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Comparison of Hong Kong and US Stablecoin Regulations: Seven Suggestions for the Development of Digital Money in China
Stablecoin Regulations: A Comparative Analysis of Hong Kong and the United States with Development Suggestions for China
On May 21, the Hong Kong Legislative Council passed the "Stablecoin Regulation Bill". Almost simultaneously, the U.S. Senate also passed the "Stablecoin Uniform Standards Protection Act" (GENIUS). These two legal documents have sparked widespread discussion, but many commentators have not conducted an in-depth study of them. It is necessary to analyze these two documents specifically and explore the demands of all relevant parties.
I. Analysis of the Hong Kong Stablecoin Regulation Draft
The "draft" clearly defines stablecoins in five aspects:
Presentation format: expressed in terms of valuation unit or economic value storage format.
Scope of application: used for payment, debt settlement, investment, and trading.
Storage and transfer method: Can be done electronically.
Operating Platform: Operate on a distributed ledger or similar information storage repository.
Value anchoring basis: a single asset or a group/basket of assets.
The "draft" also made specific provisions regarding the regulation of stablecoins:
Overall, Hong Kong aims to provide innovative payment tools for the new economy while mitigating risks.
2. Analysis of the U.S. Stablecoin Unified Standards Protection Act
The regulatory logic of the "bill" in the United States and the "draft" in Hong Kong is generally similar, but they also have their own characteristics:
Similarities:
Differences:
Overall, both regions have legalized local currency stablecoins and brought them under regulation, promoting innovation while preventing risks.
3. Comparison of Stablecoins and Bank Notes
From a legal perspective, the issuance and management rules of stablecoins are basically the same as those of bank notes.
Stablecoins can be regarded as a type of currency under the conditions of fiat currency, similar in nature to early paper money and promissory notes.
4. Demands of Stablecoin Stakeholders
The success of stablecoins depends on whether they can meet the demands of all stakeholders:
Payer:
Recipient:
Issuer:
Technical Support Party:
Regulatory authorities:
5. The Impact of Stablecoins on Monetary Policy and Circulation Management
Stablecoins, as a type of currency, will have an impact on the money supply.
The issuance scale and regulatory model of stablecoins need to be included in the considerations of monetary policy. Based on the characteristics of distributed ledger technology, they may have circulation patterns different from traditional cash.
In terms of cross-border payments, stablecoins need to efficiently connect with the banking system to truly succeed.
6. Seven Suggestions for China
Adhere to technological neutrality and encourage financial innovation applications.
Understanding the Real Demand for Stablecoins
Legislate for stablecoins, promote innovation and prevent risks
Consider issuing a人民币 stablecoin
Use stablecoins to explore application scenarios for digital renminbi
Innovation of the connection between the RMB stablecoin and bank accounts
The development of the RMB stablecoin should prioritize serving emerging economies and the internationalization of the RMB.
In summary, the development of stablecoins requires a balance between innovation and risk. China can actively explore based on existing foundations to provide new payment tools for the development of the digital economy.