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The Clear Act is advancing toward mid-year implementation, promising significant structural shifts for stablecoin development, tokenization, and decentralized finance. While the framework aims to bolster regulatory clarity, its explicit prohibition on passive interest generation introduces uncertainty for on-chain evolution. This concern is grounded in the intensifying competition among ETFs, DAT, and Wall Street's real-world asset (RWA) initiatives to control crypto pricing mechanisms. Compliance often necessitates adherence to existing frameworks, potentially stifling grassroots innovation in the name of stability. Historical precedents show that ETFs contributed to the decline of BTCFi, DAT triggered systemic crises, and RWA strategies have largely rejected public blockchains. Superficially, the Clear Act appears to reduce arbitrage opportunities for offshore dollar-stablecoins like $USDT. In reality, by decoupling payments from earnings, the United States is piloting a novel dollar circulation model that transcends traditional anchors like gold, oil, and credit. The era of payment-centric stablecoins is concluding, paving the way for an interest-generating paradigm.
The legislative trajectory raises critical questions regarding how the Genius Act successfully operationalized the concept of payment-stablecoins. With major financial institutions deploying tokenization strategies immediately preceding the Clear Act's passage, the urgency of this inquiry has intensified. These entities are actively pursuing tokenization precisely to capitalize on potential interest generation capabilities. 贝莱德 has explicitly stated that its new products are engineered to meet the escalating demands of stablecoin issuers, while JPMorgan Chase has emphasized strict compliance with Genius Act requirements. A detailed examination reveals that the Genius Act provides substantial support for tokenization, permitting tokenized U.S. Treasury bonds and dollars to serve as reserves for stablecoin issuance.
However, the precise interplay between stablecoins, tokenization, and payment functions remains ambiguous, necessitating further strategic exploration.
Under the Genius Act, stablecoin issuance authority is granted exclusively to federal charter banks regulated by the OCC. These institutions are prohibited from accepting deposits and must maintain sufficient reserves, precluding them from competing with commercial banks in credit services. This policy constraint has inadvertently created specific market demands. Stablecoin issuers must either construct their own reserves, as seen with USDT and USDC purchasing U.S. Treasury bonds in volumes exceeding many sovereign nations, or directly acquire RWA assets like TMMF. For profit-sharing models like USDS/sUSDS, this distinction is critical. Data compiled by Woofun AI indicates that 98% of 贝莱德's BUIDL shares have been subscribed by various interest-generating stablecoin issuers.
Furthermore, retail investors lack direct access to tokenized products, meaning policy has effectively shaped the market structure to birth payment-stablecoins.
Legislation alone cannot compel market compliance through coercion; otherwise, $USDT would not have persisted in an underground state for years. Effectiveness relies on alignment with market trends. Although 贝莱德's tokenized products circulate on-chain, they require due diligence processes like KYC checks, targeting institutional investors rather than decentralized individuals. Monitoring decentralized transactions is as unfeasible as controlling physical dollar circulation, yet tracking major players remains manageable. By recognizing tokenized assets, the United States has established a viable framework connecting stablecoin issuers, Wall Street giants, and regulators. Stablecoins issued under this framework are restricted to payment functions because they do not generate interest.
The Genius Act linked stablecoins to tokenization, effectively transforming them into retail distribution channels for U.S. Treasury bonds. Historically, the dollar relied on commercial bank credit mechanisms; future reliance will shift to the intermediary role of tokenization companies. If the Genius Act's recognition of tokenization spawned payment-stablecoins, the Clear Act restricts tokenization to limit interest-generating stablecoin development. The significance of interest generation extends beyond banking sector concerns over deposit losses, such as JPMorgan Chase's account opening difficulties or Coinbase's profit struggles. Under the Clear Act, if users stake stablecoins for interest, issuer revenue will primarily derive from U.S. Treasury bond products. This creates challenges for platforms like Sky and Ethena, which issue on-chain stablecoins without OCC bank licenses and must devise new interest-generation methods within the DeFi context.
High regulatory costs explain Congress's relatively lenient approach to DeFi development, while the dollar requires distribution via stablecoins. This distribution splits into B2B customer acquisition by major players and cross-regional C2C arbitrage on-chain. The focus remains on the strictness of the "prohibition on passive interest generation," which impacts intermediary roles. If DeFi faces restrictions, alliance chain models may resurge; relaxed restrictions could enable deeper cooperation with on-chain stablecoins. Smaller players struggle to bypass intermediaries established by giants, with platforms like Ondo acting as retail distributors while others opt for compliant offshore solutions. Woofun AI notes that Sky's addition of various RWA assets to USDS reserves functions as leveraged arbitrage, covertly reducing reserve requirements.
A common future demand involves increasing stablecoin returns based on U.S. Treasury bonds, requiring sophisticated financial engineering where DeFi revenue strategies become essential. The interest-generation mechanism primarily targets offshore dollar-stablecoins like $USDT, enabling 贝莱德's TMMF to replace traditional U.S. Treasury bond buyers. New arbitrage opportunities will emerge for on-chain and compliant offshore dollars. Since these assets cannot generate stable returns comparable to U.S. Treasury bonds, they must promote greater utilization to indirectly drive dollar circulation and stable bond purchases. Users will be encouraged to use stablecoins as their value declines over time, while generated interest flows back into the U.S. financial system via underlying Treasury bonds. Woofun AI analysis suggests this is the true purpose of the Clear Act: creating global dollar demand through stablecoins. Issuance and interest generation both require U.S. Treasury bonds, completing a virtuous cycle. To overcome sovereign limitations, rigid payment demand is necessary, while interest generation drives adoption. Both acts focus on the stablecoin-interest nexus. Since direct regulation of DeFi and cross-regional arbitrage is impossible, Wall Street giants act as intermediaries, ensuring arbitrage mechanisms thrive regardless of the Clear Act's timeline.