Circle：CLARITY法案对稳定币奖励的影响-速评

Circle: CLARITY impact on stablecoin rewards - Quick take Circle closed up ~20% and Coinbase up ~6% yesterday following the release of bipartisancompromise text on the Digital Asset Market CLARITY Act. The compromise resolves whathad been the final sticking point in the bill - the treatment of stablecoin yield - by prohibitingissuers from paying interest "economically or functionally equivalent" to a bank deposit onpassive stablecoin balances, while explicitly preserving rewards tied to "bona fide activitiesor bona fide transactions" such as trading, payments, and usage-driven incentives. In our view, the market was conflating “who earns yield” with “who distributes yield” andthus the negative impact earlier in March was not justified, in our view -Circle: Don'tconflate stablecoin issuer with distributor. The worst case assumed a blanket banon any form of stablecoin reward. The compromise text prohibits passive deposit-likeyield (which Circle does not offer directly anyway) while protecting the activity-basedand distribution-linked incentive structures that underpin USDC's growth. Better still,the prohibition removes what we had previously cited as a key investor concern: thatstablecoin competition would devolve into a yield pass-through arms race, allowing lessliquid issuers to attack USDC's market position/ share by simply outbidding on rates.By cementing stablecoins as payment instruments rather than deposit substitutes, thelegislation reinforces Circle's positioning as payment instrument and protects the floatincome for Circle. Also, the rewards structure now makes the transition to a new model manageable forCoinbase. Coinbase passes on yield on stablecoin (3.5%) for Coinbase One users. IfCoinbase restricts the yield pass-through on stablecoin balances, these customers do havethe option to move their stablecoin balances to money market funds or high yielding bankdeposits. However, we understand that customers leave USDC balances on platform toengage with trading and other crypto-related activities - there is an ecosystem effect. AndCoinbase can still pass through rewards linked to user activity or engagement. However, the senate still has a limited window to mark up and pass through the bill. ThePolymarket odds of Clarity passing have risen to 62%. Circle operating metrics continue to strengthen. USDC supply stands at ~$78bn (Exhibit1), up ~78% since the end of 2024 vs. ~48% growth for total dollar-backed stablecoins.Activity remains robust, with USDC transaction volume reaching $23Tn in Q1 2026 (~3xYoY) and adjusted transaction volume at $2.8Tn (~250% YoY). Correspondingly, USDC’sshare has expanded to ~80% of total stablecoin transaction volume and ~63% of adjustedvolume (vs. ~70% / ~39% in Q1 2025) - Exhibit 2-Exhibit 5. INVESTMENT IMPLICATIONS We rate CRCL (PT $190) and COIN (PT $330) Outperform. BERNSTEIN TICKER TABLE