[GUSD] MIP6 Collateral Onboarding Application

[GUSD] MIP6 Collateral Onboarding Application for Gemini USD Token

  1. Who is the interested party for this collateral application?


  1. Provide a brief high-level overview of the project, with a focus on the applying collateral token.

GUSD is a fully collateralized USD stablecoin operating on the Ethereum network. GUSD is issued by Gemini Trust Company, LLC, and fiat funds are held by State Street Bank and Trust Co (NYSE:STT).

  1. Provide a brief history of the project.

Gemini was founded by the Winklevoss brothers in 2013, initially focusing on the exchange business. They have since expanded into general custody services as well as stablecoin issuance. The Gemini USD was launched in September 2018 and for a time was one of the largest stablecoins with over $100M circulating at its peak. The circulating supply of GUSD has since declined as it was dwarfed by USDC, USDT and other stablecoins with wider trading and defi usage. The supply of GUSD is currently ~$11M, having grown from a trough of ~$4M at the end of 2019.

  1. Link the whitepaper, documentation portals, and source code for the system(s) that interact with the proposed collateral, and all relevant Ethereum addresses. If the system is complex, schematic(s) are especially appreciated.

Whitepaper: https://gemini.com/static/dollar/gemini-dollar-whitepaper.pdf

Website: https://gemini.com/dollar

Source Code: https://github.com/gemini/dollar

GUSD token contract: https://etherscan.io/token/0x056fd409e1d7a124bd7017459dfea2f387b6d5cd

  1. Link any available audits of the project. Both procedural and smart contract focused audits.

Accountant’s reports at bottom of page: https://gemini.com/dollar#reports

Trail of bits contract audit: https://gemini.com/static/dollar/gemini-dollar-trailofbits-audit.pdf

  1. Link to any active communities relating to your project.

Twitter: https://twitter.com/Gemini

  1. How is the applying collateral type currently used?

GUSD is used to make USD transfers and other transactions on the Ethereum network. GUSD can be redeemed for USD via Gemini exchange accounts. GUSD is also accepted for deposits and lending via BlockFi.

  1. Does one organization bear legal responsibility for the collateral? What jurisdiction does that organization reside in?

GUSD is issued by Gemini Trust Company, LLC, a New York state based trust company. The fiat USD corresponding to issued GUSD is held by State Street Bank and Trust Company (NYSE:STT). Monthly accounting examinations are performed by BPM, LLP.

  1. Where does exchange for the asset occur?

GUSD can be exchanged for USD at a fixed 1:1 rate on the Gemini exchange. GUSD also has a few trading pairs on other centralized exchanges such as OKEx, HitBTC, and ZB.

  1. (Optional) Has your project obtained any legal opinions or memoranda regarding the regulatory standing of the token or an explanation of the same from the perspective of any jurisdiction? If so, those materials should be provided for community review.

I am not aware of any publicly available legal opinions addressing the project or token’s regulatory standing.

  1. (Optional) Describe whether there are any regulatory registrations for the token and provide related documentation (including an explanation of any past or existing interactions with any regulatory authorities, regardless of jurisdiction), if applicable.

Gemini Trust Company, LLC received authorization from the New York DFS to issue GUSD before operations began in 2018. Press release here: https://www.dfs.ny.gov/reports_and_publications/press_releases/pr1809101

  1. (Optional) List any possible oracle data sources for the proposed Collateral type.

The GUSD oracle price could be pegged to $1 similarly to the current USDC oracle.

  1. (Optional) List any parties interested in taking part in liquidations for the proposed Collateral type.


GUSD has certainly seen better days, with it’s circulating supply off ~90% since its peak. That being said, it has the advantage of having a different issuer and custodian than USDC, TUSD, and the Paxos stablecoins (PAX, HUSD, BUSD). This could help diversify Maker’s credit and custody exposures and reduce overall risk. To avoid a Coinbase dominated USDC monoculture, we should consider dogfooding some competing stablecoins by onboarding them before they have found wide adoption in DeFi.


All great points. The more diversity, the better. Nothing substantive to add aside from thanking monet-supply for pushing this. That excitement is contagious!