On Sept. 9, Tether and Fasanara Capital said they were launching StableFund, a private credit fund seeded with $400 million from the two sponsors and aimed at raising as much as $3 billion from third-party institutions. Tether said it would act as co-sponsor, source financing opportunities tied to USDT, and provide stablecoin settlement infrastructure.
Fasanara Capital, based in London, was founded in 2011 and co-founded by Francesco Filia. The firm manages about $6 billion in assets and focuses on fintech-driven private credit strategies. According to the article, StableFund will lend to fintech platforms across more than 60 countries, covering small-business lending, consumer credit, trade receivables, and supply-chain finance. The fund is registered in the Cayman Islands. The release did not say how much of the $400 million came from Tether, and Tether did not disclose that figure afterward.
Excess reserves dropped by $4.12 billion in one quarter
Six weeks before the StableFund announcement, on July 31, Tether published its reserve report as of June 30. Total assets stood at about $187.75 billion and total liabilities at about $183.64 billion. The difference, $4.11 billion, is what Tether calls excess reserves, the portion of reserve assets above liabilities.
That figure had been $8.23 billion on March 31. On that basis, excess reserves fell by $4.12 billion in one quarter, a 50.1% decline. Liabilities changed by only $106 million over the same period.
Tether did not provide a line-by-line explanation for the decline and described the quarter as “strong” in its release. The article says the explanation can be inferred from the assurance report by BDO.
Gold and Bitcoin were identified as the main pressure points
As of June 30, Tether’s reserves were not limited to U.S. Treasuries. The reserve assets listed in the article were:
- $114.96 billion in U.S. Treasuries
- $25.6 billion in reverse repos
- $40.3 million in cash and bank deposits
- $18.84 billion in precious metals
- $5.8 billion in Bitcoin
- $3.76 billion in publicly listed equities
- $5.24 billion in other investments
- $13.45 billion in secured loans
The article also says the $6.5 billion money market fund position Tether held at the end of 2024 had been fully exited.
Using the prices cited in the BDO report, gold fell from $4,668.06 per ounce on March 31 to $4,008.02 on June 30, a decline of 14.1%. Bitcoin fell from $68,200 to $58,600 over the same period.
Gold and Bitcoin together accounted for $24.6 billion, while excess reserves were only about $4.1 billion. The article argues that a 17% move in those two assets would be enough to wipe out the entire excess reserve cushion.
It also points to BDO’s equity bridge. Group equity at the start of the year was $6.34 billion. Financial results for the first half were negative $3.17 billion. After adding $943 million in capital, equity ended at $4.11 billion.
For a company whose gold and Bitcoin exposure is described as roughly six times its surplus, the article says a 2.2% cushion means further declines in those assets would keep eroding excess reserves, while not all losses have yet been fully recognized on the books.
The piece notes that Tether can point to $10 billion in profit for 2025 and audited surplus of $6.814 billion to show financial strength. Still, it says the direction is clear: excess reserves as a share of liabilities fell from 3.5% a year earlier, to 5.2% at the end of 2024, and then to 2.2% now. In the article’s framing, the decline came from asset depreciation rather than user redemptions.
Secured loans remain inside reserves despite an earlier pledge to eliminate them
The article then turns to secured loans, meaning loans Tether extends to borrowers against collateral.
In December 2022, after the collapse of FTX, Tether said it would “reduce secured loans in reserves to zero” over the course of 2023. At that time, the secured loan book stood at $6.1 billion.
The figures that followed moved in a different direction. The article lists $4.8 billion a year later, $8.19 billion at the end of 2024, $17.04 billion at the end of 2025, and $13.45 billion as of June 30, 2026. Tether described the latest $2.38 billion reduction as a “15%” cut.
At $13.45 billion, secured loans were 3.3 times the size of the $4.1 billion excess reserve cushion, according to the article.
BDO did not disclose the borrowers or the types of collateral. The wording in the latest report described the loans as “overcollateralized and regularly monitored,” while the prior three reports had described them as “fully collateralized by liquid assets.” The article flags that wording change.
It places several developments on the same timeline: excess reserves hit a record in the first quarter, were cut in half in the second quarter, Tether was still carrying loans it had promised three years earlier to eliminate, and then launched StableFund in the third quarter.
StableFund was not the only lending activity mentioned
The article says StableFund is not Tether’s only newer lending line. Bloomberg reported this month that, as of the end of June, U.S. precious metals dealer Gold.com owed Tether about $1.45 billion, and that Tether financed most of the funding behind the dealer’s $1.7 billion precious metals lease.
Separately, Tether said in November that it had extended about $1.5 billion in commodity trade credit and planned to “significantly expand” that business. In June, Tether and Ledn, a lender it has invested in, said holders of the XAUT gold token would be able to borrow against it later this year.
Tether’s position is that its investments are “funded by the company’s excess capital and profits and are fully segregated from USDT reserves.” The article says secured loans sit inside reserves, while the StableFund commitment appears likely to sit outside them. It also says neither the StableFund release nor the June reserve report clearly states that point.
The article questions Tether’s multiple roles in the structure
It says Fasanara itself is not the issue. The firm was co-founded in London in 2011 by Francesco Filia, manages more than $6 billion, and has spent a decade lending through fintech originators, which matches the business described for StableFund.
Even if the separation from reserves is real, the article argues the issue does not disappear because Tether occupies several roles at once. It is a sponsor sourcing loans. It is an adviser to the fund that holds those loans. It also issues the token used to move the fund’s money and operates the rails on which those transfers run.
Filia described Tether’s value as “the world’s largest stablecoin network, a crypto-native investor base with huge capital capacity, and the USDT rails.” He told GTR that the loans can remain in fiat, and that “the loans themselves and the fund equity do not need to be tokenized.” The token is used only for moving funds.
The article then says that if StableFund loans run into trouble — spread across 60 countries, covering consumer credit and small-business lending, and originated through 141 fintech partners working with Fasanara — Tether could face reputational pressure to support them. For a company with only a 2.2% cushion, it argues, any such support decision becomes a reserve question in substance, no matter which account the money comes from.
Over the 90 days through Sept. 22, USDT circulating supply fell by about $2.8 billion, or 1.5%. The article says that does not amount to a run. It says the third-quarter reserve report will show how excess reserves performed over the same period.
The GENIUS Act and Tether’s compliance route
The article also compares Tether’s structure with the GENIUS Act, signed on July 18, 2025. The law defines what qualifying payment stablecoin issuers may hold as reserves, including cash, insured deposits, U.S. Treasuries with remaining maturities of no more than 93 days, overnight repos, and government money market funds.
Section 4(a)(2) says reserves may not be pledged, rehypothecated, or reused directly or indirectly by a permitted payment stablecoin issuer, subject only to narrow exceptions. Treasury’s proposed issuance rules were published on Aug. 18, with comments due by Oct. 19. The law is expected to take effect on Jan. 18, 2027.
Tether’s answer is USAT, a separate token issued through Anchorage Digital Bank starting Jan. 27 and intended to meet compliance requirements. The same release said USDT is “moving toward” compliance.
The law sets two other dates the article highlights. Under Section 3(b), U.S. digital asset platforms may not offer non-compliant stablecoins three years after enactment, or July 18, 2028. Under Section 18, foreign issuers may enter the U.S. market after Treasury determines that their home-country regime is comparable.
The article argues that StableFund reflects the kind of structure the rule is meant to prevent, except assembled one layer outside the rule itself. The GENIUS Act does not stop a foreign issuer’s parent company from using its own equity to launch private credit. What it stops is the use of reserves for that purpose. That is why the undisclosed number — how much of the $400 million came from Tether, and from where — matters more than the fund’s headline size, according to the article.
A stablecoin issuer’s promise is redemption at par. When valuations move the wrong way, surplus is what supports that promise. As of the end of June, Tether’s surplus stood at $4.1 billion, half the March level.
What to watch in the next reserve report
The article says the third-quarter reserve report is expected around late October and points to three main items to watch.
- Whether excess reserves recover with a rebound in gold prices. If gold and Bitcoin rise, the cushion could rebuild. If they keep falling, pressure would increase.
- Whether secured loans continue to decline or start rising again. Tether pledged three years ago to eliminate them, but the balance later expanded.
- Whether the StableFund commitment appears in the reserve report or only at the group level. That would determine whether there is a firewall between the commitment and USDT reserves.
The article adds two more follow-up points. First, KPMG said on Aug. 13 that its 2025 audit found surplus that was $476 million higher than BDO reported for the same date, and Tether has not explained the basis for that difference. Second, Treasury’s comparability determination for foreign issuers under Section 18 will shape whether USDT can enter the U.S. market after 2027, while also raising a question: whether an issuer that sponsors private credit through a fund it advises is comparable to one that would not be allowed to do so.
Tether’s second-quarter release said reserves were strong. The article ends by saying that may be true, but the point of a cushion is the day reserves are no longer strong. In its telling, Tether lost half of that cushion in one quarter and responded by launching private credit.