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PaperImperium
All things DeFi, economics, and Stardew Valley. Views and opinions do not reflect those of @labsGFX. “Like the Hindenburg Research of governance”
I will need to read the paper (I haven’t yet) but this is the kind of thing that doesn’t pass the smell test. What mechanically would be at work to make this statement true? Either effect is very small (and not statistically significant) or data not good. That’s my prediction

John B. Holbein23 tuntia sitten
You know those no-cheating declarations that some professors make students sign?
There's some published evidence that these declarations actually increase cheating.
"Signing an honesty declaration doubled cheating relative to the control group. Complementary experiments suggest that the declaration backfired because it weakened the social norm of academic integrity."




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I just finished reading Christopher and Andrea’s paper Regulating Stablecoins: Comparing MiCAR and the GENIUS Act. Their work highlights contractual weaknesses in the terms of use of major stablecoin issuers, including one-sided provisions, vague redemption timelines, and unclear customer bankruptcy protections. They argue these issues are not inherent to stablecoin technology and can be addressed through modest contractual revisions.
Now that the GENIUS Act has been signed into law, we are entering the implementation phase—when regulators at the OCC and Treasury will begin crafting the rules and application process for onboarding GENIUS-compliant stablecoins. As part of that process, existing issuers such as Circle and Tether will need to apply to Treasury for approval of their stablecoins.
At this early stage, the application process remains unclear. While the Act does not explicitly require regulators to review an issuer’s Terms of Service, the OCC and Treasury have broad authority to evaluate whether an issuer’s operations meet statutory objectives. This provides an opportunity for regulators to engage with stablecoin issuers on revising their terms—not only to comply with GENIUS Act requirements, but also to address the concerns raised in Christopher and Andrea’s paper.
For example, as a condition of approval, regulators could require revised terms that guarantee timely redemption, establish direct contractual privity with all holders, grant holders clear priority claims over reserves in insolvency, and use plain-language disclosures.
Integrating this review into the approval process would align contractual rights with the Act’s operational safeguards, strengthen consumer protection, and enhance the credibility of U.S.-approved stablecoins in both domestic and global markets.
Thanks for sharing your paper. I am currently compiling a list of proposed comments and concerns from key crypto-sector figures that regulators should consider as they begin the GENIUS Act rulemaking process.
I’d welcome your thoughts on this proposed remedy, and I’d like to hear from others in the sector and in government so we can ensure we get this right. I’m happy to advise and consult on this and other GENIUS Act related issues.
Thanks,
Carlo
Founder and Chief Strategist
@circle
@jerallaire
@ddisparte
@Tether_to
@paoloardoino
@USTreasury
@USOCC
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Getting an S&P rating is pretty cool, so congratulations, but the rating itself is pretty devastating.
"B-" is basically junk status and renders USDS uninvestable for most institutions.
Nevertheless, I'm rooting for Maker/Sky and hope to see improvements in the rating over time! Ultimately, truly decentralized protocols should be more secure than their centralized counterparts.
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