Which Tokens Are Considered "Convertible"? AICPA Requires Clear Classification
The new guidelines require stablecoin issuers to clearly disclose the classification and circulation status of various tokens. The report categorizes tokens into three main types:
Convertible Tokens: Immediately convertible to equivalent fiat currency according to contract terms.
Temporarily Non-Convertible Tokens: Such as time-locked tokens not yet unlocked, or tokens in temporarily restricted accounts.
Permanently Non-Convertible Tokens: Including test tokens, permanently frozen tokens, etc.
Issuers need to start from the "actual minting quantity" on the blockchain, subtract the above non-convertible types, and calculate the truly circulating and convertible stablecoin quantity, and disclose related blockchain addresses and smart contract information for public verification.
Redemption Asset Composition Must Be Specifically Disclosed: Cash, US Bonds, Holder Information Explained Together
In the asset disclosure section, the guidelines require issuers to comprehensively explain the reserve contents supporting stablecoins, covering the following points:
Asset Types: Cash, cash equivalents, money market funds, short-term US Treasury bonds, repurchase agreements, etc.
Holder Identity and Jurisdiction: Disclose which type of financial institution holds the assets, the country, and the regulatory environment.
Whether Assets Are Pledged or Have Usage Restrictions.
Account Nature: For example, whether it is a custodial account, whether it has bankruptcy isolation protection.
These data will help investors determine whether assets can be quickly mobilized and not constrained by legal or financial risks in case of large-scale redemption needs.
1:1 Reserve and Time Discrepancy: Audit Mechanism First Included in Guidelines
The third part of the report clearly states that issuers should disclose the comparison between the total amount of convertible tokens and total reserve assets, and answer a core question: "Is 1:1 reserve maintained?"
According to the guidelines, if the issuer's terms specify that each stablecoin should correspond to one dollar of reserve assets, then the third-party auditor must verify this, disclose whether assets are sufficient, and explain any potential surplus or shortage situations.
Additionally, the report requires disclosure of specific amounts and reasons for "time discrepancies" and "temporary differences", including:
Tokens paid but not yet minted.
Redemption requests paid but funds not yet distributed.
Temporarily non-convertible situations due to account restrictions or technical issues.
This information must be included in the report and disclose whether it has exceeded the processing time allowed in the issuer's terms, ensuring the public understands these differences are "temporary" and not systemic risks.
Can Assets Be Misused? AICPA Requires "Disclosure of Rights", But Does Not Directly Prohibit
Notably, the report does not prohibit stablecoin issuers from using reserve assets, such as for repurchase agreements, lending, or re-pledging. Instead, AICPA emphasizes "honest disclosure of asset usage rights and restrictions".
According to the guidelines, issuers must disclose whether they have rights to transfer, sell, lend, or re-pledge assets, and whether assets can only be used for token redemption. They must also explain the type of account where assets are stored, whether it has bankruptcy isolation, whether insurance has been purchased, or whether assets have been used as collateral.
This means that as long as information is fully disclosed, market participants can make judgments based on their own risk tolerance. For some issuers, this provides operational flexibility; for investors and audit institutions, it serves as a revealing mirror.
AICPA Guidelines Are Not Mandatory Regulations, But May Become Audit Basis
Although these guidelines do not yet have legal force, they are clearly designed to correspond with US accounting attestation standards (AT-C Section 205), meaning that in the future, stablecoin companies undergoing third-party audits will likely need to operate according to these standards.
AICPA also recommends that issuers incorporate the guidelines into their terms and operational rules when establishing them to reduce legal and reputational risks.
Industry observers point out that while the AICPA guidelines do not have regulatory force, they may become the basis for future legislation by U.S. regulatory agencies. Stablecoin issuers like Circle of USDC, or Tether, which is actively moving towards compliance, would help enhance market trust if they are the first to adopt these guidelines.
Risk Warning
Cryptocurrency investment carries high risks, and its price may fluctuate dramatically. You may lose all of your principal. Please carefully assess the risks.