CLARITY 법이 스테이블코인 수익 경제를 어떻게 재편하는가

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2026-05-30 11:00

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스테이블코인 수익 경제 전체가 '보유 시 이자 지급'에서 '사용 시 이자 지급'으로 강제로 재편되었으며, 토큰화된 머니마켓 펀드가 기초 준비 자산으로서 새로운 패러다임에서 가장 안정적으로 혜택을 보는 규제 준수 수익 인프라 중 하나가 되었습니다.

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핵심 시각: 미국 CLARITY 법안이 상원 은행위원회를 통과하면서 스테이블코인 수익 금지를 모든 디지털 자산 서비스 제공업체로 확대하고, '수동적 수익 vs 활동 기반 보상'이라는 법적 이분법을 도입하여 업계가 '보유 시 이자 지급'에서 '사용 시 이자 지급'으로 전환하도록 강제했습니다. 월스트리트 자산운용사(모건스탠리, 블랙록, JP모건)들은 토큰화된 머니마켓 펀드를 동시에 준비하며 새로운 패러다임 하에서 가장 안정적인 규제 준수 수익 인프라로 자리매김하고 있습니다.
핵심 요소:
1. CLARITY 법안 섹션 404는 두 가지 핵심 사항을 수행합니다: 수익 금지를 스테이블코인 발행자에서 거래소, 수탁사 등 모든 DASP 및 그 관계사로 확대하고 '수동적 수익'과 '활동 기반 보상'의 이분법을 도입하여 단순 보유 기반 이자는 금지하지만 스테이킹, 거래 등 실제 활동 기반 보상은 허용합니다.
2. 이 법안은 코인베이스의 구독 모델, 앵커리지의 관계사를 통한 '간접 이자 지급' 등 규제 우회 경로를 차단하여 업계가 수익 모델을 재구축하도록 강제합니다.
3. 법안 통과 전 28일 동안 모건스탠리(MSNXX), 블랙록(BSTBL/BRSRV), JP모건(JLTXX)이 거의 동시에 스테이블코인 준비금 수요에 최적화된 토큰화된 머니마켓 펀드를 등록하여 시장 기대가 이미 새로운 패러다임에 따라 산업을 재편하고 있음을 보여줍니다.
4. 새로운 패러다임 하에서 수익 전달은 세 가지 경로를 가집니다: 경로 A(거래소의 활동 보상 재설계), 경로 B(DeFi 프로토콜 계층의 비수탁 수익), 그리고 경로 C(토큰화된 머니마켓 펀드가 준비 자산으로서 이자 지급). 이 중 경로 C가 규제 직접 위협이 가장 적고 위험 조정 매력도가 가장 높습니다.
5. OCC가 제안한 '토큰화된 준비 자산 비중 20% 상한' 제안은 경로 C의 규모화 가능성을 결정짓는 핵심 게임입니다. CLARITY 법안이 토큰화된 증권에 법적 지위를 부여하여 OCC의 제한 근거를 약화시켜 상한선이 완화될 가능성이 있습니다.
6. 블랙록은 이미 3계층 제품 매트릭스(BUIDL, BSTBL, BRSRV)를 구축하여 DeFi 담보, 전통 기관 현금 관리 및 스테이블코인 준비 자산을 포괄하는 완전한 생태계를 형성했습니다.
7. BUIDL의 집중 리스크가 두드러집니다: 단일 펀드가 USDtb 준비금의 약 90%와 JupUSD 준비금의 약 81%를 지원합니다. OCC 상한선이 완화될 경우 이러한 단일 장애점 리스크가 증폭되어 시스템적 위험을 초래할 수 있습니다.

Original author: @BlazingKevin_, Blockbooster Researcher

On May 14, 2026, the U.S. Senate Banking Committee passed the CLARITY Act with a bipartisan vote of 15-9.

The most significant content in this "legislative progress" is Section 404 of the bill text. This section, redrafted by Senators Thom Tillis and Angela Alsobrooks in a compromise text released on May 1, accomplishes two things that the GENIUS Act did not:

First, it extends the stablecoin yield prohibition to all Digital Asset Service Providers (DASPs) and their affiliates – including centralized exchanges, brokers, dealers, and custodians. When signed in July 2025, the GENIUS Act only restricted "stablecoin issuers" (PPSI/FPSI). All the compliance workarounds used by Coinbase, Anchorage Digital Neo Ltd., etc., to continue offering users 3.5%-5% yields through "non-issuer interest payment" paths have been closed off by Section 404.

Second, it clearly introduces a legal dichotomy between "passive yield vs. activity-based rewards." Section 404 prohibits rewards that are "functionally or economically equivalent to interest on bank deposits" – i.e., yield generated automatically solely based on holding – but preserves rewards "based on genuine activity or transactions," such as staking, market-making, credit card cashback, and merchant transaction rewards.

Together, these two changes constitute a paradigm shift. The stablecoin industry is transitioning from a market of "hold-to-earn" towards a market of "use-to-earn."

Simultaneously, over the past month, the three largest asset management institutions on Wall Street (Morgan Stanley, BlackRock, JPMorgan) have nearly simultaneously launched money market fund products tailored for stablecoin reserve requirements. Morgan Stanley's MSNXX was established on April 16 and publicly announced on April 23; BlackRock filed for two tokenized funds, BSTBL and BRSRV, on May 8; JPMorgan filed for JLTXX on May 12. The three firms launched highly similar products within a 28-day window.

This timing is certainly not a coincidence. We believe: The expectation that CLARITY Section 404 will pass is pushing the stablecoin yield economy towards a new paradigm – the hold-to-earn path is narrowing, the use-to-earn path is preserved, and tokenized money market funds, acting as compliant yield-bearing tools for stablecoin reserves, become the most resiliently beneficial compliant yield layer in this new paradigm.

The products concentratedly filed by Wall Street asset management giants in April-May represent an industrial positioning for this paradigm shift. It is important to clarify: CLARITY has currently only passed the Senate Banking Committee and still has a way to go before presidential signature, but market expectations are already reorganizing in this direction.

This article will start by reconstructing the timeline, deconstruct the legal relay structure between GENIUS and CLARITY, and analyze why the tokenized reserve asset layer is becoming the most resilient compliant yield channel in the new paradigm.

1. A 30-Day Window of Industrial Positioning

1.1 April 16: Morgan Stanley's Opening Move

Let's go back to the earliest event first.

On April 16, 2026, Morgan Stanley's Stablecoin Reserves Portfolio (ticker: MSNXX) was officially established.

On April 23, MSIM publicly announced the product.

The product positioning of MSNXX is very precise. The official statement read: "The Fund offers a qualifying money market fund option for compliant stablecoin issuers to invest the reserve assets backing their circulating stablecoins."

MSNXX is a product tailored for reserve asset requirements – investing in cash, U.S. Treasury securities maturing within 93 days, and overnight repos collateralized by Treasuries.

However, MSNXX is not a tokenized product and does not trade on-chain. Morgan Stanley's product strategy is conservative – it only offers a traditional MMF wrapper, allowing stablecoin issuers to invest through traditional financial channels.

This is the first publicly announced product "specifically designed for stablecoin reserve needs" from Wall Street asset management giants. While not revolutionary in itself, it sends a clear signal: the demand for stablecoin reserves has grown large enough for asset management giants to create a dedicated fund for it.

1.2 May 8: BlackRock's "Dual Filing"

22 days later, BlackRock submitted two registration statements to the SEC simultaneously: the BlackRock Select Treasury Based Liquidity Fund tokenized version (BSTBL) and the BlackRock Daily Reinvestment Stablecoin Reserve Vehicle (BRSRV).

The design of these two products contrasts sharply with MSNXX. BSTBL is a tokenized version of BlackRock's existing Select Treasury Liquidity Fund. It serves traditional institutional cash managers – clients who have already bought the fund, now simply gaining an additional on-chain distribution channel.

BRSRV is a newly created tokenized money market fund, distributed multichain via Securitize, targeting only one customer group: stablecoin issuers.

The key difference between BlackRock and Morgan Stanley lies in tokenization. BlackRock chose to issue shares of the same underlying assets (short-term Treasuries + cash + overnight repos) on-chain for stablecoin issuers, giving the reserve assets themselves on-chain composability, 24/7 transferability, and potential for integration with DeFi protocols. This is a product form tailored for crypto-native clients (like Ethena, Jupiter).

The BSTBL + BRSRV filing extends BlackRock's existing product matrix, expanding the tokenization infrastructure from BUIDL's "DeFi collateral" use case to BRSRV's "stablecoin reserve asset" use case.

1.3 May 12: JPMorgan's Second Entry

Four days later, JPMorgan filed with the SEC for the JPMorgan OnChain Liquidity-Token Money Market Fund (JLTXX).

The fund itself invests in U.S. Treasuries and overnight repurchase agreements collateralized by Treasuries or cash, with underlying assets identical to BUIDL, BSTBL, and BRSRV. The Token Class Shares are dated May 13.

JLTXX is not JPMorgan's first on-chain MMF. As early as December 15, 2025, JPMorgan Asset Management launched My OnChain Net Yield Fund (MONY) on Ethereum. MONY is a 506(c) private fund available only to qualified investors.

This means JPMorgan already has nearly five months of operational experience in the tokenized MMF track. JLTXX is not a catch-up product; it's the second step in JPMorgan's on-chain MMF strategy – expanding a product previously limited to 506(c) qualified investors into a registered fund accessible to a broader customer base, specifically targeting the stablecoin reserve use case.

On one hand, JPMorgan explored the possibility of issuing a joint syndicate stablecoin with Bank of America, Wells Fargo, and Citigroup in 2025. On the other, it deeply positions itself in the tokenized reserve asset track through the MONY → JLTXX product matrix. Regardless of the OCC's final ruling, JPMorgan has a product in place – this "betting on both sides" is the unique strategic space JPMorgan enjoys as both a GSIB bank and an asset management company.

1.4 May 14: The CLARITY Act Validates the Entire Track

On May 14, the Senate Banking Committee passed the CLARITY Act with a bipartisan vote of 15-9.

It's worth pondering: Morgan Stanley's MSNXX, BlackRock's BSTBL/BRSRV, JPMorgan's JLTXX – these products were all prepared before the compromise text of CLARITY Section 404 was made public.

In fact, since CLARITY was first shelved in January 2026, the asset management industry has understood two things clearly: First, the "hold-to-earn" stablecoin reward path would eventually be shut down. Second, stablecoin reserve assets must exist, must be compliant, and will inevitably yield interest.

Putting these two together: When the hold-to-earn path narrows, one of the most resilient "indirect yield" transmission paths is through the reserve asset layer – the stablecoin issuer itself does not pay interest, but its reserve's tokenized money market fund legally pays interest to the issuer, who then decides how to pass this yield to users within a compliant framework.

The products of the asset management giants are the infrastructure prepared for this "most resilient compliant yield channel."

2. Why CLARITY Is Much More Important Than GENIUS

2.1 The Limited Scope of the GENIUS Act

To understand the paradigm-shifting effect of Section 404, one must first precisely understand what it expands upon – GENIUS Act 4(a)(11).

Signed into law in July 2025, the GENIUS Act stipulates that compliant stablecoin issuers or foreign stablecoin issuers shall not pay any form of interest or yield to stablecoin holders.

This means the GENIUS Act itself does not distinguish between "passive yield" and "activity-based rewards"; any form of interest or yield paid by the issuer to the holder is prohibited.

Second, its restrictions apply only to the issuer itself, not to third parties like exchanges, wallets, custodians, or affiliates.

This second limitation created a regulatory loophole – known in the industry as "pass-through evasion." Throughout the entire 2025-2026 period, the stablecoin industry essentially operated by seeking compliant innovation space within this loophole:

Coinbase / Kraken Model: Exchanges distribute rewards. USDC is issued by Circle, but Coinbase offers approximately 4% rewards to USDC holders through the Coinbase One subscription model.
Gemini Credit Card Model: Rewards are triggered by external merchant transactions. GUSD is issued by Gemini Trust Company, but Gemini credit card holders receive GUSD cashback when spending at merchants.
Anchorage Digital Neo Model: Rewards are paid through a separate affiliated legal entity. USDtb is issued by Anchorage Digital Bank, but Anchorage Digital Neo Ltd. (a distinct legal entity) pays the rewards.

These three models collectively formed the "indirect yield" ecosystem of the GENIUS era.

But the compliance foundation for all this was the limited scope of the GENIUS Act restricting only issuers.

2.2 The Substantive Expansion of CLARITY Section 404

CLARITY Act Section 404 does the two things the GENIUS Act did not.

First: Expansion to DASPs and Affiliates

The restrictive scope of Section 404 is no longer limited to stablecoin issuers but extends to "covered digital asset service providers and their affiliates." This scope explicitly covers centralized exchanges, brokers, dealers, and custodians.

This expansion immediately closes all the "non-issuer interest payment" compliance paths used by Coinbase, Kraken, Gemini, Anchorage Digital Neo, etc. Coinbase, as a DASP, can no longer offer hold-only rewards on USDC; Anchorage Digital Neo can no longer pay rewards on USDtb.

Second: Introducing the "Passive vs. Activity" Dichotomy

Section 404 prohibits DASPs from providing rewards "functionally or economically equivalent to interest on bank deposits" but preserves rewards "based on genuine activity or transactions."

This means any reward tied to "spending, transacting, staking, or transferring" can survive, while any reward that grows linearly with idle balances cannot.

Together, these two things constitute a complete paradigm shift. All the "indirect yield" templates from the GENIUS era are either shut down or need to be redesigned in the CLARITY era.

The stablecoin industry is moving from a market of "hold-to-earn" to a market of "use-to-earn."

2.3 The Winning Paths in the Paradigm Shift

In the use-to-earn paradigm, there are three possible paths to pass yield to users.

Path A: Redesign Rewards as Activity-Based Rewards

Applicable to: Exchanges, wallets, credit cards. Coinbase might change its USDC rewards from "hold-to-earn" to "based on transaction frequency/spending amount." Gemini is already using the credit card cashback model.

The key question for Path A isn't whether it can retain users, but its design cost – Coinbase would need to restructure the entire legal framework and product UI of its rewards system, with every active design subject to SEC/CFTC factual testing. This restructuring could take 6-12 months, during which user attrition is a real risk. However, in the medium term, Path A could potentially recover and even surpass the appeal of the hold-to-earn era.

Path B: Keep Yield at the Protocol Layer, Transmitting to Users via Activity-Based Actions

Applicable to: DeFi protocols. The definition of "covered digital asset service provider" in Section 404 is clearly built around centralized intermediaries – yield generated by non-custodial smart contracts – for example, supplying USDC to Aave for variable rate lending – is designed to fall outside this definition.

This means users depositing USDC into Aave's lending pool to earn variable interest is currently considered compliant by most legal scholars – CLARITY seemingly unintentionally leaves a yield channel open for non-custodial DeFi.

However, this exemption carries significant uncertainty. If final rules extend the concept of "economically equivalent" to non-custodial DeFi, or define DeFi frontends as affiliates, the exemption for Path B could be substantially narrowed.

Path C: Pay Yield Through the Reserve Asset Layer

This is the path Wall Street asset management giants are betting on. The specific mechanism: The stablecoin issuer itself does not pay interest, DASPs do not pay interest, but the stablecoin's reserve assets are tokenized money market funds. The fund legally pays interest to its holder (the stablecoin issuer). The stablecoin issuer then retains this distributed yield as corporate profit – or partially passes it to users via designed active behavior rewards.

The key compliance advantage of this path: Its yield layer is not at the stablecoin layer or the DASP layer, but at the underlying fund layer – unrelated to the stablecoin regulatory framework.

These three paths are not mutually exclusive; they will evolve simultaneously.

Path A might find new life with players like Coinbase who possess retail brands and distribution channels;

Path B might receive an unexpected boost for protocols like Aave and Pendle (albeit with tail risks of regulatory tightening over the next 12 months);

Path C is the path least directly threatened by Section 404, but requires the OCC's 20% cap not to pass as a precondition.

Path C is the "most resiliently beneficial" compliant yield layer, but not the "only beneficial" one.

This is why Wall Street asset management giants concentratedly filed for tokenized money market funds in April-May. They are providing one piece of the compliant yield infrastructure for the use-to-earn paradigm about to be solidified by CLARITY Section 404. Considering the implementation costs and regulatory uncertainties of Paths A and B, Path C offers the strongest risk-adjusted attractiveness – this is the industry judgment of BlackRock and its peers.

2.4 The Collaborative Relationship Between Path B and Path C

There seems to be potential for collaboration between Path B and Path C. A complete on-chain yield system could utilize both paths simultaneously:

The reserve asset layer uses BUIDL – ensuring a compliant yield source.
The user layer uses Aave lending or Pendle yield splitting – ensuring the "yield" perceived by users originates from active operations.
This dual-layer structure of "BUIDL at the bottom, DeFi protocols on top" could theoretically build a use-to-earn system that is both compliant and user-friendly. BlackRock likely did not specifically foresee Section 404 when launching BUIDL, but this product perfectly becomes the optimal underlying layer for the use-to-earn system under the new paradigm.