Upcoming CGP: Increase target level of stable holdings in the reserve

Hello @Tobi and @Pinotio.com - I wanted to add a couple of thoughts regarding this proposal.

One thing I think warrants discussion is that the spreadsheet assumes that DAI will hold its peg in a Crypto Crash scenario. I think it may be worth examining the assumptions behind this.

DAI and USDC will hold its value in a Crypto Crash - I think its important to think about the different causes of the potential crypto crash that we are worried about. If it is caused by a general risk-off sentiment that is triggered by equity sell-off and leveraged position liquidations, I think this assumption is likely to hold true.

However, I think the biggest risk that cStables need to guard against is a “bank-run” scenario on stablecoins caused by a loss of confidence. While it may never happen, if one of the larger stablecoins, such as USDT, were to experience a material depeg event, that would likely lead to a large crypto crash. In that scenario, I think it would be very important that the backing for cStables is simple and straightforward to understand.

Its not a given that USDC or DAI will be “fine” if USDT depegs. For example, while USDC is certainly considered to be safer than USDT, it is unclear what kind of liquidity risk Circle is taking with the reserve assets. Even if there was a 1:1 backing of reserve assets for USDC, a sudden demand for liquidity in of itself can cause USDC to depeg because these assets cannot be liquidated quickly enough. If Circle is keeping its assets in banks, even if the banks are FDIC insured, Circle is imposing credit risk of the bank on to USDC holders. Its the classic distinction between solvency vs liquidity.

In banks, there is extensive regulation to safe guard against both types of risk. Solvency requires the bank to hold certain types of assets. Liquidity regulations such as LCR requirements (Liquidity Coverage Ratio - ACT Wiki) ensure that banks can meet liquidity requirements even in extremely stressed scenarios. It seems like most of the debate surrounding centralised stablecoins has focused on the solvency part of the question but has largely ignored the liquidity part.

DAI inherits all of USDC’s risk and introduces additional complexity. Liquidations occur on a vault level and not on the overall collateralization level. Even if overall collateralization looks “safe”, a large account can trigger cascading liquidations.

In short, I think the risk of adding DAI or USDC is increased complexity. The current stablecoin landscape (and DeFI in general) is starting to look a bit like the CDO, CMO market in 2007, when products were being packaged together to create increasingly complex derivatives.

Of course there are benefits to adding stablecoins to the reserve as mentioned above, but I think it is worth examining the increased risk in worst-case scenarios.

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