大历史视角下的CEX监管

MirrorPublished on 2023-10-17Last updated on 2023-10-17

Abstract

历史不会重复,只是押韵。传统世界与链上世界都经历过银行业大发展的时期,对比这两个时期能够给我们以全新的视角审视目前的CEX困局。

历史不会重复,只是押韵。传统世界与链上世界都经历过银行业大发展的时期,对比这两个时期能够给我们以全新的视角审视目前的CEX困局。

在上个世纪初,美国也经历了银行业大发展及银行券与美元强挂钩的时代,由于银行业的黄金抵押不足,引发了1907年的美国银行业危机。前事不忘,后事之师。

一、 以史为鉴,对比传统与链上世界

1900年,美国通过了黄金标准法案,将黄金确立为兑换纸币的唯一标准。黄金对于1900年的美国正如比特币对于当前Web3世界的意义。

1905年,美国银行出现了井喷。于此类似的是DeFi Summer也在2020年席卷链上市场,DEX、借贷、机枪池协议对于链上世界的意义与银行对于美国金融的意义类似。

1906年,美国股市经历了投机繁荣。2021年NFT Summer的出现也是极端流动性带来的泡沫狂欢。

1907年,美国出现银行危机,纽约证券交易所( New York Stock Exchange) 从前一年的高峰期,下跌了接近50%。1907年10月纽约人信托公司投机失败的消息终于引发了挤兑恐慌进而只能关张。流动性紧缩以及投资者的恐慌蔓延到了股票交易所,金融机构回收贷款使股票市场的现金回流受阻,活期贷款利率达到了100%,股票交易所面临关闭的困境。2022年,链上世界的Luna、3AC和FTX的连番暴雷表演,让行业出现了恐慌。

在1907年危机期间,JP摩根承担了最终贷款人的角色,组织了对银行和信托机构的救援,避免了纽约证券交易所的关闭,并策划了对纽约市的金融救助。在2021年加密行业内扮演JP摩根角色的是CZ,他也正在筹集资金决心对于优质项目进行救助。

二、这一次,我们的解决方案是中心化的吗?

在1913年,在1907年大恐慌后的3年,美联储成立,它的重要职责则是推动资金在银行系统内安全高效地流转。在其设立后银行开始更合规的运行。所以,行业大咖普遍认为:历史必将重复,CEX头上的紧箍将在未来不断收紧。

但是从比特币引发的星星之火,不是为了打造和旧世界一样的金融系统,而是在最小化中心信任的前提下,打造全新的系统。目前的CEX是行业无法绕开的交易、信息的集散地。虽然CEX面临了Fraud的问题,但是要避免将洗澡水和孩子一起倒出去,更多采用行业自律的方式。

三、CEX自我监管的尝试

(一)行业依然在自我进化

9月份对以太坊的升级从根本上降低了能源消耗,为其高效处理高交易量铺平了道路,他也发布了未来时间的升级路线图。我们可以认为,以太坊的长期价值也不断凸显。

(二)未来CEX将强调自我监管

经过FTX的危机后,交易所为了大小用户疑虑必将加强自我监管。目前行业已经有一些CEX的自我监管方向:

一是CEX运行的过程可控。确保将盗窃和欺诈行为降至最低。未来CEX需要事实披露自身流动资产,以确保客户存款不被挪用。

二是定期披露。CEX需要披露是否进行了可以的内部交易或者向与关联方有巨额的账目往来。

三是自我革命。CEX需要披露是否进行了可以的内部交易或者向与关联方有巨额的账目往来。

四、外部监管趋严,但是全球的监管框架短期难以落地

(一)全球化的监管框架短期难以落地

从历史上来看,由于行业尚处于一个早期阶段,如巴塞尔协议3一般重大且严格的监管框架难以在短期无法落地。

(二)在地化的监管框架可能会成为主流

图片来源:BCG, Foresight Ventures

由于各国对于加密货币的态度出现了比较明显的分歧。有的国家依然希望加密赛道在本地的繁荣,而有的国家干脆直接取缔。

此外,本次风险的传染性较小,很难相信巴厘岛的G20峰会能够就此达成实质性的监管框架。

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