We released our preliminary analysis of the recently enacted GENIUS Act and its applicability to @aave's GHO token. Our primary conclusion: GHO, in its current form, does not qualify as a "payment stablecoin" under the Act's statutory definition. Here's what you need to know 👇 The Act’s definition requires an issuer to be legally obligated to redeem a token for a fixed monetary value. GHO does not meet this dispositive prong, as no legal person—neither the Aave DAO nor any facilitator—undertakes this redemption obligation. GHO's crypto-collateralized design is fundamentally distinct from the cash-reserve model the statute anticipates. This threshold determination places GHO outside the Act's primary regulatory regime. Key consequences include: 🔹 Issuer & Intermediary Prohibitions Inapplicable: The Act's restrictions on issuing or offering payment stablecoins to U.S. persons do not attach to GHO. 🔹 Prudential Rules Inapplicable: GHO is not subject to the detailed rulebook for permitted issuers, including the mandate for 1:1 cash reserves or the obligation to implement technical capabilities for blocking and freezing transactions at an issuer level. 🔹 Statutory Protections Not Conferred: While avoiding these regulatory burdens, GHO does not benefit from the Act's statutory protections. This includes the powerful bankruptcy priorities for holders and the explicit safe harbors from securities laws that are granted only to permitted stablecoins. Our analysis recommends that GHO maintain its current architecture and ensure communications are precise about its design to preserve this status. For a full, section-by-section breakdown of the GENIUS Act and its technical implications for GHO, read the complete review.