Written by Lee Da Zhuan | Edited by Josh Lee Kok Thong
We’re all law and tech scholars now, says every law and tech sceptic. That is only half-right. Law and technology is about law, but it is also about technology. This is not obvious in many so-called law and technology pieces which tend to focus exclusively on the law. No doubt this draws on what Judge Easterbrook famously said about three decades ago, to paraphrase: “lawyers will never fully understand tech so we might as well not try”.
In open defiance of this narrative, LawTech.Asia is proud to announce a collaboration with the Singapore Management University Yong Pung How School of Law’s LAW4032 Law and Technology class. This collaborative special series is a collection featuring selected essays from students of the class. Ranging across a broad range of technology law and policy topics, the collaboration is aimed at encouraging law students to think about where the law is and what it should be vis-a-vis technology.
This piece, written by Lee Da Zhuan, critically examines whether the present regulatory picture in Singapore presents a clear framework to govern the phenomenon of “stablecoins”.
As its name suggests, stablecoins have been held to be a form of cryptocurrency which are designed to function as the composition of some value which attempts to stay stable with traditional currencies or its underlying assets. Given its recent hype in Singapore as being the cryptocurrency which generates exceptional returns with significantly lower risk vis-à-vis other cryptocurrencies, an important question arises as to whether our current legislations presents a clear framework to regulate these cryptocurrencies. This paper examines this question by adopting the following approach. Part II provides a primer to stablecoins and its different classifications used today. Heralding on the information from part II, part III evaluates that the scope of coverage found in the current Payment Service Act is insufficient to cover various different classes of stablecoins. Part IV concludes with possible recommendations. It is the author’s hope that the findings presented from this paper would present an overview of the lapses of the Payment Services Act concerning the governance of stablecoins.
The concept of “cryptocurrency” is familiar to many. Indeed, with its highly volatile price fluctuations, cryptocurrency has been widely known amongst persons to result in almost exclusively two outcomes: converting a person from literal rags to riches, or from literal riches to rags. Along with the impact of COVID-19 and consequently its stay-home measures resulting in persons probably having too much time for their own good, it comes as no surprise that we would see such a huge proliferation in that virtual currency.
With its proliferation, however, comes risks. Indeed, cryptocurrency generally is mired with dangers: from money-laundering and terrorism financing concerns to financial risks (as very clearly visible with its ability to turn one from riches to rags), regulation was needed to control its possibly catastrophic adverse consequences. Consequently, with the enactment of new legislation (such as the Payment Services Act (“PSA”)) on part of the Singaporean government, the problems faced by the use of such cryptocurrencies were generally addressed.
However, like the proverbial phoenix, a relatively new player in the cryptocurrency has arisen from the ashes – that of “stablecoins”. This form of cryptocurrency has been defined as “a type of cryptocurrency that is designed to maintain a stable value, usually by a stable fiat currency, rather than experiencing significant price changes”. These stablecoins have recently been touted to give rise to exceptional returns with “significantly lower risk” – indeed, a person may now be exposed to “yield-farming” – the process of staking one’s stablecoins in return for much better interest rates as opposed to conventional bank rates.
However, a deeper analysis into stablecoins reveals complications. A central problem in the regulation of stablecoins is found in the many different classifications of stablecoins which may be distinguished by its design. Accordingly, stablecoins falling outside of the general definitions provided by the Singapore regulatory framework today may even be devoid of regulation. In facing these problems, the central question becomes: do current regulations in Singapore present a clear framework to govern stablecoins?
This article seeks to answer the question posed above. In doing so, the author will attempt to take a deeper dive into the realm of stablecoins and its possible legal implications in the context of Singapore. Part II provides a primer to stablecoins and its different classifications used today. Part III evaluates that the scope of coverage found in the current Payment Service Act is insufficient to cover various different classes of stablecoins. Part IV concludes with possible recommendations.
Stablecoins: A primer
Stablecoins have been defined by some proponents to be “a type of cryptocurrency that is designed to maintain a stable value, rather than experiencing significant price changes”. Other proponents have also attempted to define stablecoins as “a new class of cryptocurrency which offer price stability and/or are backed by reserve assets, combining the instant processing and security of payments of cryptocurrencies, and the volatility-free stable valuations of fiat currencies.”
Whilst there has yet to be a harmonised definition of stablecoins, it suffices to say that these digital coins are conceptualised to function as the composition of some value which attempt to stay stable with traditional currencies or its underlying commodities. This is in stark contrast to conventional cryptocurrencies, which are typically highly volatile. Given this contrasting function, stablecoins have played a fundamental role in the cryptocurrency market, due to its liquid trading pairs which are quoted in stablecoins.
Despite its similarities in concept, there are in fact stablecoins which are different by design. Stablecoins may be split into four major types: fiat-collateralised stablecoins; commodity-collateralised stablecoins; crypto-collateralised stablecoins; and algorithmic (or non-collateralised) stablecoins. The nature of each form shall be discussed in turn.
Perhaps the most common form of stablecoin are coins which are collaterised by fiat currency. As its name suggests, stablecoins of this form are usually pegged to fiat currencies, such as the United States Dollar or the Euro, and are usually backed at a 1:1 rate. This means that for every stablecoin owned, there is an equivalent amount of fiat currency that is held which backs that said stablecoin. The peg to the fiat currency, on the other hand, operates as how any fiat or asset would operate. That is, a centralised institution, such as a central bank of a country, would monitor its currency exchange rate relative to the dollar’s value. Should the currency fall below or rise above the peg, the central bank would be responsible for raising the currency’s value. Owners of such stablecoins may readily exchange these coins for a claim of the equivalent fiat currency from an exchange at any particular time.
Besides the conventional fiat-backed stablecoins as explained, stablecoins may also be pegged to a bundle of currencies. Persons may find such stablecoins more attractive to the single-fiat backed stablecoins since the premise of pegging such cryptocurrencies to a bundle of currencies presents the benefit of shielding the stablecoins from any possible crashes from one particular country or currency. An example is Saga (SGR), a recently discontinued stablecoin which was pegged to the International Monetary Fund’s special drawing rights, comprising of a basket of world currencies which are curated by the international organisation. Saga’s discontinuance should not deter one from understanding the intricacies behind stablecoins of such a nature. Indeed, it has been suggested by Facebook’s representatives that its highly anticipated Diem Coin (formerly known as Libra) will also be a stablecoin pegged to a basket of currencies. Given Facebook’s international outreach, one may suggest that the potential popularity of the Diem Coin could lead to the mainstream use of such stablecoins.
As its name suggests, commodity-collateralised stablecoins are cryptocurrencies which are backed by commodity assets such as precious metals. These said assets are in turn stored by a trusted third party. Holders of such stablecoins are typically able to redeem these coins for real assets at a specific convertible rate, suggesting its otherwise liquid nature. Unlike purchasing stablecoins pegged to fiat currencies, purchasers of commodities-backed stablecoins have the potential to earn on the potential appreciation in value of the commodities in the stablecoins they are investing, whilst yet maintaining a rather certain value. This is consequently an added incentive to hold such stablecoins as opposed to fiat-backed stablecoins. A clear example of these stablecoins is the PAX Gold Stablecoin (PAXG),which is a stablecoin backed by gold.
Crypto-collateralised stablecoins, on the other hand, are stablecoins which are pegged to other cryptocurrencies as collateral. A huge difference between crypto-collateralised stablecoins with the other stablecoins described above lies in the volatility of the cryptocurrencies in which the stablecoin is pegged to. Due to the instability of value in such cryptocurrencies, protocols and rules are usually instituted to ensure that the price of such stablecoins is maintained at the value in which it is claimed to be pegged to. One such protocol would be that of over-collateralisation, where issuers of such stablecoins would usually hold a 2:1 value of cryptocurrencies in place of the price of the stablecoins to guard against the volatility of the said cryptocurrencies.
An advantage of such stablecoins lies in its transparency. As everything occurs on the blockchain, crypto-backed stablecoins have open-source codes, and can be operated under a decentralised system – unlike fiat-backed and commodities-backed stablecoins. A common crypto-backed stablecoin would be DAI, which is pegged to the US Dollar, but collateralised by Ethereum. Another example of a crypto-backed stablecoin would be Money on Chain (BPro), which is pegged to the price of Bitcoins, and which value may be translated accordingly into the value of the said Bitcoins in which they are pegged to.
Algorithmic or non-collateralised stablecoins
Algorithmic stablecoins, unlike all the above stablecoins, differ mostly in that it is not backed by a collateral. Rather than holding collateral, these stablecoins would take advantage of total supply manipulations to maintain a pegged value. In simplified terms, these stablecoins functions like a central bank – it defends its peg directly in the market, offering or selling its coins in the event of a price drop or wherein its price increases beyond the specified asset in which it is pegged to. A stark difference, however, lies in the fact that there is no real centralised institution – that is, no “central bank”, defending that said peg. Rather, these stablecoins would take advantage of algorithms to execute smart contracts which issues more coins when prices increase, and buying these coins off the market when its price falls. Hence, there exists a decentralisation of decision-making responsibilities for such stablecoins, and an absence of an issuer that is responsible for satisfying an attached claim to such stablecoins. Examples of such a stablecoin is the Ampleforth coin (AMPL), which is pegged specifically to the value of the 2019 US Dollar, or the NuBits coin, which is also pegged to the US Dollar.
The next Part assesses the adequacy of the PSA in Singapore vis-à-vis these cryptocurrencies.
Does the PSA sufficiently cover stablecoins?
The rise of cryptocurrencies warranted the introduction of specific legislation to combat against possible risks prevalent in its use. Amongst all regulations, the most relevant to cryptocurrencies is found in the recently enacted PSA. The next few paragraphs briefly introduce the PSA .
Recognising the different traits of cryptocurrencies, the PSA provides legal clarity in classifying cryptocurrencies as either “e-money” or “digital payment tokens”.
“E-money” is defined as electronically stored monetary value that (a) is denominated in any currency, or pegged by its issuer to any currency; (b) has been paid for in advance to enable the making of payment transactions through the use of a payment account; (c) is accepted by a person other than its issuer; and (d) represents claim on its issuer.
“Digital payment tokens”, on the other hand, means any digital representation value (other than an excluded digital representation of value) that (a) is expressed as a unit; (b) is not denominated in any currency, and is not pegged by its issuer to any currency; (c) is, or intended to be, a medium of exchange accepted by the public, or a section of the public, as payment for goods or services or for the discharge of a debt; (d) can be transferred, stored or traded electronically; and (e) satisfies such other characteristics as the Monetary Authority of Singapore may prescribe.
Persons wishing to deal with the cryptocurrencies falling within the definition of the two expressions above, may in turn be regarded as payment service providers. Payment service providers under either definitions will attract different regulatory requirements. For example, for e-money based service providers, obligations stemming from the safeguarding of its customer’s monies would arise. Whereas, for digital payment token service providers, regulatory requirements imposed not only by the MAS but also international organisations like the Financial Action Task Force must be followed. This includes strict anti-money laundering and the countering of financing of terrorism obligations.
For the purposes of this paper, however, it suffices to elaborate that payment service providers wishing to conduct business with the said cryptocurrencies are required to obtain a license to carry on its business of providing any of the regulated payment service.
From this, it becomes relatively clear that in order for stablecoins to be regulated in Singapore, such said cryptocurrencies must consequently be categorised either as “e-money” or as a “digital payment token”. This is important, as whether stablecoins are comprehensively regulated would ultimately rely on whether they are properly classified within the boundaries of the laws which are enacted to govern them. Should such cryptocurrencies fall through the cracks of either definitions, the lack of regulation of these cryptocurrencies would pose a risk for consumers who are uninitiated to the risks of investing in cryptocurrencies. Having unregulated stablecoin providers operating in the market without a proper license issued under the PSA would also elevate concerns of money laundering and the financing of terrorism activities which the authorities have been attempting to solve.
With the rise of the different classes of stablecoins, it becomes necessary to test the definitions provided under the PSA to each form of stablecoins to determine if any such regulatory uncertainty would be caused. Specifically, the key question becomes: can all forms of stablecoins as defined above be classified distinctly as an “e-money” or “digital payment token”?
As introduced, fiat-collateralised stablecoins may be classified in two different forms: stablecoins which are pegged and backed by a single fiat currency, or coins which are pegged and backed by a basket of currencies. Unsurprisingly, regulations currently imposed by the PSA are sufficiently comprehensive to cover the former variation of stablecoins. Single fiat currency-collateralised stablecoins are well within the scope of ‘e-monies’: such stablecoins are denominated in a currency, are paid in advance to enable the making of payment transactions through the use of payment accounts, are accepted by persons in the market, and finally, adequately represent a claim on its issuer.
Considering that such stablecoins are denominated in a specific currency, it suffices to say that single fiat currency-collateralised stablecoins would not attract simultaneous regulations as “digital payment tokens” within the PSA. Hence, such stablecoins should not pose a huge problem in its regulation under the PSA.
It is, however, the multiple-fiat backed variation of the stablecoins that is not as certain. The definition of “e-money” under the current Act fails to accommodate for multiple-currency collateralised stablecoins. Such stablecoins, which are currency-collateralised, would also not fall within the definition of “digital payment tokens”.
There is uncertainty about the classification of commodities-collateralised stablecoins under the PSA. Taking PAXG as an illustration, the stablecoin may well be caught within the definition of “e-monies” only if gold is “currency” in within the PSA. Taking reference from the broad definition of “currency”, it is the case that extraterritorial notes and coins which are legal tender in territories or countries outside of Singapore can be considered as currency under the PSA.
Applying this to the Currency Act in Singapore, gold is not made explicitly legal tender in the country. Accordingly, it is unlikely the case that Singaporean regulators would treat gold as a currency within the meaning of the PSA. However, taking reference from jurisdictions which have explicitly made gold legal tender, such as the state of Utah,gold is made legal tender only in specific situations, such as when the said gold coins are issued by the US Mint. Uncertainties therefore arise in situations where stablecoins are backed by precious metals like that of PAXG. Considering that gold is not universally legal tender – should they otherwise be considered “currency” for the purposes of the PSA?
The uncertainties of labelling gold as a currency has a knock-on effect to its regulation under the PSA. As there is currently no clear answer as to whether gold can be labelled as a currency, it becomes unclear whether stablecoins such as PAXG ought to be regulated as “e-money”. Given the uncertainty of the definition of gold as a currency, forcing the said stablecoins to be regulated as a digital payment token is an approach that is neither here nor there as well. Pertinent problems would thus arise as to the manner in which commodities-backed stablecoins should be regulated under the PSA.
Some crypto-collateralised stablecoins may well fall under either definitions of “e-money” or “digital payment tokens” under the PSA.
DAI, for example, is a stablecoin which, whilst backed by cryptocurrencies, is both denominated and pegged to the US Dollar. Under the PSA, this would mean that DAI ought to be regulated under the said act as an “e-money”. The BPro coin, tokenised by the company Money On Chain, however, is a stablecoin that is backed by and pegged to Bitcoins. As it has been acknowledged by regulators in Singapore that Bitcoin is an example of a “digital payment token”, the BPro coin, although comprising of traits closer to the definition of “e-money” – in that it represents a claim on the issuer – may well be regulated as a digital payment token instead. Given the variation of such stablecoins, complexities may thus arise as to how crypto-collateralised stablecoins may be regulated. Indeed, given that the function of both DAI and the BPro coins are relatively similar – why should they be subjected to different regulations?
It remains unclear how algorithmic stablecoins are regulated under the PSA. Whilst some papers have suggested that algorithmic stablecoins may be subject to regulation under the PSA as a “digital payment token”, realities would suggest otherwise. Taking AMPL as an illustration, the stablecoin is pegged to the 2019 US Dollar, but is not backed by the issuer. With these traits, neither definition under the PSA adequately covers the AMPL coin. Indeed, as the AMPL coin is denominated in the US Dollar, the coin may not be classified as a “digital payment token” – however, given that the AMPL coin does not represent a claim on its issuer, such a stablecoin might not be classified as an “e-money” as well. Taking the explanations provided above, the same conclusion may also be reached when one uses the NuBits coin, which is also an algorithmic stablecoin akin to the AMPL coin, as a second illustration.
Implications and conclusion
This paper has attempted to shed light on the insufficiencies of the PSA as a form of regulation as regards complex technologies like the stablecoins. Indeed, given the varying classes of stablecoins, along with its different classifications and definitions, it has been demonstrated that the two definitions provided under the PSA are simply inadequate to govern against the rapidly changing innovations that is the stablecoin. Illustration A below presents a summary of the arguments expounded above:
|Are ___…||E-Money?||Digital Payment Tokens?||None?||Both?||Ultimate Result|
|Multiple fiat-backed stablecoins||X||Unregulated|
Illustration A: Are they E-Monies or Digital Payment Tokens?
Rather, the analysis of stablecoins above shows that the PSA only adequately covers single-fiat collateralised stablecoins, which may be properly classified as “e-monies”. However, as regards other stablecoin designs, there may either be uncertainties or gaps in the PSA.
However, the author recognises that other regulations may well serve as a backstop against such gaps. For example, for commodities-collateralised stablecoins, regulations and licensing requirements under both the Securities and Futures Act (“SFA“), as well as the Commodities Trading Act (“Commodities Trading Act“) could address the improper use of such stablecoins. Nevertheless, the author posits that the analysis of existing regulation from these statutes ought to be comprehensively studied on for another occasion. For now, it suffices to say that the regulation of stablecoins under the PSA could be insufficient to combat against its ever-evolving nature. Instead of clarifying the framework of regulation in Singapore, the PSA adds on to the SFA and CTA to present a confusing patchwork for the regulation of stablecoins today.
Perhaps the regulatory bodies in Singapore already appreciate the gaps in current regulations which are in place. This possibly explains the recent moves to enact a new omnibus financial services act for the regulation of all things financial in Singapore. From MAS’s consultation paper, it would appear that the intended omnibus act aims (among other things) to enhance MAS’s regulatory powers in relation to digital services across the financial sector. The omnibus act presents a huge opportunity for regulators in Singapore to address the issues highlighted above.
This piece was published as part of LawTech.Asia’s collaboration with the LAW4032 Law and Technology module of the Singapore Management University’s Yong Pung How School of Law. The views articulated herein belong solely to the original author, and should not be attributed to LawTech.Asia or any other entity.
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 See, eg, Crypto.com, available at: <https://crypto.com/sg/>, where investors staking stablecoins such as the USD Coin (USDC) may earn interests of up to 12% per annum; Hodlnaut, available at: <https://www.hodlnaut.com/>, where investors may earn up to 12.78% per annum staking their stablecoins.
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