US commercial law. 🚀💥🤠
2/ This is AWESOME & is LONG overdue. For lawyers out there Texas is proposing to apply the UCC "take free" rules, which means innocent purchasers of #bitcoin & other virtual currencies take free of any adverse claims as long as they didn't defraud the seller. THIS IS A BIG DEAL!
3/ It's same as the in-process proposal of @uniformlaws. Texas is jumping out ahead to adopt it early. I've been an observer of Uniform Law Commission process & it has made great strides to get to where it is--namely that #control of a virtual currency is the determining factor.
Read 16 tweets
2 Mar
1/ QUESTION for #DeFi experts--has anyone seen analysis of DeFi projects under Misesian distinction of **commodity credit** vs **circulation credit**?

Here's where I'm going: if all debt in the DeFi system is commodity credit, then system is solvent & yield is coming from vol.
2/ But if some debt in the system represents circulation credit, then system is fundamentally not solvent at the systemic level--so that at least some of the yield is coming from counterparty risk, & then the question becomes "how do you quantify the credit risk in the system?"
3/ In other words, yield can be broken into 2 components: risk-free nominal yield + a credit spread. If all debt in the #DeFi project is commodity credit, then system is solvent (ie, all debt backed by someone else's equity)--so in theory no credit spread (excl. operational risk)
Read 5 tweets
21 Feb
THIS PASSAGE in interview of James Grant by Kevin Duffy struck me given heartbreak in Texas. Interview predated Texas storms.

Commodity mkts have been booming generally, driven by tight supply

When demand spike hits tight supply, prices ⬆️. It’s not just happening in #bitcoin
BTW, the price of a gallon of gasoline is up about 20% since Jan 1 near me. Ouch. #inflation
“What matters to me...is speaking up...for the great institution of corporate solvency (you’d be surprised how controversial it can become at the end of a boom).-James Grant @mises

I agree—corporate solvency can go out window in bull mkts. Happens to #bitcoin intermediaries too
Read 4 tweets
9 Feb
1/ HAPPY #TESLA DAY, #bitcoin! Two things in the announcement caught my eye🧐& are worth pondering.🤔

* the $1.5bn #bitcoin purchase was 7.7% of @Tesla's $19.4bn of cash. Why only 7.7%?

* Tesla plans to accept bitcoin as payment but "may or may not liquidate upon receipt." Why?
2/ Why only 7.7% of cash? Well, @Tesla confirmed it's using indefinite intangible accounting, which is UGLY treatment (lower of cost or market+risk of impairment charges). We bitcoiners must work to get bitcoin acctg fixed. It's prob why Square only put 2% of its cash into #BTC.
3/ What gives? "Impairment charge"=☠️. Cos hate them bc they cause sudden hits to earnings. I'd guess Tesla & Square ran scenario analyses to see how big an impairment charge they cld tolerate in a #bitcoin bear mkt, & sized their investment based partly on that (+other factors).
Read 14 tweets
16 Jan
1/ FASCINATING few weeks for social media—the migrations away from big platforms by fed-up users has been MASSIVE. Users proved we’re MUCH more powerful in ecosystems than many ppl thought (vaguely reminiscent of #UASF event in #bitcoin).

The b4 vs after venn diagram of the...
2/ ...social platforms & news sources I use has surprisingly little overlap. I’m trying many new platforms (today I happened upon a great Clubhouse chat room on #crypto law w/ @propelforward. Clubhouse is gonna disrupt podcasts in a v big way, IMHO). Follow me if you’re there! 🤠
3/ I don’t plan to leave @Twitter but I’m not wedded to it either. None of us should be! When 40m people sign up for one new platform & 25m for another in just days, you know something big is afoot.

Related, one of my mentors said something v wise:

#bitcoin will hack big tech.
Read 4 tweets

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