Topic: Banking-Treasury & ALM
Report type: Assessment Report on the Impact of Stablecoins on Bank Liquidity Management and Balance Sheet Structure (稳定币发展对银行流动性管理与资产负债结构影响评估报告)

With the rapid expansion of fiat-backed stablecoins (e.g., USDT, USDC), whose total market capitalization has exceeded USD 200 billion, most commercial banks remain in a wait-and-see stance. The core question is: under what conditions will the growth of stablecoins pose a material challenge to the bank deposit system, and how should banks respond strategically?

Focusing on the development of stablecoins in the United States and major international markets, and based on publicly available research and regulatory frameworks, conduct a systematic analysis from a financial system perspective, addressing the following tasks:

1. Threshold analysis:
What key conditions (e.g., scale, regulatory clarity, yield competitiveness) are required for stablecoins to transition from a niche tool to systemically important financial infrastructure? Is the United States currently on this trajectory? What lessons can be drawn from comparable historical episodes, such as the expansion of money market funds or the adoption of payment platforms like PayPal?

2. Strategic dilemma for banks:
Banks face a strategic paradox: ignoring stablecoins risks disintermediation, while actively engaging may expose them to regulatory and reputational constraints. In this context, what is the likely optimal strategy for large U.S. commercial banks, and what are the underlying logic and constraints?

3. Regulatory calibration:
Proposed U.S. stablecoin legislation requires 1:1 reserve backing. How would this requirement interact with bank liquidity regulations (e.g., LCR and NSFR)? Would it effectively mitigate systemic risk, or merely redistribute risk within the financial system (e.g., concentrating risk in reserve asset markets)?

## Evaluation Criteria for *Stablecoin Expansion, Bank Deposit Disintermediation, and Strategic Response*

This framework evaluates deep research reports on stablecoin growth, bank disintermediation risk, and regulatory calibration. The focus is whether the report identifies the tipping point at which stablecoins materially affect bank deposits, analyzes banks’ strategic choices and constraints, and assesses the interaction between stablecoin regulation and bank liquidity rules. Total: 100 points.

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### 1. Tipping-Point Analysis of Stablecoin Impact on Banks (30 points)

#### (1) Adoption conditions and transition mechanism (12 points)
- **10–12**: Clearly identifies key conditions such as scale, regulatory clarity, yield competitiveness, payment use cases, and user adoption, and explains how stablecoins could evolve into systemically important infrastructure.
- **7–9**: Covers major conditions, but the mechanism is incomplete.
- **0–6**: Lists conditions without a clear logic chain.

#### (2) Transmission path to bank deposit substitution (10 points)
- **9–10**: Clearly explains how stablecoins may affect demand deposits, payments, and bank funding costs, distinguishing gradual substitution from sudden shocks.
- **6–8**: Identifies the direction of impact, but the transmission mechanism is rough.
- **0–5**: Lacks substantive analysis of bank liability-side impact.

#### (3) Historical analogy and current-stage judgment (8 points)
- **7–8**: Uses cases such as money market funds and PayPal effectively and gives a clear judgment on the current U.S. stage.
- **4–6**: Provides analogy, but with limited relevance or weak conclusions.
- **0–3**: Lacks historical reference or stage assessment.

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### 2. Bank Strategic Response Analysis (30 points)

#### (1) Identification of strategic options (10 points)
- **9–10**: Clearly compares key paths such as waiting, defensive response, partnership, and in-house deployment, with relevant conditions for each.
- **6–8**: Identifies major options, but comparison is not systematic.
- **0–5**: Thin strategic analysis without a clear framework.

#### (2) Optimal strategy and constraint analysis (12 points)
- **10–12**: Explains the relatively optimal strategy for large U.S. banks from the perspectives of regulation, reputation, funding stability, customer relationships, and technical capability, while defining its limits.
- **7–9**: Offers a clear view, but constraint analysis is incomplete.
- **0–6**: Gives conclusions without sufficient support.

#### (3) International comparison and lessons (8 points)
- **7–8**: Draws on major international markets and extracts relevant implications for bank strategy.
- **4–6**: Includes some international perspective, but comparison is shallow.
- **0–3**: Lacks international comparison.

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### 3. Regulatory Calibration and Systemic Risk Assessment (25 points)

#### (1) Understanding of the stablecoin regulatory framework (8 points)
- **7–8**: Accurately explains core requirements such as 1:1 reserves, reserve asset scope, and redemption rules.
- **4–6**: Mostly correct, but incomplete.
- **0–3**: Contains major omissions or misunderstandings.

#### (2) Interaction with bank liquidity regulation (10 points)
- **9–10**: Clearly analyzes the relationship between reserve rules and LCR/NSFR, and the implications for bank liquidity management and liability structure.
- **6–8**: Identifies the main interaction, but lacks depth.
- **0–5**: Fails to discuss the mechanism effectively.

#### (3) Systemic risk reallocation judgment (7 points)
- **6–7**: Assesses whether regulation truly reduces risk or merely shifts it toward reserve assets, liquidity concentration, or market structure.
- **3–5**: Provides risk judgment, but not systematically.
- **0–2**: Lacks a systemic-risk perspective.

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### 4. Report Quality and Strategic/Policy Conclusions (15 points)

#### (1) Structure and professionalism (5 points)
- **5**: Clear structure, sound logic, and strong financial-system research quality.
- **3–4**: Basically complete, but average in organization.
- **0–2**: Weak structure and professionalism.

#### (2) Actionability of conclusions (6 points)
- **5–6**: Provides clear and actionable implications for bank strategy or regulation.
- **3–4**: Clear conclusions, but only moderately actionable.
- **0–2**: Vague conclusions.

#### (3) Risk disclosure and boundary conditions (4 points)
- **4**: Covers key risks such as regulatory change, weaker-than-expected adoption, credit events, and liquidity shocks, with clear transmission paths.
- **2–3**: Lists major risks, but without depth.
- **0–1**: Missing or formulaic risk disclosure.