법정화폐 기반 스테이블코인의 경제적 분류와 정책적 함의: 통화고정형, 머니마켓형, 수익배분형 모델을 중심으로

초록

This study reclassifies fiat-backed stablecoins based on their "economic substance"—specifically reserve management and payout policy— rather than legal formalities, and analyzes the risk mechanisms and policy implications of each type from the perspective of monetary economics. While existing regulations tend to treat stablecoins as a monolithic asset class, this paper establishes a taxonomy comprising three distinct models: (1) Currency-Board Tokens, which function as "narrow banks" mirroring the Chicago Plan; (2) Money-Market Tokens, which exhibit "shadow banking" characteristics with inherent run risks as described by the Diamond-Dybvig model; and (3) Pass-Through Fund Shares, which operate as performance-based investment products. Empirical analysis, including the 2025 FDUSD de-pegging event, confirms that while Currency-Board models offer superior payment stability, Money-Market models remain structurally vulnerable to liquidity mismatches, and Pass-Through models are subject to market price risks. Based on these findings, this study proposes a "dual-track" regulatory framework that balances micro-prudential and macro-prudential objectives. From a micro-prudential perspective, capital requirements and liquidity coverage ratios (LCR) should be imposed on Money-Market issuers to mitigate run risks, while disclosure obligations must be strengthened for Pass-Through models to protect investors. From a macro-prudential perspective, policymakers must manage the risk of bank disintermediation caused by the proliferation of Currency-Board tokens. Furthermore, this paper suggests that Pass-Through models, if integrated with central bank reserves, have the potential to evolve into "Synthetic CBDCs," thereby serving as a new transmission channel for monetary policy. This research contributes to both academic theory and practical policy by applying classical financial theories to the digital asset landscape and offering a sophisticated, tiered regulatory approach

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