Why this report matters

This second part examines the implications of the CLARITY framework for DeFi and examines the investment case for potential winners and losers if the act is implemented (see the first part here and our report from January 18). While there are clear structural beneficiaries, the outcome is not limited to a single winner. At the same time, investors should remain mindful of the emerging headwinds that could shape the broader landscape.

The latest CLARITY proposal effectively ends the stablecoin-as-savings-product narrative. While revenue sharing remains permitted, passing yield on to end users is effectively prohibited. Coinbase can continue to monetize USDC, but it loses its most powerful growth lever, offering yield to users, thereby representing a structural headwind for its distribution model. At the same time, Circle now bears the burden of demonstrating that its arrangements constitute legitimate profit-sharing rather than yield circumvention, introducing increased legal risk, potential contract restructuring, and ongoing regulatory scrutiny.

At its core, this is about control over money markets. Stablecoins are being defined strictly as payment instruments rather than interest-bearing assets, effectively ringfencing yield within banks and regulated vehicles such as money market funds and ETFs (e.g., IQMM). This represents a clear re-centralization of yield.

USDC Outstanding (LHS, $bn) vs. USDC Volume (RHS, $ bn)