The U.S. Federal Reserve has introduced the reserve and two-day redemption rules of the GENIUS Act, but the mortgage rules, liquidation thresholds and interest rates of DeFi lending may still be changed by governance votes, and the risk of borrowing fully reserved U.S. dollars has not disappeared. (Preliminary summary: The Fed promotes the implementation of the GENIUS Act: Stablecoin issuers must save money to prevent risks, and redeem within 2 days or liquidate) (Background supplement: The U.S. OCC is the first to make a decision on the GENIUS Act stablecoin final rules: effective on January 18, 2027, banks and non-silver issued currency paths have decided) The rules for the issuance of stablecoins are finally coming to fruition. On September 24, the U.S. Federal Reserve proposed two new rules to implement the GENIUS Act, requiring issuers to use reserve assets to support tokens and apply new capital and risk management standards; the draft also stipulates that redemption must be completed within two working days, and issuers must report to the regulatory authorities every month the number of stable coins in circulation. The bill will take effect on January 18, 2027, or 120 days after publication of the final rule, whichever comes first. The issuer finally has a set of rules that everyone can read, and we will see more national-level use cases, such as debt repayment and cross-border circulation of US dollars. However, the DeFi lending market into which stablecoins eventually flowed is still far from mature. The problem pointed out by Mike Hathaway and Joseph Quintilian, co-founders of DeFi lending protocol Ajna, is: in a typical on-chain lending market, the price provided by the oracle determines when a loan will be liquidated, and token holders can vote to change the entire set of rules, often after the money is loaned out. This combination was originally intended to protect the user. Curated vaults and standardized price feeds have removed the barriers to early DeFi. Institutions now have a vetted market menu. They only need to evaluate a counterparty, and the risk language is consistent with the habits of credit committees. But convenience comes from concentration, and risk sits on concentration. When the same risk managers and the same price source underwrite hundreds of billions of dollars in loans, a bad quote or a brief price spike can spread along all the markets that depended on that source, dragging into liquidation markets that had nothing to do with the original error. The examples cited in the article span more than a year. In November 2025, Stream Finance suffered a loss of US$93 million, and analysts traced possible exposures of approximately US$285 million spread across protocols such as Euler, Silo, and Morpho; in February this year, Moonwell set a price feed set by a governance vote, which quoted cbETH at approximately US$1.12, while the actual price was approximately US$2,200, leaving approximately US$1.78 million in bad debts; in March, Aave The setting of the previous risk control tool expired, causing wstETH to be undervalued by about 2.85%, triggering a liquidation of about $27 million. In September, Vesu liquidated 47 positions worth about $3 million just because of two minutes of incorrect price information. A comparison of the amount of bad debts and liquidations in four DeFi lending cases in the past year (self-drawn by the dynamic area) After the money is lent out, who can change the terms? Institutional lending depends on the terms. If a governance vote could change collateral rules, liquidation thresholds, or interest rates after a loan is released, the loan would be unpriced, no credit department could underwrite a contract that might be rewritten by a token vote next week, and externally managed oracles might fail or become unavailable. The article reminds that Wall Street will recognize this pattern: "too big to fail" interconnection problems are being rebuilt without the capital buffers that the Federal Reserve now requires stablecoin issuers to have. The regulatory guarantee stops at the issuing end. A U.S. dollar that is fully reserved at the issuing end may still be borrowed into a market where the terms can be changed by voting next week, or it may be priced by a price feed that may be wrong for two minutes in a row. The more bank-like the issuer is, the more noticeable this gap will be. The solution proposed by Ajna is to make the change optional: there is no oracle, the lender chooses the price at which he is willing to lend, the interest rate is determined by a fixed formula in the contract rather than by voting, and the rules cannot be changed by anyone after the fund pool goes online. The price is that the vulnerability cannot be patched, and users can only choose to migrate to a new version. For institutions, the question of "who can change the terms of a loan after it is disbursed" is a better determinant of risk than "which market is the safest." Follow-up observations: Effective date and institutional capital flows The first line is timeline. The effective date of the GENIUS Act is set for January 18, 2027, and the OCC has also preemptively decided on its own version of the final rules in October. The two sets of rules are stacked, and the outline of the issuer’s compliance costs has been roughly determined. The current draft text governs reserves, capital and redemption, and does not address risks such as oracle failure or governance voting to change terms. This also means that the rules of the lending market will still have to be resolved by the market itself in the short term. The second line is where the money goes. After reserves, capital buffers and two-day redemptions are implemented, the dollar position on the chain will only be larger, and most of this money will first enter centralized infrastructure such as curatorial vaults. Whether institutions are willing to give up convenience for immutable terms will determine the shape of the next generation of lending markets. The costs of clause variability already have concrete figures to reconcile against the amounts for four incidents since 2025. Related reports: Whales short CRV, Aave spends millions to pay? Why does a DeFi lending agreement generate bad debts? Why does a fishing trip reveal the contradictory soul of whether DeFi can "have both fish and cake"? Venus Attack Apocalypse The Feasibility of Liquidation-Free Lending Protocols: DeFi’s High Yields and Flexible Performance? 〈The GENIUS Act only protects the issuer! DeFi lending terms can also be changed by voting> This article was first published in Dongqu BlockTempo "Dongqu Dongzhi - the most influential blockchain news media".