#CLARITY法案或利空DeFi CLARITY Act Rewrite: DeFi Life and Death Ledger: Circle Gains, DeFi Tokens Bleed!

The latest CLARITY proposal effectively ends the narrative of stablecoins as savings products. While yield sharing is still permitted, the pathway to pass on returns to end users has been cut off. Coinb can continue to profit through USDC, but it has lost its most powerful growth leverage—offering yields to users—which creates structural resistance to its distribution model. Meanwhile, Circle now needs to demonstrate that its arrangements are legal profit sharing rather than yield avoidance, bringing higher legal risks, potential contract restructuring, and ongoing regulatory scrutiny.
Essentially, this is about control over the money market. Stablecoins are strictly defined as payment tools rather than interest-bearing assets, effectively isolating yields within banks and regulated financial instruments (such as money market funds and ETFs like IQMM), leading to a re-concentration of earnings.

Implementation of the CLARITY Act Will Harm DeFi
Although the CLARITY framework structurally favors Circle, supporting USDC adoption and valuation, even at the cost of reduced flexibility (e.g., yield sharing, incentives) and short-term margin compression, it poses significant resistance to DeFi. Many DeFi tokens and activities may require registration and compliance review, especially when governance and fee-generation mechanisms resemble equity structures.
Some believe the CLARITY framework could benefit DeFi by pushing users toward DeFi lending due to the ban on yields. However, this assumes DeFi remains unaffected by regulation. In reality, the framework is likely to extend to front-end interfaces and restrict how stablecoins are used within DeFi.

The 10x Perspective: DeFi Is Not the Beneficiary, But the Loser
Structurally, this is bearish for DeFi tokens because reduced flexibility, increased compliance, and potential restrictions on stablecoin use will pressure liquidity, activity, and ultimately valuation.
The key overlap is with stablecoins. Circle (CRCL) and Uniswap heavily rely on USDC as core liquidity for trading and settlement. Stricter regulation could pressure front-end interfaces, token listings, and liquidity incentive mechanisms, possibly introducing KYC and compliance layers. This would directly impact fee income, token velocity, and permissionless access, potentially leading to decreased trading volume, reduced composability, and shrinking liquidity pools.

According to CLARITY, the most affected assets are DeFi tokens and governance tokens linked to fee income. DEX tokens like UNI, SUSHI, DYDX, 1INCH, and CAKE face direct risks because their governance-plus-yield models resemble equity and may require regulated front-ends. Similarly, lending and yield protocols like AAVE and COMP are under scrutiny due to their interest accrual structures and yield-sharing mechanisms, which could be classified as unregistered financial products.
MKR Will Benefit from the Yield Re-Centralization Trend
Markets seem to have largely digested these factors, so a structural revaluation driven solely by the CLARITY Act is unlikely. MKR outperformed USDT in 2026, thanks to its unique position in the evolving yield landscape. Unlike most DeFi tokens, Maker earns actual yields by investing in U.S. Treasuries and other real-world assets, with these earnings ultimately distributed to MKR holders through surplus mechanisms.
In an environment where user-level stablecoin yields are increasingly restricted by regulation, value is shifting toward issuers or protocol layers, and Maker’s structure has already positioned it to benefit from this shift. Therefore, MKR’s valuation is more seen as a “crypto market equity” capable of generating yields rather than a speculative DeFi token. MKR/USDT also appears to be a leading indicator for CRCL.

Meanwhile, MKR stands in stark contrast to stablecoins like USDT, which, despite their large scale, do not directly transfer economic value to token holders. This creates a structural difference, especially as high interest rates continue to support Maker’s income streams.
Importantly, MKR is more of an exception. While most DeFi tokens face adverse effects from tighter regulation and stablecoin restrictions, Maker’s early integration of real-world assets and its semi-compliant structure make it a beneficiary of the yield re-centralization trend.
More broadly, most DeFi protocols rely on USDC as collateral and settlement infrastructure. If regulation restricts USDC’s use in DeFi, liquidity could decline, trading volume decrease, and token valuations come under pressure.
Ultimately, the CLARITY Act may not only regulate cryptocurrencies but also reshape the entire DeFi ecosystem. Beneficiaries could include compliant infrastructure providers like Circle, exchanges, and custodians (BitGo), while tokens associated with permissionless finance and fee extraction could suffer. In this context, any tokens that behave like equity within financial protocols (e.g., Uniswap) and are unregulated will face structural downside risks.

Is Circle Still a Worth Investment?
According to recent discussions, the CLARITY proposal will prohibit platforms from directly or indirectly providing yields to stablecoin holders, especially those resembling bank deposit yields. This restriction will broadly apply to digital asset service providers, including exchanges, brokers, and their affiliates, explicitly targeting any structures “economically or functionally equivalent to” interest.
While the bill allows activity-based rewards such as loyalty programs, promotions, or subscription plans, these rewards cannot be linked to balances or trading volume in any way that mimics interest income. This significantly limits how incentives can be structured and clearly delineates that stablecoins cannot operate as interest-bearing deposit accounts.
Circle appears to have become a structural winner, while Coinb faces structural resistance, and BitGo is somewhere in between. BitGo’s market cap has fallen from about $2-2.5 billion at IPO to around $1.14 billion, but its valuation has become more attractive. Based on the past 12 months’ performance, the company earns approximately $57 million, with a P/E ratio of 20, which is not expensive for a regulated, institutionally-strong crypto infrastructure provider.

However, profit quality remains a key constraint. Its reported revenue is inflated by total transaction volume, but actual profit margins are very low (net profit margin below 1%), making BitGo’s structure closer to low-margin custody and execution platforms rather than high-margin asset-liability models like Circle or Tether.
Therefore, although BitGo’s valuation has become more reasonable after the decline and asymmetry has improved, its downside risk remains limited, and it is more of a low-beta infrastructure company rather than a candidate for valuation revaluation. In contrast, Circle still offers stronger investment prospects, as regulatory changes could significantly alter its profit margins and valuation.
Tether’s hiring of top-tier (Big Four level) auditors marks a major step in its institutional credibility, indicating improvements in transparency, governance, and readiness to operate under stricter financial regulation. While this does not guarantee a successful IPO, it clearly lowers one of the key listing hurdles and could signal future listing potential if regulatory conditions become more favorable.
This move will directly impact Circle: increased competition from a more institutionalized Tether could compress Circle’s relative valuation premium, but it will also validate the overall effectiveness of the stablecoin model and potentially expand its market size. In this sense, a more transparent, institutionally aligned Tether will challenge Circle’s market position while reinforcing the broader argument that stablecoins are a core financial infrastructure.
Even after the CLARITY Act, Circle is unlikely to reach Tether’s profit margins, but the gap could narrow significantly. Tether’s higher margins are due to retaining nearly all reserve income, fewer regulatory restrictions, and a very low revenue-sharing ratio. Under the CLARITY framework that limits yield transfers, Circle will face higher compliance costs, stricter reserve requirements, and possibly continue (albeit renegotiated) revenue sharing with distribution partners like Coinb.
The CLARITY Act could clearly boost Circle’s profit margins. If yields cannot be transferred to users, issuers will retain more economic benefits, and Circle’s bargaining power in renegotiations will increase. Coupled with scale and institutional adoption, this could drive margins higher from the current double digits to over 20%.
If USDC continues to grow at a similar pace, Circle’s valuation remains justified. Over the past 18 months, USDC’s circulating supply increased by about $46 billion, reaching $79 billion, indicating high adoption. As a settlement and liquidity layer, Circle currently earns about 4% on reserves, generating roughly $3.2 billion in gross revenue. After deducting yield sharing and costs, net income is approximately $2-2.3 billion.
If USDC expands to $120-150 billion, gross revenue could reach $4.8-6 billion; with profit margins rising to 20-25%, net income could be $1-1.4 billion. Applying a P/E ratio of 25-30, its valuation range would be approximately $250-420 billion, higher than the current market cap of about $245 billion.
However, this valuation heavily depends on USDC’s continued growth. Recent data shows USDC supply growth has started to plateau, indicating the market has begun to anticipate a slowdown. Therefore, Circle’s investment is no longer just a valuation re-rating driven by regulatory tailwinds but increasingly relies on sustained growth. Continued expansion and improved economic benefits of USDC are necessary to justify current share prices.
10x’s base target price for the next 12 months is $120. If USDC growth accelerates again and margins improve significantly, it could rise to $150; but if growth stalls and the current economic environment persists, there is a risk of dropping to $80.

Summary
The CLARITY Act accelerates the transition of stablecoins into regulated products, especially when combined with developments like the GENIUS ETF framework and Treasury-backed structures. The ultimate result is a shift of stablecoin reserves into regulated money market products. This dynamic is structurally positive for infrastructure players like Circle but adverse for yield-dependent DeFi tokens and protocols.
Before the CLARITY Act (if enacted), stablecoins were a hybrid tool—both a payment instrument and a yield-generating asset, also serving as core collateral in DeFi. Under the proposed framework, this model fundamentally shifts: stablecoins are defined solely as payment tools, with yields limited to regulated products.
This causes a clear redistribution of value. Potential winners include Circle, Treasury-backed ETF structures, custodians, and other compliant financial infrastructure; losers are Coinb’s monetization flexibility and DeFi yield protocols and “earn” products, which face structural resistance.
In fact, the Office of the Comptroller of the Currency (OCC) not only restricts yields but also redefines who can earn them. The result is a transfer of economic value from native crypto channels (Coinb and DeFi) to regulated financial infrastructure.
The main beneficiaries of the CLARITY Act are likely to be Circle, MKR, and BitGo, although BitGo’s low profit margins and about 50% post-IPO decline make its valuation more attractive. Conversely, Coinb and a range of DeFi protocols—including 1inch, Aave, COMP, dYdX, Sushi, and Uniswap—are structurally disadvantaged. To some extent, markets are already digesting these changes; the CLARITY Act is less a new catalyst than an amplification of existing trends.