这么一个看似漫不经心的转账，却在无意间造成了一个全新的局面，那就是这笔美元从纽约转到伦敦后，就变成了"不受美国监管的孤儿美元"。这是因为， 美国的监管体系从来不是监管美元这张纸，而是监管存放美元的机构。在1950年代，美联储的管辖范围限于以下两点：第一，它监管美国境内的银行和清 算系统；第二，它能对在美国司法管辖范围内的银行账户实施冻结、审查或资本要求。一旦美元存款不在美国境内、不在美国监管体系下运营，美联储的法 律权限就结束了。 回到上面这个例子，位于伦敦的莫斯科人民银行地处英国，由前苏联政府从莫斯科控制，不属于美国体系。其交易也不依赖美国清算网络，而是通过伦敦的 同业拆借市场结算。当这笔钱离开纽约后，等于从美国法律可触及的链条里消失了。美国无法要求伦敦的银行执行美国法律，也无法查看其账户信息，更无 法对其施加存款准备金或监管要求。也就是说，美元一旦进入伦敦的银行账户，它就从"美国监管美元"变成"自由美元"。也正是从这一刻起，伦敦的银行 家们意识到了一件惊人的"发现"： 美元可以在美国监管之外独立生存 。 最先察觉到这笔"自由美元"的，并非英国的监管部门，而是伦敦的 Midland Bank【1】。原因在于 ...

米兰强调，监管机构应避免过度反应，并指出在2008年危机后规则制定得过度严格。他补充说，这导致 许多传统银行业务部分迁移到监管较少的领域，部分原因就是"繁琐的规定"。 尽管围绕银行准备金余额及其利息、资产负债表构成、以及国债市场中介等议题的讨论愈加 热烈，但我认为这些讨论在很大程度上都是银行监管框架的下游问题。 特朗普政府时期的一些官员曾考虑放松多项在2008年金融危机后制定的银行资本监管措施，包括所谓 的"强化版补充杠杆率"（enhanced supplementary leverage ratio）。美联储近期也刚刚敲定了对大型银行 监管评级框架的修改，放宽了对部分贷款机构的要求。 美联储理事斯蒂芬·米兰（Stephen Miran）表示，他希望美联储在讨论与央行资产负债表相关的其他经 济问题之前，先重新调整华尔街的一系列监管规定。 米兰周三在华盛顿的行业组织——银行政策研究所（Bank Policy Institute）发表的预先准备讲话中表 示： 多年来，金融监管基本上只朝一个方向发展，不断加强对银行业的限制。监管与金融市场、 经济以及货币政策执行之间的互动往往不被充分重视。 他表示："虽然我并不偏见 ...

Core Insights - The recent losses at Zions Bank and Western Alliance highlight systemic risks in the commercial real estate (CRE) loan market, exacerbated by the Federal Reserve's interest rate hikes [1][3][4] Group 1: Events Focus - Zions Bank reported unexpected losses of approximately $50 million from two commercial and industrial loans in California, while Western Alliance is facing a lawsuit related to loan fraud [3] - These incidents reveal deeper issues in the commercial loan market, particularly following the bankruptcies of FirstBrands and Tricolor, which have intensified the risks associated with commercial loans [3] Group 2: Commercial Real Estate Loan Risks - The CRE loan market is facing a triple risk loop: the normalization of remote work is leading to declining office valuations, banks are extending loan terms to delay the recognition of bad debts, and low securitization levels are obscuring true risks [4] - Approximately 15% of regional banks' CRE loans are experiencing repayment difficulties, yet only 3% are officially classified as non-performing loans [4] Group 3: Impact of Interest Rate Hikes - The Federal Reserve's interest rate hikes are impacting banks differently, with regional banks experiencing a 40% faster increase in deposit costs compared to large banks, which have hedged 75% of their interest rate risks through derivatives [5] - The financial sector saw a 2.75% decline, with regional banks contributing over 70% of this drop, while major banks like JPMorgan only saw a minor 0.5% decrease [5] Group 4: Systemic Risk Indicators - There are three warning signals of systemic risk: increased liquidity mismatch with money market fund sizes surpassing bank reserves, regulatory arbitrage leading to high-risk asset transfers to regional banks, and a significant drop in market confidence as indicated by a 20% spike in the VIX index [6] - The KBW regional bank index fell by 4.8%, reflecting heightened panic in the market [6] Group 5: Reform Directions - The current events have exposed regulatory gaps from the 2008 crisis, including a lack of stress testing standards for NDFI loans, absence of liquidity support mechanisms for regional banks, and non-transparent disclosures regarding CRE loans [7] - Although risks are currently localized, historical patterns suggest that financial risks do not exist in isolation, prompting concerns about the overall resilience of the financial system [7]

Core Viewpoint - A fierce debate is unfolding on Wall Street regarding loan risks, particularly following the bankruptcies of Tricolor Holdings and First Brands Group, highlighting tensions between traditional banks and private equity firms over accountability for credit market turmoil [1][2]. Group 1: Bank and Private Equity Tensions - The recent bankruptcies have intensified the longstanding conflict between traditional banks and private equity firms, with banks accusing private equity of regulatory arbitrage and private equity firms countering that banks should examine their own practices [2][5]. - The International Monetary Fund (IMF) has called for regulatory scrutiny of banks' exposure to private credit, noting that banks are increasingly lending to private credit funds due to higher net asset returns compared to traditional commercial loans [2][6]. Group 2: Responses from Private Equity Leaders - Marc Rowan, CEO of Apollo Global Management, attributed the bankruptcies to banks' long-standing pursuit of high-risk borrowers, suggesting that the competitive market environment has led to shortcuts in lending practices [3][4]. - Jonathan Gray, President of Blackstone, echoed Rowan's sentiments, emphasizing that the failures were rooted in bank-led processes and denying the notion of systemic issues [3][4]. Group 3: Bank's Acknowledgment of Issues - Jamie Dimon, CEO of JPMorgan Chase, acknowledged the bank's exposure in the Tricolor case, admitting that it revealed internal issues and that the situation warranted increased vigilance [4][6]. - The bankruptcies have triggered a chain reaction in the credit market, with significant losses reported by major investment firms and banks, including a $170 million loss for JPMorgan Chase due to Tricolor's collapse [4][6].

Core Viewpoint - Major Wall Street banks reported strong performance in trading and investment banking for Q3, with an increase in lending activities, indicating a shift towards financing non-bank lending institutions and asset management companies [1][3][4]. Group 1: Financial Performance - JPMorgan Chase reported record quarterly revenues in its equity and fixed income trading businesses [3]. - Goldman Sachs and Citigroup also achieved their best Q3 performance in years, with Goldman Sachs' investment banking revenue increasing by 43% to $2.66 billion [5]. - Overall, investment banks' consulting and capital market revenues reached their highest level since the end of 2021, driven by active IPOs and a rebound in M&A advisory fees [5]. Group 2: Lending Trends - There is a notable increase in loans to non-bank financial institutions, which now account for 13% of total outstanding loans from banks [4]. - Analysts express concern that non-bank lenders are focusing more on trading assets rather than providing new financing for the real economy [4][6]. Group 3: Regulatory Environment - The Federal Reserve is expected to lower interest rates and may reduce capital requirements for banks, which could enhance their ability to engage in riskier lending practices [6][7]. - Concerns have been raised about "regulatory arbitrage" outside the banking system, with warnings that credit quality may deteriorate more than anticipated during an economic downturn [6]. Group 4: Market Outlook - There are fears that the U.S. economy may slow down next year, with a softening labor market, leading to potential increases in asset prices rather than resolving uncertainties related to trade and tariffs [7]. - Analysts suggest that U.S. regulators should focus on encouraging banks to create credit for the real economy rather than fostering financial bubbles [7].

Core Viewpoint - The Governor of the Bank of England, Andrew Bailey, emphasizes the need for enhanced global policy responses to emerging threats posed by private finance and stablecoins, highlighting the importance of identifying and addressing new vulnerabilities in the financial system [1] Group 1: Global Financial Stability Committee (FSB) Actions - The FSB, chaired by Bailey, is committed to reforming its monitoring policies to be more flexible and responsive to emerging financial vulnerabilities [1] - Bailey has pledged to facilitate open discussions among member countries regarding next steps in addressing these threats [1] - The FSB aims to strengthen its collaboration with the global private sector to leverage expertise on risks and market vulnerabilities [1] Group 2: Rise of Stablecoins - Stablecoins, which are digital currencies backed by traditional assets like the US dollar, have seen rapid growth, particularly in the US market, with some analysts predicting their scale could expand to $2 trillion [1] - These digital currencies are designed to maintain a stable value, typically pegged 1:1 to the US dollar, and have gained traction in cross-border financial services [1] - The emergence of stablecoins is viewed as a potential blueprint for the 21st-century global payment system, although concerns about new risks in the financial system have been raised [1] Group 3: Regulatory Challenges - Bailey notes significant gaps in addressing financial stability risks, with few jurisdictions establishing comprehensive regulatory frameworks for stablecoins [1] - The FSB has struggled to collect comprehensive risk data from the rapidly growing non-bank financial sector, which includes a wide range of entities from hedge funds to private credit [1] - The trend towards deregulation raises concerns about the potential weakening of reform efforts, with Bailey citing delays in implementing post-crisis banking reforms as a notable example [1]

Core Viewpoint - The Bank of England Governor Andrew Bailey emphasizes the need for a global policy response to emerging threats posed by the increasing use of private finance and stablecoins, as stated in his recent speech to the G20 [1]. Group 1: Global Financial Stability Committee (FSB) - The FSB, established by the G20 in June 2009, aims to enhance global financial regulation and stability, with its current chair being Andrew Bailey [1]. - Bailey committed to reforming FSB's monitoring policies to be more flexible and responsive to emerging vulnerabilities and financial gaps [1]. - The FSB plans to engage in open discussions among member countries regarding next steps and strengthen ties with the private sector to leverage their expertise on risks and market vulnerabilities [1][3]. Group 2: Rise of Stablecoins - Stablecoins, a form of digital currency backed by traditional assets like the US dollar, have seen rapid growth, particularly in the US market, with some analysts predicting their scale could reach $2 trillion [2]. - These digital currencies aim to maintain a stable value, typically pegged 1:1 to the US dollar, and have gained traction in crypto trading and cross-border financial services [2]. - The European financial stability regulators are pushing to ban the issuance of stablecoins in conjunction with other jurisdictions due to concerns about unpredictable cross-border risks [2]. Group 3: Regulatory Challenges - Bailey highlighted significant gaps in addressing financial stability risks, noting that few jurisdictions have established comprehensive regulatory frameworks for global stablecoins, raising concerns about regulatory arbitrage [3]. - The FSB has prioritized non-bank financial entities but has struggled to collect comprehensive risk data from this rapidly growing market [3]. - There is a growing concern that the trend towards deregulation may weaken reform efforts, as evidenced by delays in implementing post-crisis banking reforms [3][4].

Core Insights - The bankruptcy filing of First Brands Group has raised concerns about the potential for a repeat of the 2008 subprime mortgage crisis within the private credit market, highlighting deep-seated risks in this sector [2][4]. Group 1: First Brands Bankruptcy and Private Credit Risks - First Brands' bankruptcy revealed a complex debt structure of $12 billion, including $5.8 billion in leveraged loans and $6.2 billion in off-balance-sheet financing, involving numerous private equity funds and CLO managers [2]. - The debt structure included cross-collateralization traps and issues with collateral management, where the same receivables were pledged multiple times, leading to potential "commingled" collateral [2]. - The lack of transparency in financial reporting, as a non-public company, contributed to the information black hole, with traders only noticing anomalies shortly before the bankruptcy [2]. Group 2: High-Yield Temptations in Private Credit - The private credit market has attracted global capital with annualized returns of 8%-10%, but the First Brands case has exposed the inflated risk premiums and the misleading nature of these returns [3]. - Some fund managers had projected returns on inventory debt exceeding 50%, which far surpassed the actual profitability of the companies involved [3]. - The use of structured products through multiple SPVs has obscured underlying risks, packaging BB-rated loans as "quasi-government" products [3]. Group 3: The $2 Trillion Private Credit Market - The U.S. private credit market has ballooned from $310 billion in 2010 to $2.1 trillion in 2025, accounting for 45% of the global private credit market [4]. - Research indicates that the actual default rate, when accounting for expected loss loans, has reached 5.4%, nearing levels seen before the 2008 crisis [4]. Group 4: Operational Flaws in Private Credit - Regulatory arbitrage allows banks to indirectly engage in high-risk lending through private equity funds, circumventing restrictions imposed by the Dodd-Frank Act [5]. - Rating agencies have applied lenient standards to private credit, with some CLO products receiving AAA ratings despite underlying risks equivalent to BBB- [5]. Group 5: Systemic Risk Transmission - Major financial institutions, such as JPMorgan and Blackstone, are both providers of private credit and primary buyers of CLOs, creating a "risk loop" [7]. - Approximately 20% of U.S. pension funds are invested in private credit, raising concerns about a potential "retirement crisis" if defaults occur [7]. Group 6: Historical Parallels with the Subprime Crisis - The structural similarities between the CDOs of the subprime crisis and the SPV structures in private credit highlight a concerning pattern of risk isolation [8]. - Following First Brands' bankruptcy, CLO prices plummeted by 60%, triggering fears of a "private version of Lehman moment" [9]. Group 7: Market Reactions and Regulatory Gaps - Optimistic views from firms like Morgan Stanley suggest that First Brands is an isolated incident, while pessimistic forecasts predict a wave of private credit defaults in 2026 [10]. - The lack of information disclosure in private credit hampers market oversight, reminiscent of the financial black holes seen during the Enron era [11]. Group 8: Future Scenarios and Institutional Reforms - Short-term strategies may include liquidity injections from the Federal Reserve and debt restructuring based on the 2008 stress test model [12]. - Long-term reforms could involve enhanced transparency requirements for private credit funds and prohibiting banks from providing unsecured revolving credit to these funds [13]. Conclusion - The bankruptcy of First Brands is indicative of the excessive expansion and regulatory shortcomings within the private credit market, serving as a warning that financial innovations detached from the real economy may lead to systemic crises [14].

OKX 的作风给我感觉就是有点太专注技术和产品了，导致有时候和资产端有点脱离。我在很长一段时间内都并未意识到，以 Hyperliquid 为代表的一类 perpdex 更像是利用监管漏洞进行监管套利的 CEX，和以往的 GMX 等产品有着比较大的差异但同时也是优越性。现在不可否认的是这轮 perpdex 的资产炒作热很成功，市场对这一类新叙事有着明显偏好而 Star @star_okx 的核心观点很显然，是认为未来有可能这部分也会被纳入监管。但这并不妨碍在未纳入监管的红利期中，perpdex 能够捕获非常大一块无 KYC 用户和无需合规监管的资产自 BN Alpha 上线后，除币安之外的交易所不同程度遇到了交易量和上币费用等问题的挤压。或许未来每个 CEX 都会有自己的 perpdex 来卷这一大块无 KYC 用户从吸引用户的手法来说：一个有代币激励的高控筹模型能够产生非常大的补贴激励——吸引用户使用交手续费——手续费回购代币形成现货买压。这看来是一套行之有效的飞轮模型，现如今 $OKB 也已 CEX 主体进行了拆分，如果以 $OKB 为基础或者是自拉一个 perpdex 代币，都是可能的补贴飞轮解决方案，很 ...

Core Viewpoint - The French securities regulator is considering actions to prevent cryptocurrency companies licensed in other EU countries from operating domestically, aiming to centralize regulatory authority within the EU to address regulatory gaps and inconsistencies [1][2]. Regulatory Gaps - The cryptocurrency industry, valued in the trillions, faces significant regulatory scrutiny as global regulators warn of potential market disruptions and investor harm if not properly managed [2]. - France, along with Italy and Austria, has called for the European Securities and Markets Authority (ESMA) to take over the regulation of major cryptocurrency companies, highlighting the need for consistent oversight across the EU [2][3]. Potential Actions - The French Financial Markets Authority (AMF) has indicated it may challenge the "passport" system that allows companies licensed in one EU member state to operate across the EU, referring to this as a "nuclear option" [2]. - AMF's president expressed concerns about the rapid issuance of licenses by some countries and the adequacy of cross-border regulatory oversight [2][3]. Differences in Regulatory Approaches - The initial months of implementing new rules have revealed significant differences in how various national regulators approach cryptocurrency oversight [3]. - Specific examples of regulatory discrepancies include Malta's licensing process, which faced scrutiny for inadequate risk assessment [3]. Calls for Enhanced Regulation - France, Italy, and Austria are advocating for amendments to the Markets in Crypto-Assets Regulation (MiCA) to impose stricter regulations on cryptocurrency companies operating outside the EU, improve cybersecurity oversight, and enhance scrutiny of new token issuance [3]. Support for Centralized Authority - France has long supported granting greater powers to ESMA, which has received backing from its chair, although some EU member states oppose this move [4].