MiCA 核准約 25 家，歐元穩定幣為何沒長大？

6:54:31開場：遠端連線談 MiCA 兩年

6:54:31好。現在可以了嗎？好，很好。大家好，午安，很抱歉剛才出了技術狀況。遠端參與本來就有這種風險。我其實很想親自到新加坡跟各位見面，原因有兩個：第一，我很喜歡新加坡。第二，這裡正在辦一場很大的活動，而且這個週末還有一場對我個人來說更大、更重要的活動，就是新加坡大獎賽。但沒辦法成行，所以我只能遠端跟各位連線。Right. Does it work now? Okay, very good. Hello, good afternoon to you all, and I'm sorry for the technical hiccup. That's always the risk if you... participate remotely. I would very much have liked to join you live in Singapore because, one, I love Singapore. Secondly, there is a very big event on, and there's even a more, a bigger event, a more important event to me personally on this weekend, which is the Singapore Grand Prix. But it wasn't, so I couldn't be there, so I'll have to join you remotely.

6:55:00歐盟穩定幣監管兩年了：這教了我們什麼？我認為，MiCA 規則裡穩定幣相關規定上路兩年之後，我們真的可以檢驗當初的理論、那些擔憂，還有當時的熱情。我們開始著手制定穩定幣監管、或者更廣義的加密資產監管，是 2019 年的事，因為確實就是那麼久以前開始的，那時候市場對穩定幣的熱情並沒有Two years of stablecoin regulation in the European Union: what does it teach us? I think that after two years of implementation of the MiCA regulation as regards its stablecoin provisions, we can really test the theory, the fears, but also the enthusiasm. And when we started off developing stablecoin regulation or crypto-asset regulation in general, back in 2019, because that's how long ago it is that we started developing this regulation, the enthusiasm for stablecoins wasn't

6:55:39那麼高，央行跟財政部尤其如此。我記得很清楚，2019 年春天，有一家不算大的公司，當時叫做 Facebook 的社群媒體公司，宣布要為社群媒體加上一套支付系統，而且要靠一枚穩定幣來做，就是 Libra。這在央行跟財政部之間造成很大的恐慌，他們覺得這真的有點脫軌，接著all that big, certainly not among central bankers and finance ministries. I remember very well that in the spring of 2019, a smallish company, a social media company by the name of then Facebook, announced its plans to power up social media with a payment system and to do that on the back of a stablecoin, Libra. This created a very big fear among central bankers and finance ministries, who saw this really as a bit of an aberration, and

6:56:19他們在 G20、也就是全球最大經濟體的場合做成決定：在穩定幣監管架構到位之前，任何全球穩定幣安排都不得開始營運。這就是我們從 G20 接到的指示，也是我們真正動手的起點。所以問題不是該不該禁止、該不該支持，而是該有什麼樣的監管架構，去框住風險、抓住they decided, in the context of the G20, the largest economies of the world, that no global stablecoin arrangement should start operating before a regulatory framework for stablecoins was in place. That really was the instruction that we received from the G20, and that's what really set us going. And the question, therefore, was not whether we should prohibit them, whether we should support them, but what kind of regulatory framework should we have to frame the risks and seize

6:56:59穩定幣所帶來的機會。現在世界各地也在仿效的穩定幣監管原則是：如果一樣東西宣稱自己穩定，這個承諾背後到底站著什麼？這是很重要的原則。背後是什麼資產？你怎麼確保持有人可以按面額贖回？因為贖回是一項重要原則。the opportunities that stablecoins engender. And the principle of stablecoin regulation that is now also being emulated across the world is that if something claims to be stable, what stands behind that promise? That's a very important principle. What assets stand behind it? How do you ensure the holder can redeem at par? Because redemption is an important principle.

6:57:26贖回之所以重要，是因為它是錨的保證：持幣人隨時可以回去找發行人，按面額把穩定幣的價值從發行人那裡拿回來。發行人因此負有重要負債，那麼誰來監督發行人？信心消失的時候會發生什麼事？這就是我參與制定的 MiCA 規則真正想做到的事。Redemption is an important principle because it is the guarantee of the anchor, the fact that the holder of the coin can always return to the issuer and get the value at par for the stablecoin back from the issuer. Because the issuer has important liabilities, therefore, who supervises the issuer? What happens when confidence disappears? And that is what the MiCA regulation, which I worked on, really tried to achieve.

6:57:51嚴格規則沒有掐死創新，也沒有做出大規模市場

6:58:03規則現在已經上路，我認為已經可以從這套規則得出三個結論。第一，它沒有掐死歐洲的穩定幣創新。雖然 MiCA 的要求其實相當嚴格，很多人覺得還不夠嚴，但我個人認為其實已經相當嚴。有一陣子，尤其是幾年前我們處在低利率環境的時候，外界很懷疑So we have this regulation in place now, and I think that we can draw three conclusions already from the regulation. First, it did not kill stablecoin innovation in Europe. Even though the requirements in MiCA are actually quite strict, a lot of people think that they are not strict enough, but I personally think that they are actually quite strict. And for a while, especially during the low interest rate environment that we were in a number of years ago, it was very debatable as to

6:58:39穩定幣商業模式能不能賺錢，因為發行人要怎麼從準備資產上賺到足夠的收入，去資助並營運這套系統？所以它沒有掐死穩定幣創新，但 MiCA 也沒有做出一個大規模的歐洲穩定幣市場，我必須說，那本來就不是預期。但它確實顯示一件事：監管明確是規模化的必要條件，但不是充分條件。whether a stablecoin business model could be profitable, because how could the issuer actually generate enough revenue on the reserve assets to finance and operate the system? So it did not kill stablecoin innovation, but MiCA also did not create a large European stablecoin market either, and that was never really the expectation, I must say. But what it does show is that it demonstrates that regulatory clarity is necessary for scale, but it's not sufficient.

6:59:15以穩定幣來看，歐洲在這件事上是一個很特殊的市場。這也可以用穩定幣目前的用途來解釋。我們看看全球，現存約 3,100 億、3,200 億美元規模的穩定幣，到底拿來做什麼？我們看到的主要用途其實有四種。最大的用途是加密貨幣交易的 on-ramp 與 off-ramp。Now, Europe is a very specific market in this case, if you look at stablecoins. And that also is explained by what stablecoins are currently used for. If we look across the globe as to what stablecoins, the 310, 320 billion dollars' worth of stablecoins that exist, what are they used for? Really, four main use cases we see. The main use is crypto trading on and off-ramp.

6:59:46所以交易加密資產、數位資產的人需要結算，而且常常用穩定幣結算；或者他們要退出波動市場、想轉到比較穩定的部位，因為他們要離開市場，或暫時不在市場裡，就會把部位換成穩定幣。這是我們看到最主要的用途。第二，我們看到相當數量的穩定幣用在匯款，往往跟移民金流有關。So people who trade crypto assets, digital assets, they need to settle, and often they settle in stablecoins, or if they move out of volatile markets and want to move into a more stable position because they're leaving the market or they're temporarily out of the market, they will turn their position into a stablecoin. That is the predominant use we see. Secondly, we see a fair amount of stablecoin use for remittances, often linked to migration flows.

7:00:19第三是跨境支付，尤其是銀行軌道不存在或不夠好的地方，有時甚至是國內支付，同樣是銀行軌道不存在或不夠好。第四種用途是在高通膨國家當通膨避險：那裡的人未必拿得到真正強勢的貨幣，像美元、歐元或其他強勢貨幣，因此會去找他們能拿到、最接近的替代品The third is for cross-border payments, especially where banking rails are non-existent or not satisfactory, sometimes even domestic payments where banking rails are non-existent or not satisfactory. And the fourth use for stablecoins is as an inflation hedge in high-inflation countries, where people do not necessarily have access to actually strong currencies like the dollar or the euro or other strong currencies, and therefore seek access to the closest proxy they can get access to

7:00:59也就是這些強勢貨幣的替代，而那往往就是美元穩定幣。因為在歐盟，沒有任何一個成員國有惡性通膨，因為我們的銀行軌道表現很好、可及性也高，跨境支付系統更是世界級的。又便宜又有效率。穩定幣所呈現的許多使用情境，在歐洲其實並沒那麼必要。of these strong currencies, and that are then often dollar stablecoins. Because in the European Union, no member state in the European Union has hyperinflation, because our banking rails are very performant and access to our banking rails are good, and our cross-border payment systems are of world class. They are cheap and efficient. Many of the use cases that stablecoins present aren't really all that necessary in Europe.

7:01:31這也解釋了目前歐盟穩定幣使用規模相對有限。所以歐洲也許有最完備的穩定幣監管架構，但怎麼想都沒有最完備的穩定幣市場。話雖如此，監管做出的是一個可投資的市場，而不是把市場關掉。And this explains the relatively limited size, for the time being, of stablecoin use in the European Union. So we may have in Europe the most elaborate regulatory framework governing stablecoins, but we do not have, by any stretch of the imagination, the most elaborate market for stablecoins. That said, regulation created an investable market rather than shutting it down.

7:01:59我們自己的資料也顯示，規則上路兩年後，歐盟目前有 25 家取得執照的穩定幣發行人，分布在 14 個國家。很多規模相當小，其實非常小，但大型的也在。當然最大的是 Circle，據點在法國，同時發行 USDC 和 EURC。不過法國其實有六家穩定幣發行人，盧森堡三家，荷蘭三家，馬爾他兩家，立陶宛And it shows, if we look into our own data, we currently have, two years after the implementation, 25 stablecoin issuers that are licensed in the European Union across 14 different countries. Many of them are quite small, actually very small, but the larger ones are also there. Of course, the largest is Circle, operating out of France, issuing both USDC and EURC. But France actually has six stablecoin issuers, Luxembourg has three, the Netherlands has three, Malta has two, Lithuania

7:02:19歐盟已有 25 家持牌發行人

7:02:39兩家，芬蘭一家，丹麥一家，德國一家，捷克一家，拉脫維亞一家，波蘭一家，冰島一家，葡萄牙一家，還有斯洛維尼亞，總共 25 家。這算成功嗎？那要看你怎麼定義成功。一個市場能支撐多少家不同的穩定幣發行人？市場上有很多發行人，發行的代幣也許是同一種貨幣計價，但不一定可互相替代，這對市場好不好？它們之間有匯率。has two, Finland has one, Denmark has one, Germany has one, the Czech Republic has one, Latvia has one, Poland has one, Iceland has one, Portugal one, and Slovenia, in total 25. And is this a success? Well, depends on how you define success. How many different stablecoin issuers can a market support? Is it good for a market that you have many different issuers that are issuing tokens that are maybe denominated in the same currency, but they are not necessarily fungible? They have exchange rates between them.

7:03:27這些匯率可能非常接近錨定值，但並不是完全一樣。所以我們有幾家較大的業者，也有一些較小的業者。但我們 European Commission 不是在做挑選贏家這件事，所以我們既不偏袒小業者，也不偏袒大業者。我們真的希望市場自己走完這段路，也祝大家在這件事上都成功。有意思的是，歐洲的穩定幣制度其實有兩種穩定幣。Now, these exchange rates may be very close to their peg, but they're not absolutely the same. So we have a few larger players, but also a number of smaller players. But we at the European Commission are not in the business of picking winners, so we're not favoring smaller players or we're not favoring bigger players. We really want the market to play out and wish everyone a lot of success on this. What is interesting is that our European stablecoin regime actually has two kinds of stablecoins.

7:03:55電子貨幣代幣與資產參考代幣

7:04:01一種是電子貨幣代幣，錨定某個國家的官方貨幣。另一種叫做資產參考代幣，是用商品、其他價值，或法幣組合來擔保的穩定幣。這當然是比照 Libra 的模式，因為 2019 年 Libra 最初提出時，本來要由一籃子貨幣來支撐。資產參考代幣這一類，在市場上完全沒有被採用。We have electronic money tokens, which are pegged to an official currency of a country. And then we have something which is called asset-referenced tokens, which are stablecoins which are backed by commodities or other values or combinations of fiat currencies. And this was modeled, of course, on the Libra model, because originally when Libra was proposed back in 2019, it was going to be supported by a basket of currencies. This category of asset-referenced tokens has seen no uptake at all in the market.

7:04:35到目前為止，沒有任何一家資產參考代幣發行人取得授權。這可能代表兩件事。要嘛是市場對這類穩定幣興趣有限，這是一種可能。第二種可能是，規範這些資產參考代幣的規則並不適合、或沒有對準市場，限制太嚴，這個市場發展不起來。這兩個答案哪個才對，還是兩個都對？There is not a single asset-referenced token issuer authorized. So far, this may indicate two things. Either it indicates that there is limited market interest in this kind of stablecoins. That's one possibility. And the second possibility is that the rules and regulations governing these asset-referenced tokens are not adapted or not suitable for a market. They are too restrictive for this market to develop. Which of these two answers is the correct one, or whether both of the answers are correct?

7:05:10這需要進一步研究，我們目前也把它放進 MiCA 檢討諮詢裡在看。這套規則確實會改變、或至少允許市場結構演變。目前我們的貨幣體系其實就是央行貨幣加上商業銀行貨幣，一個雙層體系。而穩定幣監管、或者講得更廣一點，代幣化貨幣監管，That's something that requires further study and that we are currently looking into as part of our MiCA review consultation. The regulation does change, or allows for market structure to evolve. Currently, our monetary system is really central bank money and commercial bank money, a two-tier system. And what stablecoin regulation or tokenized money regulation, to put it more widely,

7:05:39顯示的是：我們正逐漸從央行貨幣加商業銀行貨幣的雙層貨幣體系，走向一個貨幣多元宇宙，不同種類、不同形態的貨幣正在出現。有些人擁抱這個。有些人覺得這非常正面。有些人害怕。他們覺得這不是好狀況。shows is that we are moving gradually from a dual monetary system with central bank money and commercial bank money into a money multiverse, where different kinds and form factors of money are emerging. Some people embrace this. Some people think this is extremely positive. Some people fear this. They think that this is not a good situation.

7:06:08尤其是央行官員習慣偏好央行貨幣加商業銀行貨幣的雙層貨幣體系，未必喜歡其他種類、其他形態的貨幣出現。他們喜歡或不喜歡，市場會不會跟著走，又是另一個問題，因為穩定幣就算不被喜歡、不被支持，也不代表它不存在。你可以看到市場力量可以很強，我們 European Commission 希望承認這一點。In particular, central bankers have a habit of preferring the two-tier monetary system with central bank money and commercial bank money, and do not necessarily like other kinds of money or form factors of money to emerge. Whether what they like or dislike will also be followed by the market is another question, because it's not because stablecoins are not necessarily liked or supported that they do not exist, and you see market forces can be quite powerful, and we at the European Commission want to recognize this.

7:06:46但它也改變市場結構，意思是監管架構特別能讓機構採用。機構使用者不會去碰監管邊界之外的金融工具或貨幣形態。所以如果你要機構採用穩定幣，就需要一套包住它的監管架構。它也讓你可以從你的But it also changes market structure in the sense that it allows, a regulatory framework allows, in particular for institutional adoption. Institutional users are not going to engage with financial instruments or money form factors that are outside of the regulatory perimeter. So if you want to have institutional adoption of stablecoins, you need to have a regulatory framework around that. It also allows you to exclude from your

7:07:08USDT 未在歐盟取得授權

7:07:19市場排除那些不符合規定的穩定幣、那些貨幣市場工具，歐盟已經這樣做了。事實上，全球最大的穩定幣 USDT 在歐盟並未取得授權。我們沒有禁止任何東西。當事公司選擇不去申請執照，那是他們的權利。但當然，自己選擇不申請執照、在歐盟沒有授權，當然會有後果：因此這個產品也就不能在歐盟行銷。market those stablecoins, those money market instruments that do not comply, and we have done that in the European Union. Actually, the largest stablecoin in the world, USDT, is not authorized in the EU. We did not prohibit anything. The company in question chose not to seek a license, and that's their good right. But of course, not seeking a license, not being authorized in the EU by their own choice, has of course consequences: that therefore the product can also not be marketed in the European Union.

7:07:59這當然會有市場結構、市場上的效果。但如我所說，這套規則運作得不錯，符合預期。我覺得很有意思的是，你看 MiCA 規則，再看例如美國的 GENIUS Act，它也涵蓋穩定幣，實質內容非常、非常相似。我幾乎要說其中一個在抄另一個，GENIUS Act 很大程度上是在抄 MiCA。律師們通常不同意我。And that, of course, has market structure, market effects. But as I said, the regulation is working well. It's working as expected. What's quite interesting to me is that if you look at the MiCA regulation and then, for example, the GENIUS Act in the United States, which also covers stablecoins, in substance they are very, very similar. I would almost say that one plagiarizes on the other, that the GENIUS Act very much copies MiCA. Lawyers tend to disagree with me.

7:08:46他們看到有細微差異，而且這些差異很有意義。我個人並不認為這些差異那麼重大、那麼有意義。但有意思的是，即使法律本質上是一樣的，至少依我的讀法是這樣，兩邊司法管轄區對待穩定幣的態度卻很不同。大致上，歐洲國家跟歐洲央行想要限制They see that there are subtle differences and that these differences are very meaningful. Personally, I do not think that these differences are all that significant or very meaningful. But what's interesting is that even though the law is in essence the same, at least in my reading, the approach to stablecoins is very different between the two jurisdictions. By and large, European countries and European central banks seek to limit

7:09:19穩定幣的使用。這是對是錯，目前仍是開放的。我們 European Commission 在這件事上保持中立。如我所說，我們不挑選贏家。規則在那裡，但某些主管機關顯然希望限制穩定幣使用。在美國你看到的是相反的。規則實質上相同，這些規則卻被用來推廣穩定幣、支持穩定幣使用，我其實覺得很有意思。stablecoin use. Whether that's the right approach or the wrong approach, that remains open. We at the European Commission are neutral on this. As I said, we do not pick winners. The regulation is there, but there's a clear desire from certain authorities to limit stablecoin use. And in the United States, you see the opposite. While the rules are effectively the same, these rules are used to promote stablecoins and to support stablecoin use, which I find actually quite interesting.

7:09:58美國境內的穩定幣使用到底佔多少，如果我們再看全球市場，也還有爭議。歐盟跟美國都有完備的穩定幣規則，但穩定幣的使用，包括美元穩定幣，其實大多發生在歐盟跟美國之外。但如果看整體資料，以歐元計價的穩定幣目前其實相當有限，到今天約 7.5 億歐元。7.5 億歐元，用貨幣規模來看，只是四捨五入的誤差。How much of the stablecoin use in the U.S. is domestic is also debatable if we really look at, again, global markets. Both the EU and the U.S. have elaborate rules on stablecoins, but most of the use of stablecoins is actually, including dollar stablecoins, is actually outside of the EU and outside of the United States. But if we look at the data overall, we see euro-denominated stablecoins are actually quite limited at 750 million euros to date. 750 million euros is, in monetary terms, a rounding error.

7:10:22歐元穩定幣規模小、週轉較快

7:10:36這真的不算什麼。看全球穩定幣市值，這些數字大家都知道：我們大概在 3,000 億美元以上的穩定幣規模。所以 99%、超過 99%、99.5% 的市場是美元計價。但市值只是一項指標。你還得看交易量。這些幣多久動一次？週轉速度是多少？這裡我們看到，歐元穩定幣的週轉率非常高。It really doesn't represent very much. If we look at the global market capitalization of stablecoins, well, these are well-known figures: we're somewhere above 300 billion U.S. dollar worth of stablecoins. So 99%, more than 99%, 99.5% of the market is dollar-denominated. Yet market capitalization is only one indicator. You also have to look at trading volumes. How often do these move? What is the velocity of the movement of the coin? And here we see that the euro stablecoins have a very high velocity rate.

7:11:19所以歐元穩定幣的交易量、成交量其實相當高，週轉也高於美元穩定幣，這表示不少美元穩定幣其實是被當成價值儲存來持有，遠多於當成支付工具或交易工具。監管的存在是為了提供安全、穩妥、健全，去支撐市場。但監管做不到的是創造流動性。它創造不了通路。它創造不了網路效應。So trading volumes, transaction volumes in euro stablecoins are actually quite high and are higher than the velocity of dollar stablecoins, which suggests that a number of those dollar stablecoins are actually held as a store of value much more than as a means of payment or a means of transaction. But regulation is there to provide safety, security, soundness to support the market. But what regulation cannot do is create liquidity. It cannot create distribution. It cannot create network effects.

7:11:59它創造不了全球交易對。它創造不了讓人非用不可的使用情境。那真的得由市場來決定。這裡我們看到，市場明顯偏好美元穩定幣，不是因為美元比較好。依我看，美元並不是比歐元更強的貨幣。我個人認為歐元是比美元更好的貨幣。當然，你們會預期我這樣想。但人們最後用的，不總是最好的。人們用的是別人在用的。It cannot create global trading pairs. It cannot create a compelling use case. That really is for the market to determine. And here we see that there is a clear preference for dollar stablecoins, not because the dollar is better. In my view, the dollar is not a stronger currency than the euro. I personally think that the euro is a better currency than the dollar. Of course, you would expect me to believe that. But it's not always what is best that people end up using. People use what other people use.

7:12:36網路效應比哪一種貨幣更好、更扎實、更健全更重要。針對人們想拿它來做的那些用途，網路效應是什麼？我們也看到量在快速成長，雖然去年聽到的預測是穩定幣發行規模會成長到 3 到 4 兆美元。當然有可能，但我們離那條軌道還差很遠。The network effects are more important than what is actually a better, more solid, more sound currency. What is the network effect for the uses that people want to make of it? What we also see is that volumes are growing fast, although the projections that we heard last year that stablecoin issuance would grow to three to four trillion U.S. dollars. It is, of course, possible, but we are nowhere near to be on that trajectory.

7:13:06看過去八個月，全球穩定幣市值幾乎是一條平線，所以進度不快。歐元穩定幣在成長，美元那邊則差不多走平。我們也看到，雖然交易量在增加，性質上並不足以把我們帶到 3 到 4 兆的那些預測。兆。機構採用穩定幣能不能把我們帶到那裡，目前仍是開放問題。If we look at the last eight months, we see an almost flat line when it comes to global market capitalization of stablecoins, so we're not progressing very fast. The euro stablecoin is growing, but dollar is kind of flatlining. And we also see that while transactional volumes increase, it is not really of a nature to bring us to these forecasts of three to four trillion. trillion. Whether institutional adoption of stablecoins will get us there, that remains an open question.

7:13:46但如果那些目標，那不是我們的目標（那是民間部門的估計），如果要達標，而且到 2030 年必須達到 3 到 4 兆美元的市值，那市場必須很快開始加速，否則依我個人看法，那些目標不會達成。這是好事還是壞事，我沒有判斷。這真的是市場、市場想要什麼的問題。But if those targets, which are not our target—these were private sector estimates—are to be met, and three to four trillion U.S. dollars of market capitalization has to be reached by 2030, then the market would have to very quickly start picking up, because otherwise those targets will, in my personal view, not be met. Whether that's a good thing or a bad thing, I have no judgment on. It is really what the market, what the market wants.

7:14:19另外有意思的是，你看這套監管，我們的經驗是：穩定幣監管裡最無聊的某些部分，其實所有穩定幣監管都相當無聊，因為處理的是非常艱澀、一點都不好玩的題目，卻變成政治上最有爭議、政治上最緊繃的。其中一個當然是按面額贖回，這到底怎麼運作？受監管發行人的可辨識程度如何，準備金的保全怎麼運作？What's also interesting, if you look at the regulation, the experience which we have is that some of the most boring parts of stablecoin regulation—actually, all stablecoin regulation is actually quite boring, because it deals with very turgid, not very exciting subjects, have become the most politically disputed and politically most tense. One was, of course, the redemption at par, and how does that work? How identifiable the regulated issuer is, how does the safeguarding of the reserves work?

7:15:05準備金的流動性標準是什麼？穩定幣發行人的贖回復原規劃是什麼？治理是什麼？監理是什麼？這些都是極其無聊、極其乏味的題目，而且重要的是，對這些要求不要太過興奮，因為興奮不是好政策的好指南。穩定、韌性、不要讓自己負擔過重，依我自己的看法，才是邁向好政策的更好指南。這不代表一切都定案了。What liquidity standards do you have for the reserves? What is the redemption recovery planning of a stablecoin issuer? What's its governance? What's its supervision? These are all extremely boring and tedious subjects, and it's important that there's not too much excitement about these requirements, because excitement is not a good guide for good policy. Stability, resilience, not overburdening yourself is a much better guide towards good policymaking, in my own views. That doesn't mean that everything is settled.

7:15:47我提過，我們有一場進行中的諮詢，不過剛結束，是關於 MiCA 以及下一步該做什麼。在那裡面，我們提出問題，人們也評論：我們現有的準備金要求，也就是 30% 到 60% 的準備金必須放在銀行存款，這一條要不要維持。有一些人認為，要求穩定幣準備金放在銀行存款有重大風險，We, I mentioned, we have an ongoing consultation, but just closed, about MiCA and what we should do as a next step. And in that, we raise questions and people make comments as to whether or not the reserve requirement, which we have, that 30 to 60 percent of the reserves have to be held in bank deposits, whether it has to be maintained. There are a number of people who see significant risks with this requirement to have stablecoin reserves in bank deposits,

7:16:19因為這會在銀行體系跟穩定幣體系之間做出一條傳染通道。但也許未來這兩套體系會匯流，那樣的話這條傳染通道也許就不那麼重要。另一場辯論，也是在美國鬧得很兇、最後某種程度上讓辯論沉下去的那場，because it creates a contagion channel between the banking system and the stablecoin system. But maybe in the future these two systems converge, in which case this contagion channel maybe is less important. The other debate is one which is also a debate that was raging and ultimately partly sunk the debate in the U.S.

7:16:44是 CLARITY Act 上關於穩定幣報酬的問題：穩定幣該不該被允許附帶利息，或者穩定幣或加密資產服務業者該不該被允許對穩定幣支付利息或獎勵。目前在歐盟這是禁止的，雖然當時並沒有真正積極辯論過。回到當時，2019 年我們提出 MiCA 的時候，很明確是希望不要讓市場負擔過重、也不要推得太快，所以我們想要限制。on the CLARITY Act was remuneration on stablecoins, whether stablecoins should be allowed to carry interest, or whether stablecoin or crypto asset service providers should be allowed to pay interest or rewards on stablecoins. Currently in the EU, this is prohibited, although it was never really actively debated. Back at the time, back in 2019, when we proposed MiCA, there was a clear desire not to overburden the market, not to promote the market too quickly, so we wanted to restrict.

7:17:19或者說立法者想要限制這個市場、讓它冷靜下來，因此我們不想用獎勵來推廣穩定幣。現在這場辯論出現了，所以我們需要再辯一次，我們也看到意見非常分歧，穩定幣獎勵到底是好事還是壞事。但如果你不直接給穩定幣獎勵，我們確實看到規避效果。Or the legislator wanted to restrict this market to calm it down, and therefore we did not want to promote stablecoins by having rewards. Now there is this debate, so we need to have this debate again, and we see opinions being very varied as to whether stablecoin rewards are a good thing or a bad thing. But if you do not reward stablecoins directly, what we do see is circumvention effects.

7:17:42我們看到人們於是把穩定幣從不能發獎勵的受監管領域，搬到不受監管的 DeFi 領域，用 DeFi 放貸協議去做 yield farming。這是我們對監管總會看到的事：你監管一件事，然後就像打地鼠一樣，問題會在監管邊界之外的某處冒出來。簡而言之，這就是我們到目前為止、MiCA 上路兩年在穩定幣上的經驗。We see that then people take stablecoins out of the regulated field, where they cannot pay rewards, and into the unregulated field of DeFi with DeFi lending protocols that then provide yield farming. And that is something which we always see with regulation, is that you regulate one thing and then, like a game of whack-a-mole, the issues emerge somewhere outside of the regulatory perimeter. I think this, in a nutshell, is our experience so far with MiCA two years in, when it comes to stablecoins.

7:18:19我認為可以公平地說，用一句話總結：在穩定幣這件事上，MiCA 正按照它被設計的樣子、也按照預期在交付成果。設計對不對，是 MiCA 檢討要處理的問題。非常感謝。I think it is fair to say, to sum it up in one sentence, that when it comes to stablecoins, MiCA is delivering as it was designed and as it was expected to deliver. Whether the design was right is an issue for the MiCA review. Thank you very much.