Kyle McAndrew

July 25, 2025

8 mins

Stablecoins Are Not Digital Cash

Introduction: Deconstructing the "Digital Cash" Fallacy

Stablecoins are often marketed with a promise so shiny, it could almost pass for satire: "Imagine a dollar that never sleeps, never loses value, and runs on magic internet money." If that sounds too good to be true, it’s because it is.

Promoted as the blockchain age’s answer to paper currency, stablecoins aim to offer the price stability of sovereign money combined with the frictionless speed of crypto networks. Issuers pitch them as “digital dollars” or “safe stores of value,” implying they’re the modern, tech-savvy equivalent of cash.

But that narrative is more sales pitch than substance. In truth, fiat-backed stablecoins are not digital cash—they are private IOUs, tethered not to the U.S. government, but to a corporate entity and its internal reserve strategy. Unlike cash in an FDIC-insured bank, stablecoins come with a unique set of risks: counterparty exposure, questionable asset quality, and uncertain liquidity.

This report dissects the digital cash myth by comparing the risks of stablecoins to the protections of government-insured bank deposits. From the mechanics of reserve backing to the cautionary tales of past failures, our goal is to arm financial advisors with a deeper understanding—so they can separate marketing gloss from financial reality, and help clients navigate this space with clarity, not hype.

The Fundamental Risk: Lack of Insurance and Reliance on Private Reserves

The core distinction between a stablecoin and cash in a bank lies in one critical feature: government-backed deposit insurance. Cash held in a U.S. bank account is more than just a number; it is a direct liability of a regulated institution, backed by the full faith and credit of the U.S. government through the Federal Deposit Insurance Corporation (FDIC).

The safety of a bank deposit is a matter of law. The FDIC insures deposits up to $250,000 per depositor, per insured bank.7 In the event of a bank failure, the U.S. government guarantees the return of a depositor's funds up to this limit. For a depositor, the risk of principal loss is effectively zero.7

Stablecoins have no such government backstop.4 They are privately-issued instruments that rely entirely on a "reserve" of assets managed by the issuer. Holding a stablecoin means accepting the credit risk of a private company and its assets; holding cash in a bank means relying on a government guarantee. This distinction is the primary source of risk.

The quality of these private reserves varies dramatically. Circle (USDC) holds its reserves primarily in cash and short-term U.S. Treasuries, a conservative approach.10 In contrast, Tether (USDT), the largest stablecoin, holds a more opaque mix of assets that has included secured loans, precious metals, and Bitcoin alongside its Treasury bills.11 This strategy introduces credit and market risk that a bank depositor simply does not face. Furthermore, transparency often relies on "attestations," which are point-in-time snapshots, not the full financial audits and continuous regulatory supervision that banks undergo.13

When the Peg Breaks: Real-World Failures

The risks associated with stablecoins are not merely theoretical. Market history is littered with examples of stablecoin failures, which provide invaluable lessons in the fragility of these instruments.

The Algorithmic Ghost: The TerraUSD (UST) Collapse

The May 2022 collapse of TerraUSD (UST) vaporized over $42 billion in investor value.14 Unlike collateralized stablecoins, UST was not backed by any real-world assets. Its stability was maintained by an algorithmic link to a sister token, LUNA.14 To drive demand, its creators offered an unsustainable yield of nearly 20% APY through the Anchor Protocol.14 When market confidence wavered, a panic ensued. As users rushed to exit, the algorithm minted trillions of new LUNA tokens, causing hyperinflation and a "death spiral" that rendered both tokens worthless in days.16

The Contagion of TradFi: The March 2023 USDC De-Peg

The temporary de-pegging of USDC in March 2023 proved that even a fully-reserved stablecoin is not immune to risk. The crisis was triggered by the failure of Silicon Valley Bank (SVB), where Circle held $3.3 billion of its cash reserves.19 When regulators shut down SVB, those funds were temporarily trapped, representing nearly 8% of USDC's backing.21 Panicked holders rushed to sell, causing USDC's price to fall to a low of $0.87.23 The peg was only restored after the U.S. government took the extraordinary step of guaranteeing all deposits at SVB.22 The event highlighted a critical risk: USDC holders were directly exposed to the credit risk of Circle's banking partner, a risk not present with insured cash deposits.

The Yield Paradox: The Hidden Price of DeFi Returns

One of the most powerful draws for holding stablecoins is the ability to generate high yields through Decentralized Finance (DeFi) protocols. However, these returns are not interest in the traditional sense; they are compensation for taking on specific, uninsurable risks that are entirely absent from the banking system.

Yield is typically generated by lending stablecoins on protocols like Aave or providing liquidity to decentralized exchanges like Curve.25 While the advertised Annual Percentage Yields (APYs) can be attractive, they mask a host of significant risks:

  • Smart Contract Risk: DeFi protocols are run by autonomous code. A bug or vulnerability in this code can be exploited by hackers, potentially leading to the complete and irreversible loss of all deposited funds.26
  • Impermanent Loss: A risk specific to providing liquidity, where the value of a user's deposited assets can become less than if they had simply held them in their wallet.27
  • "Rug Pulls": The decentralized and often anonymous nature of DeFi creates opportunities for fraudulent projects where developers attract funds with promises of high yields and then abruptly disappear with the capital.26

For a client focused on capital preservation, the choice between a 10% APY on a stablecoin yield farm and a 5% APY on an FDIC-insured High-Yield Savings Account (HYSA) should be clear. The 10% comes with the uninsurable risk of total loss, while the 5% is backed by the full faith and credit of the U.S. government.

The Regulatory Response: A Safety Net with Holes

The era of unregulated stablecoins is ending. Spurred by systemic risks, regulators are implementing legal frameworks designed to make these instruments safer. In the European Union, the Markets in Crypto-Assets (MiCA) regulation forces issuers to be authorized, maintain 1:1 reserves with secure assets, and guarantee redemption rights.29 In the United States, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, signed into law in July 2025, establishes the first federal framework for "payment stablecoins."31 The law mandates 1:1 backing with high-quality liquid assets like U.S. Treasuries, requires monthly audited reports, and explicitly bans algorithmic stablecoins.33

While these regulations are a significant step toward mitigating risk, they do not eliminate it. Crucially, these new rules do not provide a government backstop like FDIC insurance. The GENIUS Act explicitly makes it illegal for issuers to misrepresent their products as being backed by the U.S. government.35 Regulation makes stablecoins safer, but it does not make them cash.

Wall Street's Answer: The Rise of Tokenized Money Market Funds

Wall Street has awakened to a fundamental reality: the most popular stablecoins are, in essence, unregulated money market funds. Recognizing the demand for the technological benefits of stablecoins—like 24/7 transfers and instant settlement—but within a compliant structure, financial giants are now launching their own alternative: tokenized money market funds.39 In a landmark move, firms like Goldman Sachs and BNY Mellon have partnered to offer digital tokens that represent ownership of shares in traditional, highly-regulated MMFs from managers including BlackRock and Fidelity.41

These are not new cryptocurrencies but rather digital "mirror tokens" of existing securities, with ownership recorded on private blockchains while the official records remain with custodians like BNY.41 This structure aims to provide the best of both worlds: the speed and efficiency of a digital token with the safety and regulatory oversight of a security.45 Crucially, this model directly addresses a key deficiency in stablecoins. While the GENIUS Act prohibits stablecoin issuers from paying interest, tokenized MMFs can pass the yield from their underlying government securities directly to investors.46 This makes them a compelling, yield-bearing alternative for institutional investors looking to manage cash on-chain without taking on the counterparty and regulatory risks of stablecoins.40

A Financial Advisor's Framework for Risk Mitigation

Given the inherent risks, an advisor's fiduciary duty necessitates looking past marketing claims and conducting an independent risk assessment. Allocating client funds to a stablecoin is an investment decision, not a cash management decision.

Before any allocation, advisors should conduct rigorous due diligence, focusing on issuer integrity, reserve quality and transparency, redemption rights, and regulatory compliance. A history of regulatory non-compliance, opaque reserves containing risky assets, or a domicile in a lightly regulated jurisdiction are all major red flags.36

After conducting due diligence, any potential allocation must be positioned appropriately within a client's financial plan:

  • This is Not an Emergency Fund: It must be unequivocally stated that stablecoins are not a substitute for cash held in FDIC- or NCUA-insured deposit accounts. Emergency funds must remain in fully insured, risk-free instruments.
  • A Tool for Specific, High-Risk Applications: The use of stablecoins should be confined to specific, high-risk-tolerance applications within a broader digital asset strategy, with a full understanding of their transactional and counterparty risks.
  • Explicit Risk Disclosure: The advisor must clearly articulate the risks: the lack of government deposit insurance, the counterparty risk of the issuer, the potential for de-pegging, and the additional smart contract risks if used in DeFi.

Conclusion: A Risk-First Approach to a New Financial Instrument

If stablecoins are "digital cash," then a vending machine IOU is a savings bond. The comparison sounds silly, and that's precisely the point.

The idea that stablecoins are a seamless substitute for government-backed cash is a dangerous oversimplification. These are complex, privately issued instruments that lack the single most important feature of bank deposits: a federal guarantee. Their value rests entirely on the solvency, transparency, and discretion of the issuing entity—exactly the kind of risk FDIC insurance was designed to eliminate.

While regulation is tightening and tokenized money market funds are entering the scene with the polish of Wall Street, even the best-dressed stablecoin still doesn’t carry the U.S. government’s seal of protection. In this context, financial advisors play a vital role—not as hype men for innovation, but as guardians of risk-aware decision making.

By cutting through the marketing fog and communicating the real risks, advisors can guide clients toward financial tools that preserve wealth rather than chase the illusion of it. Because in a world where everything is “disruptive,” a little prudence is the real innovation.

References

  1. Stablecoins: Definition, How They Work, and Types - Investopedia, accessed July 21, 2025, https://www.investopedia.com/terms/s/stablecoin.asp
  2. Stablecoins and CBDCs: The future of money in a digital world, accessed July 21, 2025, https://www.santandercib.com/insights/innovation/stablecoins-and-cbdcs-future-money-digital-world
  3. Stablecoins: A Deep Dive into Valuation and Depegging | S&P Global, accessed July 21, 2025, https://www.spglobal.com/en/research-insights/special-reports/stablecoins-a-deep-dive-into-valuation-and-depegging
  4. What Is Tether (USDT) And How Does It Work? - Bankrate, accessed July 21, 2025, https://www.bankrate.com/investing/what-is-tether-stablecoin/
  5. What is USDC? Learn about Circle's stable digital dollar, accessed July 21, 2025, https://www.usdc.com/learn/what-is-usdc
  6. USDC | Powering global finance. Issued by Circle., accessed July 21, 2025, https://www.circle.com/usdc
  7. High-yield savings accounts vs. CDs vs. money market funds - Vanguard, accessed July 21, 2025, https://investor.vanguard.com/investor-resources-education/article/high-yield-savings-vs-cd-vs-money-market
  8. Money Market Accounts vs. High Yield Savings: Which is the Best Choice? - Rising Bank, accessed July 21, 2025, https://www.risingbank.com/money-market-vs-high-yield-savings/
  9. A Method for Estimating the Price of Stablecoin Insurance - Federal Reserve Bank of Kansas City, accessed July 21, 2025, https://www.kansascityfed.org/research/economic-review/a-method-for-estimating-the-price-of-stablecoin-insurance/
  10. USDC - Stablecoin Stability Assessment - S&P Global, accessed July 21, 2025, https://www.spglobal.com/_assets/documents/ratings/research/101610806.pdf
  11. Tether Hits $13 Billion Profits for 2024 And All-Time Highs in U.S. ..., accessed July 21, 2025, https://tether.io/news/tether-hits-13-billion-profits-for-2024-and-all-time-highs-in-u-s-treasury-holdings-usdt-circulation-and-reserve-buffer-in-q4-2024-attestation/
  12. Tether reports profits, brings USDT (and secrecy) to BTC - CoinGeek, accessed July 21, 2025, https://coingeek.com/tether-reports-profits-brings-usdt-and-secrecy-to-btc/
  13. How to read a stablecoin attestation report and why it matters - Cointelegraph, accessed July 21, 2025, https://cointelegraph.com/news/how-to-read-a-stablecoin-attestation-report
  14. Anatomy of a Run: The Terra Luna Crash, accessed July 21, 2025, https://corpgov.law.harvard.edu/2023/05/22/anatomy-of-a-run-the-terra-luna-crash/
  15. Understanding the Collapse of TerraUSD (UST): Lessons and Implications for Stablecoins in Cryptocurrency - BlockApps Inc., accessed July 21, 2025, https://blockapps.net/blog/understanding-the-collapse-of-terrausd-ust-lessons-and-implications-for-stablecoins-in-cryptocurrency/
  16. Terra - What it Was, Collapse, Stablecoin - Corporate Finance Institute, accessed July 21, 2025, https://corporatefinanceinstitute.com/resources/cryptocurrency/what-happened-to-terra/
  17. LUNA: Terra's Extraordinary Crash Explained - alphaAI, accessed July 21, 2025, https://www.alphaai.capital/blog/luna-to-the-moon-a-simple-explanation-of-terras-extraordinary-crash
  18. LUNA's Crash Landing: Algorithmic Stablecoin Experiment Ends In Tears, accessed July 21, 2025, https://www.vixio.com/insights/pc-lunas-crash-landing-algorithmic-stablecoin-experiment-ends-tears
  19. USDC Stablecoin Stability Assessment - S&P Global, accessed July 21, 2025, https://www.spglobal.com/_assets/documents/ratings/research/101590836.pdf
  20. Why did USDC Stablecoin break its Dollar Peg after the Silicon Valley Bank Collapse?, accessed July 21, 2025, https://coindcx.com/blog/cryptocurrency/why-did-usdc-stablecoin-break-its-dollar-peg-after-the-silicon-valley-bank-collapse/
  21. USDC stablecoin loses peg. $3.3bn stuck in failed SVB bank - Ledger Insights, accessed July 21, 2025, https://www.ledgerinsights.com/usdc-stablecoin-loses-peg-svb-bank/
  22. Is USDC Safe? & Why Did It Depeg? | Ledn Blog, accessed July 21, 2025, https://www.ledn.io/post/usdc-depeg
  23. Why Did “Stablecoin” USDC De-Peg From the US Dollar? - Krysylis, accessed July 21, 2025, https://www.krysylis.com/blog/why-did-stablecoin-usdc-de-peg-from-the-us-dollar
  24. SVB Collapse Sparks Stablecoin Turmoil as USDC Loses Dollar Peg - Investopedia, accessed July 21, 2025, https://www.investopedia.com/usdc-loses-peg-7254222
  25. How to Earn Interest on Stablecoins | CoinMarketCap, accessed July 21, 2025, https://coinmarketcap.com/academy/article/a3a389f0-1a91-4bad-9e6a-989c6fc0b7f6
  26. Yield Farming Explained: Your Complete Beginner's Guide - Kraken, accessed July 21, 2025, https://www.kraken.com/learn/what-is-yield-farming
  27. Farming with Confidence: 5 of the Safest Stablecoin Protocols | by Pendulum - Medium, accessed July 21, 2025, https://medium.com/pendulum-chain/farming-with-confidence-5-of-the-safest-stablecoin-protocols-99800cec944a
  28. A Beginner's Guide to DeFi Yield Farming - Hedera, accessed July 21, 2025, https://hedera.com/learning/decentralized-finance/defi-yield-farming
  29. Markets in Crypto-Assets Regulation (MiCA) Updated Guide (2025), accessed July 21, 2025, https://www.innreg.com/blog/mica-regulation-guide
  30. MiCA-compliant Stablecoins: What You Need to Know | Tangem Blog, accessed July 21, 2025, https://tangem.com/en/blog/post/swap-mica-stablecoins/
  31. GENIUS Act Passes in US Congress: A Breakdown of the Landmark Stablecoin Law, accessed July 21, 2025, https://www.morganlewis.com/pubs/2025/07/genius-act-passes-in-us-congress-a-breakdown-of-the-landmark-stablecoin-law
  32. The GENIUS Act: A New Era of Stablecoin Regulation - Gibson Dunn, accessed July 21, 2025, https://www.gibsondunn.com/the-genius-act-a-new-era-of-stablecoin-regulation/
  33. Chairman McHenry's Clarity for Payment Stablecoins Act approved by the House Financial Services Committee | Davis Polk, accessed July 21, 2025, https://www.davispolk.com/insights/client-update/chairman-mchenrys-clarity-payment-stablecoins-act-approved-house-financial
  34. Congress Passes GENIUS Act: Landmark Framework for Payment Stablecoins Will Reshape U.S. Digital Asset Regulation - Pillsbury Winthrop Shaw Pittman, accessed July 21, 2025, https://www.pillsburylaw.com/en/news-and-insights/congress-genius-act-framework-stablecoin-digital-asset-regulation-us.html
  35. Trump signs landmark 'Genius Act': What are stablecoins? How new crypto law could transform your digital wallet?, accessed July 21, 2025, https://economictimes.indiatimes.com/news/international/global-trends/us-news-trump-signs-landmark-genius-act-what-are-stablecoins-how-new-crypto-law-could-transform-your-digital-wallet/articleshow/122776803.cms
  36. Attorney General James Ends Virtual Currency Trading Platform ..., accessed July 21, 2025, https://ag.ny.gov/press-release/2021/attorney-general-james-ends-virtual-currency-trading-platform-bitfinexs-illegal
  37. US Establishes First Federal Regulatory Framework for Stablecoins: The GENIUS Act Passes Congress and Awaits President Trump's Signature | JD Supra, accessed July 21, 2025, https://www.jdsupra.com/legalnews/us-establishes-first-federal-regulatory-9686451/
  38. The GENIUS Act: A New Federal Framework for Stablecoin Issuers, accessed July 21, 2025, https://www.pillsburylaw.com/en/news-and-insights/genius-act-stablecoin-issuers.html
  39. Goldman Sachs and BNY Launch Tokenized Money Market Funds with Blockchain for 24/7 Trading and Real-Time Settlements, accessed July 24, 2025, https://www.ainvest.com/news/goldman-sachs-bny-launch-tokenized-money-market-funds-blockchain-24-7-trading-real-time-settlements-2507/
  40. BNY'​s LiquidityDirect Portal Announces Plans to Tokenize Money Funds - Crane Data, accessed July 24, 2025, https://cranedata.com/archives/all-articles/10928/
  41. BNY and Goldman Sachs Launch Tokenized Money Market Funds Solution, accessed July 24, 2025, https://www.goldmansachs.com/pressroom/press-releases/2025/bny-goldman-sachs-launch-tokenized-money-market-funds-solution
  42. $7.1 Trillion Money Market Shake-Up: Goldman and BNY Go Digital, accessed July 24, 2025, https://wallstreetpit.com/128210-7-1-trillion-money-market-shake-up-goldman-and-bny-go-digital/
  43. Goldman Sachs, BNY Mellon Step into Tokenized Money Market Funds - Investopedia, accessed July 24, 2025, https://www.investopedia.com/bny-mellon-and-goldman-sachs-step-into-tokenized-money-market-funds-11777455
  44. BNY, Goldman Sachs ink tokenized money market fund deal to bring $7.1 trillion industry onchain, accessed July 24, 2025, https://www.theblock.co/post/363970/bny-goldman-sachs-tokenized-money-market
  45. Goldman and BNY Launch Tokenized Money Market Funds for 24/7 Liquidity - CoinCentral, accessed July 24, 2025, https://coincentral.com/goldman-and-bny-launch-tokenized-money-market-funds-for-24-7-liquidity/
  46. Goldman Sachs BNY Mellon Launch First US Tokenized Money Market Funds - CoinCentral, accessed July 24, 2025, https://coincentral.com/goldman-sachs-bny-mellon-launch-first-us-tokenized-money-market-funds/
  47. Tokenized money market funds: The bridge to a new financial infrastructure | Franklin Templeton, accessed July 24, 2025, https://www.franklintempleton.com/articles/2025/disruption/tokenized-money-market-funds-the-bridge-to-a-new-financial-infrastructure