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the-state-of-web3-education-and-onboarding
Blog

Why Stablecoin Issuers Are Becoming De Facto Banks

An analysis of how Tether, Circle, and Paxos now perform core banking functions—custody, KYC, and liquidity management—while operating in a regulatory gray zone, creating unprecedented systemic risk and opportunity.

introduction
THE REALITY

Introduction

Stablecoin issuers are replicating the core functions of commercial banks without the regulatory charter.

Stablecoin issuers are deposit-taking institutions. They accept user deposits (fiat or crypto) and issue a liability (the stablecoin) redeemable on-demand, mirroring a bank's core function. The on-chain balance sheet is the ledger, not a traditional database.

The yield engine is the new loan book. Protocols like Aave and Compound provide the infrastructure for issuers like MakerDAO (DAI) to generate revenue by lending out collateral, directly replicating a bank's net interest margin business.

Regulatory arbitrage defines the model. These entities operate in a legal gray area, avoiding capital requirements and deposit insurance (e.g., FDIC) that constrain traditional banks, creating a structural cost advantage.

Evidence: Tether's (USDT) $110B market cap exceeds the deposits of all but the largest US banks, and MakerDAO's PSM holds over $5B in direct USDC backing, functioning as a high-liquidity reserve.

market-context
THE REGULATORY ARBITRAGE

The $160B Shadow Balance Sheet

Stablecoin issuers now manage fractional-reserve banking operations without the corresponding regulatory capital or deposit insurance.

Stablecoin issuers are unlicensed banks. They accept deposits (mint stablecoins), manage a reserve portfolio, and generate yield, but operate outside the Basel III capital framework that governs traditional institutions like JPMorgan Chase.

The $160B reserve portfolio is a black box. Unlike a bank's disclosed balance sheet, the composition and risk of assets backing USDC (Circle) and USDT (Tether) are opaque, creating systemic counterparty risk for DeFi protocols like Aave and Compound that use them as primary collateral.

Yield generation is the core business model. Issuers earn revenue on safe treasury bills in their reserves, a practice identical to a bank's net interest margin, but they distribute this value to shareholders, not depositors.

Evidence: The combined market cap of USDT and USDC exceeds the total deposits of all but the top 30 U.S. banks, yet their operational oversight is fragmented across multiple, often non-bank, custodians.

DECONSTRUCTING THE MODERN MONEY TRANSMITTER

Stablecoin Issuer vs. Traditional Bank: A Functional Comparison

A functional breakdown of core banking services, comparing a regulated fiat-backed stablecoin issuer (e.g., Circle, Tether) with a traditional commercial bank (e.g., JPMorgan Chase).

Core Function / MetricRegulated Stablecoin Issuer (e.g., USDC)Traditional Commercial Bank

Primary Revenue Source

Yield on Treasury reserves & transaction fees

Net Interest Margin (NIM) on loans

Capital Efficiency (Loans/Deposits)

0% - No fractional reserve lending

70-90% - High leverage via fractional reserves

Settlement Finality

< 1 minute (on-chain)

1-3 business days (ACH, Wires)

Global Access (Unbanked Users)

âś… - Permissionless wallet creation

❌ - Requires KYC/geographic charter

Interest on Customer Deposits

❌ - Not offered by issuer (yield via DeFi)

âś… - Offered directly (e.g., 0.01% APY)

Operational Cost / Transaction

< $0.01 (on L2s like Base, Arbitrum)

$0.25 - $1.50 (domestic wire)

Regulatory Capital Requirement

100% reserve for fiat-backed (e.g., NYDFS)

8-13% risk-weighted (Basel III)

Primary Counterparty Risk

Custodian bank & Treasury securities

Loan portfolio & interbank market

deep-dive
THE REGULATORY REALITY

The Slippery Slope: From Mint/Redeem to Full-Service Banking

Stablecoin issuers are forced into banking roles by user demand and regulatory pressure, creating systemic risk.

The core mint/redeem model is insufficient for user needs. Users demand seamless cross-chain transfers, not manual redemptions. This forces issuers like Circle and Tether to operate liquidity pools and manage multi-chain deployments, assuming settlement and custody risk.

Regulators view on-chain activity as banking. The Bank Secrecy Act and OFAC compliance require issuers to monitor transactions across all integrated chains and bridges like LayerZero and Wormhole. This surveillance and sanctioning is a core banking function.

Yield generation creates a shadow banking system. To back reserves, issuers purchase Treasuries and use repo markets. This asset-liability management and the pursuit of yield mirrors traditional bank operations, concentrating risk in a few entities.

Evidence: Circle's USDC is natively issued on 15+ blockchains and integrated with every major DEX and bridge. Its reserve management involves BlackRock and BNY Mellon, a de facto banking partnership.

risk-analysis
SHADOW BANKING 2.0

The Systemic Risks Nobody Is Auditing

Stablecoin issuers now manage balance sheets rivaling mid-sized banks, but operate with fragmented oversight and novel on-chain risks.

01

The Liquidity Black Box

Reserve composition is often opaque or concentrated in risky, correlated assets. A single commercial paper default or bank run could trigger a de-peg cascade.

  • Tether's (USDT) ~$110B reserves are partially in undisclosed commercial paper.
  • Circle's (USDC) $28B+ is exposed to US banking system stability.
  • MakerDAO's PSM backs DAI with centralized stablecoins, creating reflexive risk.
$150B+
Combined Risk
~85%
Off-Chain Backing
02

The Custody & Counterparty Avalanche

Issuers rely on a fragile chain of traditional custodians, money market funds, and banking partners. The failure of a key node like BNY Mellon or Silvergate could freeze billions.

  • Single points of failure in treasury management.
  • Chainlink oracles become critical infrastructure for verifying off-chain collateral.
  • Regulatory seizure risk concentrated in a few jurisdictions.
3-5
Critical Nodes
24-72h
Redemption Lag
03

The Governance Attack Surface

Protocol governance keys and admin multisigs for issuers like MakerDAO, Frax, and Liquity are high-value targets. A compromise could drain reserves or mint unlimited supply.

  • MakerDAO's PSM shutdown module is a centralized kill switch.
  • Frax's hybrid model ties stability to volatile FXS token and off-chain assets.
  • Smart contract risk in mint/redeem logic is often under-audited for economic attacks.
$5B+
Governance TVL at Risk
7/10
Multisig Reliance
04

The Regulatory Arbitrage Time Bomb

Issuers exploit gaps between securities, commodities, and money transmission laws. A coordinated global crackdown could force sudden, destabilizing redenomination.

  • SEC vs. Ripple precedent hangs over algorithmic and seigniorage shares.
  • EU's MiCA imposes strict licensing, potentially excluding US-based issuers.
  • De-pegging becomes a political tool during geopolitical tensions.
50+
Jurisdictional Gaps
High
Event Correlation
05

The Cross-Chain Contagion Vector

Native issuers on Ethereum like USDC are bridged to Layer 2s, Solana, and Avalanche via wrapped versions (e.g., USDC.e). A de-peg on one chain can spread via arbitrage bots and panic across all bridges.

  • Wormhole, LayerZero, Axelar bridges become failure amplifiers.
  • Liquidity fragmentation means thin markets can't absorb large redemptions.
  • Oracles report de-peg, triggering cascading liquidations in DeFi protocols like Aave and Compound.
10+
Bridge Protocols
$2B+
At Risk per DeFi Pool
06

The Run Dynamics Are Untested

Digital, 24/7 redemption creates bank run physics at network speed. First-mover advantage is extreme, and automated DeFi strategies will front-run human redeemers, exacerbating the crisis.

  • Flash loan attacks can simultaneously drain multiple liquidity pools.
  • Stablecoin AMM curves (Curve 3pool) become unstable under stress.
  • No lender of last resort exists; protocols like MakerDAO's PSM have finite capacity.
<1 Block
Run Onset
1000x
Speed vs. TradFi
counter-argument
THE REGULATORY REALITY

Counterpoint: "They're Just Money Market Funds!"

Stablecoin issuers are not passive funds; they are active credit intermediaries operating with bank-like systemic risk.

Stablecoin issuers create credit. They invest user deposits in commercial paper and repos, a core banking function. This transforms them from passive custodians into active shadow banks.

Their failure triggers contagion. A run on a major issuer like Tether or Circle would freeze short-term credit markets. This systemic risk mirrors the 2008 crisis, not a simple fund liquidation.

Evidence: Tether’s $110B portfolio includes $80B in US Treasuries. Circle holds a $28B reserve in the US Treasury’s Triparty Repo system. Their scale integrates them directly into traditional monetary plumbing.

future-outlook
THE BANKING ENDGAME

Regulatory Capture or Disruption? The 2025 Inflection Point

Stablecoin issuers are evolving into full-spectrum financial institutions, forcing a regulatory showdown over their core nature.

Stablecoins are deposit-taking institutions. Issuers like Circle and Tether hold massive reserves, creating a shadow banking system that operates outside traditional capital requirements and lending rules.

Yield-bearing stablecoins are the Trojan horse. Products like Mountain Protocol's USDM and Ethena's USDe offer native yield, directly competing with bank savings accounts and money market funds for capital.

The 2025 inflection point is regulatory classification. The SEC will argue these are securities, while issuers will fight for a narrow payments-focused definition to avoid becoming regulated banks.

Evidence: Circle's $33B in USDC reserves now eclipse the deposits of many mid-tier U.S. banks, creating a systemic entity with no lender-of-last-resort backstop.

takeaways
THE NEW FINANCIAL PRIMITIVES

TL;DR: What This Means for Builders and Investors

Stablecoin protocols are no longer just payment rails; they are accruing the core functions of a bank, creating new attack surfaces and trillion-dollar opportunities.

01

The Problem: Yieldless Reserves

Holding billions in low-yield treasuries or bank deposits is a massive capital inefficiency. Issuers like Circle (USDC) and Tether (USDT) are leaving billions in annual revenue on the table.

  • Opportunity Cost: ~$5B+ in forgone annual yield on ~$150B+ reserves.
  • Investor Pressure: Demands for treasury diversification and yield generation are mounting.
$150B+
Reserves
~5%
Yield Gap
02

The Solution: On-Chain Treasury Management

Protocols like MakerDAO (DAI) and Ethena (USDe) are pioneering the model: using stablecoin reserves to generate native yield via DeFi.

  • Revenue Engine: Deploying capital into Aave, Compound, and staked ETH to fund protocol sustainability and holder rewards.
  • De-Banking Risk: Reduces reliance on traditional financial custodians and their associated counterparty risk.
$2B+
DeFi TVL
100%+
APY Models
03

The New Moat: Embedded Lending & Credit

Stablecoin balance is becoming the new credit score. Protocols are building lending arms directly into their issuance infrastructure.

  • Native Credit Lines: Holders can borrow against their stablecoin deposits without leaving the protocol, Ă  la Aave but vertically integrated.
  • Data Advantage: Issuers have perfect visibility into on-chain cash flows, enabling superior risk underwriting compared to traditional banks.
0-Day
Settlement
24/7
Underwriting
04

The Regulatory Arbitrage Play

Operating as a 'protocol' rather than a 'bank' provides a crucial regulatory gray zone for global expansion.

  • Speed to Market: Can launch financial products in days, not years, avoiding legacy licensing quagmires.
  • Jurisdictional Flexibility: Can structure entities and product offerings across multiple regimes (e.g., Circle in the US, Tether internationally).
10x
Faster Launch
200+
Countries Served
05

The Builders' Playbook: Protocol-as-a-Service

The infrastructure for launching a branded stablecoin is now commoditized. The real value shifts to the application layer built on top.

  • White-Label Issuance: Use Circle's CCTP or LayerZero's OFT standard to launch in weeks.
  • Monetize Distribution: Build vertical-specific use cases (e.g., payroll, trade finance) where you own the customer relationship and can embed financial services.
<4 Weeks
Time to Launch
~0%
Mint/Redeem Fee
06

The Investor Lens: Follow the Cash Flow

Valuation models must shift from simple 'fee on transaction volume' to analyzing the quality of the balance sheet and the yield spread.

  • Key Metric: Net Interest Margin (NIM) on the reserve portfolio.
  • Red Flag: Over-reliance on a single, opaque custodian or jurisdiction (e.g., a single foreign bank).
NIM >2%
Target Metric
T-1
Reserve Audit
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Why Stablecoin Issuers Are De Facto Banks in 2025 | ChainScore Blog