Дослідження з перевіркою джерел: CFTC Passive Software NO

Verified source facts

1. Issuer,The position was announced by CFTC Market Participants Division.,cftc-release 2. Registration,It concerns IB and associated-person registration recommendations.,cftc-release 3. Activity,It applies solely to software facilitating user trading with registered FCMs, IBs and DCMs.,cftc-release 4. Conditions,The release says the position is subject to specified conditions.,cftc-release

Comparison at a glance

1. Usage and measurement test: Eligibility

Stablecoin adoption cannot be inferred from a single gross counter. The eligibility dimension concerns product, region and account. Define the economic job, unit of observation, time window and entities included before counting, then verify live access. Otherwise one routed transaction, exchange rebalance or contract hop may be mistaken for several independent users or payments.

Separate ledger events from economic outcomes. A transfer can be real on-chain yet still represent internal treasury movement, automated arbitrage, bridge routing, collateral management or redemption rather than a purchase. Official sources can frame the categories, but they do not resolve false entitlement. The dataset and classification method therefore belong beside every headline number.

For eligibility, publish the numerator, denominator and exclusions that support the claim. Make the analyst verify live access, and compare at least one activity metric with one outcome metric relevant to product, region and account. Because false entitlement remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

2. Usage and measurement test: Effective time

The effective time dimension concerns dated UTC transition. Define the economic job, unit of observation, time window and entities included before counting, then convert locally.

Official sources can frame the categories, but they do not resolve missed deadline.

For effective time, publish the numerator, denominator and exclusions that support the claim. Make the analyst convert locally, and compare at least one activity metric with one outcome metric relevant to dated UTC transition. Because missed deadline remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

3. Usage and measurement test: Tier

The tier dimension concerns quantity band and ratio. Define the economic job, unit of observation, time window and entities included before counting, then map current balance.

Official sources can frame the categories, but they do not resolve wrong bucket.

For tier, publish the numerator, denominator and exclusions that support the claim. Make the analyst map current balance, and compare at least one activity metric with one outcome metric relevant to quantity band and ratio. Because wrong bucket remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

4. Usage and measurement test: Valuation

The valuation dimension concerns collateral ratio or haircut. Define the economic job, unit of observation, time window and entities included before counting, then stress lower value.

Official sources can frame the categories, but they do not resolve buffer erosion.

For valuation, publish the numerator, denominator and exclusions that support the claim. Make the analyst stress lower value, and compare at least one activity metric with one outcome metric relevant to collateral ratio or haircut. Because buffer erosion remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

5. Usage and measurement test: Debt

The debt dimension concerns outstanding principal and interest. Define the economic job, unit of observation, time window and entities included before counting, then recalculate health.

Official sources can frame the categories, but they do not resolve liquidation.

For debt, publish the numerator, denominator and exclusions that support the claim. Make the analyst recalculate health, and compare at least one activity metric with one outcome metric relevant to outstanding principal and interest. Because liquidation remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

6. Usage and measurement test: Transfers

The transfers dimension concerns deposit and withdrawal state. Define the economic job, unit of observation, time window and entities included before counting, then verify route.

Official sources can frame the categories, but they do not resolve trapped funds.

For transfers, publish the numerator, denominator and exclusions that support the claim. Make the analyst verify route, and compare at least one activity metric with one outcome metric relevant to deposit and withdrawal state. Because trapped funds remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

7. Usage and measurement test: Orders

The orders dimension concerns open positions and orders. Define the economic job, unit of observation, time window and entities included before counting, then inventory exposure.

Official sources can frame the categories, but they do not resolve orphan strategy.

For orders, publish the numerator, denominator and exclusions that support the claim. Make the analyst inventory exposure, and compare at least one activity metric with one outcome metric relevant to open positions and orders. Because orphan strategy remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

8. Usage and measurement test: Disclosure

The disclosure dimension concerns official dated source. Define the economic job, unit of observation, time window and entities included before counting, then retain evidence.

Official sources can frame the categories, but they do not resolve stale assumption.

For disclosure, publish the numerator, denominator and exclusions that support the claim. Make the analyst retain evidence, and compare at least one activity metric with one outcome metric relevant to official dated source. Because stale assumption remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

9. Usage and measurement test: Recovery

The recovery dimension concerns post-change account state. Define the economic job, unit of observation, time window and entities included before counting, then reconcile balances.

Official sources can frame the categories, but they do not resolve silent mismatch.

For recovery, publish the numerator, denominator and exclusions that support the claim. Make the analyst reconcile balances, and compare at least one activity metric with one outcome metric relevant to post-change account state. Because silent mismatch remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

10. Usage and measurement test: Stop rule

The stop rule dimension concerns unverified control or status. Define the economic job, unit of observation, time window and entities included before counting, then do not add risk.

Official sources can frame the categories, but they do not resolve irreversible loss.

For stop rule, publish the numerator, denominator and exclusions that support the claim. Make the analyst do not add risk, and compare at least one activity metric with one outcome metric relevant to unverified control or status. Because irreversible loss remains unobserved, the conclusion should describe measured behavior rather than declare universal adoption.

Sources and editorial method

• Passive software no-action release — CFTC
• Staff letters registry — CFTC
• Latest news registry — CFTC