Hi Jonas, sorry for the delay but I really don't see Medium notifications until I log back in to publish something else. I'm most reachable on Twitter or Telegram, both @mud2monarch.

Those regulations seem sensible - they just encode essentially what has been demanded by the market - but I personally think they are too prescriptive. The regulator has an interest in financial stability, but that can be accomplished through stress tests and examinations, like we have in the US for banks.

When it comes to stablecoin reserves, I tend to think that the 100% reserve in cash + treasuries is overly conservative. The reserve probably does not need to be that conservative, even in times of crisis. Perhaps regulators could set up a two-tier approach with examinations and a safe harbor for the reserve. I.e., the stablecoin issuer could set its own reserve allocation provided that they can prove in a stress test that they can redeem all stablecoin claims, with liquidity costs associated with selling assets urgently in stress. It would cost money to perform the stress test & deal with regulators, so alternatively the issuer could hold the reserve entirely in government securities and cash, which would serve as a safe harbor for the stress test (if you hold the reserve like so, you are automatically assumed to pass the stress test).

An interesting piece I read recently was the following from the NY Fed. They discuss run tendencies in money market funds and mechanisms that can shore up run risk aside from government insurance: https://libertystreeteconomics.newyorkfed.org/2022/01/pricing-liquidity-without-preemptive-runs/