Liquidity and money-ness · simulator

Build a Stablecoin

Choose the issuer's reserve assets and the holder's claim. The map places the resulting balance sheet among the familiar forms of private money: fully reserved instruments, money market funds, bank deposits and unbacked tokens. Liquidity is measured with the parameters of the Basel Liquidity Coverage Ratio (LCR); a regulatory panel then tests the same balance sheet against one stablecoin regime at a time.

Version 1.0, 7 October 2026. Issuer data: USDT as at 30 June 2026, USDC as at 31 August 2026. Regulatory texts checked on 7 October 2026.

Liquidity map

Position of the balance sheet on the liquidity map

    Horizontal axis: liquid assets after LCR haircuts and caps (plus central bank lending when the lender of last resort is on), as a share of liabilities redeemable on demand. Rows: the holder's claim. Numbered points: reference balance sheets, on their own resources. For the bank deposit, the arrow runs to its position with central bank lending at the discount set below; deposit insurance changes stress-outflow coverage only, so it does not move the point. Gold point: the balance sheet built below.

    Safety net

    Applies to bank deposits. For tokens redeemable at par it runs as a counterfactual.

    Lowers expected run-off: retail 10% to 5%, corporates 40% to 20%. Changes stress-outflow coverage, not the position on the map.

    Lends against loans and debt securities at the discount below. Moves the position on the map.

    Assets · reserves

    relative weights, normalised to 100%
    L1 · Level 1, no haircut2A · 15% haircut2B · 50% haircutH · simulator assumption— · not a liquid asset
    0%

    "Sovereign" means the sovereign or central bank of the stablecoin's reference currency, with a 0% risk weight. The LCR puts such debt in Level 1 at any maturity; LCR30.40 lets supervisors haircut it for interest-rate risk.

    Liabilities · tokens

    Holder's claim

    No effect on the liquidity figures; changes the regulatory check.

    Issuer equity (% of assets)
    2.0%

    Regulatory check

    Reserve eligibility, deposit floors, yield and redemption terms for the balance sheet above, under one regime at a time.

    A simplified test of composition and terms, not a compliance assessment or legal advice. It does not check licensing, custody, segregation, disclosure, capital or concentration limits. Every regime requires reserves in the reference currency and at least equal to tokens outstanding; the simulator assumes both.

    Method, assumptions and sources

    What is measured. A promise to redeem at par is credible only if the issuer can honour it without selling assets at a discount. The simulator measures this with the Basel LCR, which grades assets by their capacity to raise liquidity under stress (LCR30) and liabilities by the share expected to run off over 30 days of stress (LCR40).

    1. Liquid assets after haircuts = Level 1 + 85% of Level 2A + 50% of Level 2B, with Level 2 capped at 40% of the stock and Level 2B at 15% (LCR30.31, 30.33–30.36). The caps use the adjustment formula in LCR30.38–30.39.
    2. Full-redemption coverage = liquid assets ÷ liabilities redeemable on demand. At 100% or more, every holder can redeem at once without a forced sale.
    3. Stress-outflow coverage = liquid assets ÷ (outflow rate × liabilities redeemable on demand), the LCR analogue. Above 100% without full coverage, the issuer relies on not everyone redeeming at once: bank-style liquidity transformation.
    4. Safety net, in two parts. Deposit insurance acts on liabilities: it cuts the retail outflow rate from 10% to 5% and the corporate rate from 40% to 20% (LCR40.7, 40.41), leaving financial holders at 100%. It changes stress-outflow coverage but not full-redemption coverage, which already assumes every holder redeems. LCR40.7 also requires an established relationship or a transactional account, and LCR40.10 says insurance alone is not enough; the switch assumes these conditions are met. The lender of last resort acts on assets: it lends against loans and debt securities that are not liquid assets, at the discount set on the slider, and so moves the position on the map. Both apply to bank deposits. For tokens redeemable at par they run as a counterfactual, and the verdict shows the result with and without them.

    Order of the presets. The two issuer presets come first. The illustrative ones run from least to most money-like as the instruments work in practice: no redemption claim, then fund shares at portfolio value, then claims at par, with insured bank deposits at the top because the safety net keeps them at par. That order is a judgement about practice, not an output of the simulator. The map shows the other side: each balance sheet's own liquidity, where a bank deposit sits far to the left.

    Verdicts. The verdicts use no regime's legal labels. A par token whose liquid assets cover every claim is sovereign-backed, fully liquid when the backing is only central bank reserves, sovereign debt of one year or less and overnight sovereign repo. It is fully liquid when full coverage also relies on bank deposits, fund shares or longer sovereign debt. Fund shares redeemed at portfolio value are compared with US money market funds. The government-fund test applies the asset types in 17 CFR 270.2a-7(a)(14): 99.5% or more in cash, government securities and fully collateralised repo. The prime-fund test applies the weekly liquid assets of 2a-7(a)(28) against the 50% threshold in (d)(4)(iii). Both tests require that the fund hold nothing that (d)(1)(i) would exclude; the simulator treats sovereign debt over one year, loans, equities, commodities and crypto as such and assumes corporate debt is short-dated. The (d)(4) thresholds restrict new acquisitions rather than set a standing floor, so the simulator treats them as a reference point.

    Simulator assumptions (marked H). The LCR was not written for stablecoin issuers. Where it does not classify an asset used in reserves, the simulator states an assumption. Demand deposits at banks and overnight reverse repo against sovereign collateral count as Level 1. Term reverse repo counts as Level 2A. Government money market fund shares are looked through to the fund's portfolio. Outflow rates for token holders borrow the LCR40 funding categories (retail LCR40.13, non-financial corporates LCR40.40, financial institutions LCR40.42); the mixed rate is a simple average. The lender of last resort is assumed to lend against loans and debt securities but not against commodities, crypto-assets or equities, and its discount is illustrative. Sovereign debt of any maturity is Level 1 with no haircut unless the interest-rate slider is used.

    Yield. LCR40.15 names deposits placed in a search for yield as more volatile, for foreign-currency retail deposits, and leaves the rate to supervisors. The toggle therefore changes only the regulatory check.

    AssetClassBasis

    Known limitations. Three regime checks rest on texts this version could not pin down. For MiCA, the instruments eligible under art 54(b) are specified by technical standards under art 38(5); the check uses the Basel Level 1 sovereign list as a stand-in. For Singapore, "cash equivalents" is not defined in the 2023 Response, so repo and fund shares are shown as conditional; the reserve rules are also due to be set by regulations under the proposed amendments. For the United States, the Act takes effect on a date that depends on implementing regulations. Issuer figures are point-in-time reports and change monthly.

    Version history. 1.0 (7 October 2026): first public version.

    Sources

    • BCBS, Basel Framework, LCR30 (high-quality liquid assets) and LCR40 (cash inflows and outflows), versions effective 15 December 2019.
    • 17 CFR 270.2a-7 (money market funds), paragraphs (a)(8), (a)(14), (a)(28), (d)(1) and (d)(4), as on eCFR.
    • Tether International, Financial Figures and Reserves Report as of 30 June 2026, with BDO Advisory Services ISAE 3000 (Revised) reasonable-assurance report of 31 July 2026, at tether.to/transparency.
    • Circle Internet Group, USDC Reserve Report as of 11 and 31 August 2026, with Deloitte & Touche LLP examination report of 29 September 2026 (AICPA attestation standards) on management's assertion that reserves equal or exceed USDC in circulation, at circle.com/transparency.
    • Regulation (EU) 2023/1114 (MiCA), arts 49, 50, 54, 58 and 149.
    • GENIUS Act, Pub L 119-27, ss 4(a)(1), 4(a)(11) and 20.
    • FCA, PS26/10, Appendix 1: CASS 16.2, CRYPTO 2.4.14R and Glossary (core and expanded backing assets).
    • Hong Kong Stablecoins Ordinance (Cap 656), Sch 2 ss 5, 6 and 15; HKMA, Guideline on Supervision of Licensed Stablecoin Issuers (August 2025), paras 2.2.1, 2.3.1, 2.6.1 and 3.3.3.
    • MAS, Response to Public Consultation on Proposed Regulatory Approach for Stablecoin-related Activities (15 August 2023), Annex A; MAS, Consultation Paper P015-2026 (September 2026) and draft Payment Services Act amendments, s 20A(2)(c).
    • Banco Central do Brasil, Resolução BCB nº 80/2021, arts 22 and 23.

    This simulator is the personal work of Jeff Alvares. The views it expresses are his own and do not represent those of the Banco Central do Brasil. It uses public information only, and nothing in it is legal advice or an assessment of any issuer's compliance with any regime.