华尔街的「合规围猎」：稳定币储备大迁徙

Original Author: Sanqing, Foresight News

In the past week, several Wall Street institutions have almost simultaneously pushed forward their tokenized money market fund plans. On May 12, JPMorgan announced the launch of its second tokenized money market fund, JLTXX, on Ethereum. On the same day, Payward, the parent company of Kraken, signed a strategic cooperation agreement with Franklin Templeton, planning to integrate the BENJI series of tokenized funds into the Kraken platform for use as institutional collateral and cash management tools.

Shortly before, BlackRock submitted applications for two more tokenized funds to the SEC, continuing to deepen its partnership with Securitize. This concentrated series of actions reflects that regulatory expectations are rapidly driving the supply-side layout of institutions.

Wall Street's Pincer Movement: From Custody Backend to Frontend Collateral

Facing the same regulatory directive, Wall Street giants are revealing their ambitions to absorb crypto liquidity from different angles.

BlackRock, the "king of scale," once again joined forces with its long-term partner Securitize to submit two new applications simultaneously: one is a "pure-blooded" tool, BRSRV, specifically designed to comply with the GENIUS Act and strictly limited to investing in short-term debt with a maturity of 93 days; the other is BSTBL, a tokenized share of its existing ~$70 billion government money market fund.

Given that it already manages approximately $65 billion in reserves for Circle, BlackRock is attempting to fully tokenize its massive traditional stablecoin custody business, downgrading the native issuers to "distributors" only responsible for front-end issuance.

Hot on BlackRock's heels, JPMorgan launched JLTXX (On-Chain Liquidity Token Fund). This product, running on its own Kinexys (formerly Onyx) platform and debuting on Ethereum, explicitly states in its prospectus that it is designed to meet the reserve needs of stablecoin issuers.

JPMorgan is eyeing the future banking pathway. As the GENIUS Act paves a clear path for banks to issue stablecoins, JLTXX is essentially preparing for the future, attempting to become the standard settlement and reserve backend when future G-SIBs (Global Systemically Important Banks) enter the stablecoin issuance space.

In contrast, Franklin Templeton's partnership with the crypto exchange Kraken steps outside the pure reserve thinking of the former two, aiming to bridge retail and collateral. The core of their cooperation is integrating BENJI (a tokenized money market fund) into Kraken as collateral for institutional trading and a cash management tool.

Since the future CLARITY Act might prohibit stablecoins from directly paying interest, tokenized assets like BENJI, which can both generate yield and serve as underlying collateral, cleverly bypass the yield ban on stablecoins when combined with Kraken's exchange, xStocks, and other client bases. Traditional asset management's reach extends directly into the collateral layer of native crypto trading.

Furthermore, during the same period, Morgan Stanley also launched the MSNXX fund to meet compliant reserve requirements, but it did not adopt any on-chain settlement technology. Under the same compliance framework, whether or not to utilize on-chain technology has become a key differentiator for competitive advantage among the giants. Simply meeting compliance is insufficient; the 24/7 liquidity and asset composability offered by on-chain settlement represent the true moat for the next generation of dollar reserves.

The GENIUS Act Defines a Market

On July 18, 2025, U.S. President Donald Trump signed the GENIUS Act. Section 4 of the Act provides a concise yet clearly defined list of "Qualifying Reserve Assets": Federal Reserve account balances, insured deposits, U.S. Treasury securities with a remaining or original maturity of 93 days or less, overnight repurchase agreements collateralized by such Treasury securities, and government money market funds that invest exclusively in the aforementioned assets.

For every dollar of stablecoin issued, it must be backed 1:1 by these assets, and issuers are prohibited from paying any interest or yield to holders. The rules are simple, but they establish a clear product boundary around "qualifying reserves."

Last June, Treasury Secretary Bessent told a Senate Appropriations subcommittee that a stablecoin market reaching $2 trillion "is a very reasonable number." Citigroup predicts a base case of $1.9 trillion by 2030 and an optimistic case of $4 trillion; Standard Chartered estimates that tokenized money market funds alone could reach $750 billion by then. Even under a conservative view, the "qualifying reserve" compliance threshold has already framed a demand pool worth trillions of dollars.

The implementation rules for the GENIUS Act must be finalized by July 18, 2026, and the Act must take full effect by January 18, 2027, at the latest. Rulemaking by regulatory agencies like the OCC and FDIC is intensively underway. The supply side cannot afford to wait until then to act.

The CLARITY Act is Another Piece of the Puzzle

The U.S. Senate Banking Committee is scheduled for a markup of the CLARITY Act on May 14. This Act complements the GENIUS Act. While GENIUS governs stablecoin issuance, CLARITY defines the boundaries of the digital asset market structure and the jurisdictional limits of the SEC and CFTC.

There is a critical interface between the two. The GENIUS Act prohibits stablecoins from paying interest to holders. The draft text of the CLARITY Act distinguishes between business incentives and passive income, potentially leaving room for yield generation by non-stablecoin tokenized assets.

This very firewall is what makes tokenized money market funds like BENJI an on-chain, yield-bearing cash management tool distinct from stablecoins. They are not stablecoins, so they are not subject to the yield ban, yet they can still settle in real-time, be used as collateral, and be transferred around the clock. The commercial logic behind Kraken integrating BENJI is built upon this gap in the regulatory framework.

Whether the CLARITY Act can proceed as scheduled will also determine the completeness of this commercial architecture.