Key Takeaways:
Zhou Xiaochuan warns that full-reserve stablecoins can still amplify systemic risk through leverage and trading channels. The Hong Kong and U.S. frameworks have begun addressing custody and issuance, but Zhou calls the current oversight insufficient. A new study suggests stablecoins face a one-in-three chance of collapse over the next decade due to crisis-induced arbitrage failures.Former People’s Bank of China Governor Zhou Xiaochuan warned that stablecoin issuers may pursue aggressive expansion without understanding the systemic risks involved, including amplification effects that go beyond stated reserves.
In a speech delivered at the International Capital Market Association (ICMA) Annual Conference in Frankfurt and later compiled by the China Finance 40 Forum (CF40), Zhou said issuers often “lack sufficient self-discipline,” adding that stablecoins “generate a money-multiplier effect through their operation.”
Over-Issuance and High Leverage
He cautioned that even with full reserve backing, stablecoins can amplify risk through deposit-lending, collateralized financing, and asset trading.
“The potential redemption pressure may be multiples of the initial reserves,” he said.
Zhou also criticized inadequate reserve custody standards, citing Facebook’s early plans to self-custody Libra assets as an example of flawed design. He argued that reserves should be held by a central bank or a recognized custodian under central bank supervision.
The Hong Kong Stablecoin Ordinance and the U.S. GENIUS Act address some of these concerns, but Zhou said regulatory gaps persist. He recommended compiling actual circulation data to estimate redemption risks, calling current oversight frameworks “far from sufficient.”
He referenced Hong Kong’s note-issuing model, where banks post U.S. dollars with the Monetary Authority to issue local currency, noting that “M0 reserves alone cannot maintain stability under redemption pressure from M1 and M2.”
Zhou urged regulators to develop more robust tools to track amplification channels and prevent misuse of stablecoins in leveraged or speculative activity.
Run Risk Paradox of Stablecoin
TerraUSD’s May 2022 collapse illustrates the mechanism Zhou flags: once the peg slipped, the mint–burn arbitrage with LUNA accelerated supply inflation and drained market liquidity, catalyzing a run. New York Fed researchers note that between May 1 and May 16, 2022, stablecoins’ market capitalization fell by $25.63 billion—evidence of amplification channels overwhelming reserves during stress.
Recent analysis published by Investopedia paints a different picture, shifting attention from issuance mechanics to crisis-driven vulnerabilities in stablecoin design. Researchers identified a “run risk paradox,” where arbitrage mechanisms that support stablecoin pegs under normal conditions can accelerate collapse during market stress.
They found that even with decentralized arbitrage, systemic fragility remains elevated—annualized risk estimates for stablecoins range from 3.3% to 3.9%, higher than FDIC-insured deposits. Over a decade, the study suggests there is roughly a one-in-three chance of a major stablecoin crisis.
This perspective argues that stability tools like market arbitrage may themselves become sources of systemic strain, spotlighting potential design flaws in how stablecoin models handle extreme events, rather than just issuance controls or reserve policies.
Frequently Asked Questions (FAQs)
Leverage and multiplier effects can extend beyond issuers to exchanges, traders, and DeFi platforms, potentially triggering broader liquidity disruptions if redemptions spike.
Under normal conditions, arbitrage helps maintain price pegs. In volatile markets, it can accelerate instability by enabling fast, large-volume exits that drain liquidity.
Some researchers suggest that more attention should go to market design, redemption incentives, and arbitrage feedback loops, especially during volatility or cross-platform liquidity shifts.
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