（来源：吴说） 来源：市场资讯 汇丰最新报告称，美国围绕"美国股票代币化"监管的争论加速升级，传统金融机构与加密行业在是否应 将 DeFi 交易基础设施视作传统交易所上立场对立。报告指出，Citadel Securities 向 SEC 递交 13 页文 件，主张多数 DeFi 协议应按交易所监管，否则将导致监管套利与更弱的"影子市场"。加密行业则以 Coinbase 全球监管政策副总裁 Scott Bauguess 为代表，呼吁制定更符合去中心化模型的规则。汇丰表 示，SEC 最终取向仍不明确，但预计不会允许面向美国用户的链上股票市场享有明显低于传统交易所 的监管强度，监管沙盒或成为可行方案。(CoinDesk) ...

Core Viewpoint - The International Monetary Fund (IMF) warns that dollar-backed stablecoins, such as USDT and USDC with a total market capitalization of $260 billion, may accelerate currency substitution in countries with weak monetary systems, undermining central banks' effective control over capital flows [1] Group 1: Economic Impact - In high inflation and low trust economies, households and individuals tend to prefer stablecoins over volatile local currencies, increasing risks [1] - The presence of stablecoins in these economies could lead to a greater reliance on them, further destabilizing local currencies [1] Group 2: Systemic Threats - Key systemic threats include regulatory arbitrage, risk of bank runs, and illicit fund flows [1] - The IMF emphasizes that stablecoins are likely to persist in the financial landscape, necessitating a robust and coordinated international regulatory framework [1] Group 3: Financial Inclusion - The IMF calls for the establishment of strong regulations to manage risks while leveraging stablecoins to enhance financial inclusion [1]

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 ...

Core Viewpoint - The Federal Reserve Governor Stephen Miran emphasizes the need to reassess regulatory frameworks for Wall Street before addressing other economic issues related to the central bank's balance sheet [1] Group 1: Regulatory Environment - Financial regulation has predominantly moved in one direction, increasingly tightening restrictions on the banking sector [1] - The interaction between regulation, financial markets, and the execution of monetary policy is often undervalued [1] - Discussions surrounding bank reserve balances, their interest, balance sheet composition, and the role of intermediaries in the Treasury market are seen as downstream issues of the banking regulatory framework [1] Group 2: Historical Context and Changes - Some officials during the Trump administration considered relaxing several capital regulatory measures established after the 2008 financial crisis, including the enhanced supplementary leverage ratio [1] - The Federal Reserve has recently finalized modifications to the regulatory rating framework for large banks, easing requirements for certain lending institutions [1] Group 3: Recommendations and Transparency - Regulatory bodies should avoid overreacting and recognize that post-2008 crisis rules have been overly stringent, leading to a migration of traditional banking activities to less regulated areas due to cumbersome regulations [1] - Miran advocates for the Federal Reserve to enhance transparency, which would benefit both the public and the industry [2]

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].