The biggest outcome of the Clarity Act may be the creation of an entirely new market for “performance as a service,” according to Joe Vollono, chief commercial officer at stablecoin infrastructure firm STBL.
At the center of the debate is Section 404 of the proposed legislation, which would prohibit Digital Asset Service Providers (DASPs) and their affiliates from offering performance solely based on owning a digital asset.
The provision could fundamentally reshape the way cryptocurrency users earn returns, moving the market away from passive “hold-to-earn” products and toward more active, regulatory-compliant return-generating strategies.
“What this effectively does is change the industry from a hold-to-earn market to a use-to-earn market,” Vollono told CoinDesk in an interview. “Compliant performance strategies will be needed to generate rewards on what would otherwise be idle capital.”
The Clarity Act has already passed the Senate Banking Committee and is now expected to move to the Senate floor to merge with the Senate Agriculture Committee’s version of the bill before House reconciliation, with an optimistic timeline pointing to a full vote as early as July. Regulators would then have approximately 12 months to implement the framework.
Vollono, who spent more than seven years at Morgan Stanley and worked at SIFMA, where he worked on industry advocacy and market structure issues, said the implications of the Clarity Act extend far beyond the performance products themselves. He argued that regulatory clarity could finally unlock large-scale institutional participation in crypto markets.
“Once these issues are resolved, large-scale capital will be allowed to enter the market,” he said. “That’s the real catalyst here.”
The passage of the Clarity Act is widely seen as a potential turning point for crypto markets because it would establish the first comprehensive US regulatory framework for digital assets, ending years of uncertainty over whether and how tokens fall under the jurisdiction of the Securities and Exchange Commission (SEC) or the Commodity Futures Trading Commission (CFTC).
The legislation would create clearer rules for exchanges, brokers, stablecoin issuers and decentralized financial platforms, a move that many analysts say is necessary before large institutional investors, banks and asset managers can commit capital at scale. Supporters argue that regulatory clarity could reduce legal risk, improve consumer protection, and provide traditional financial companies with the compliance framework necessary to create crypto products and services in the US rather than abroad.
The role of AI
The likely result, Vollono said, is the emergence of a middle layer of infrastructure providers focused on generating compliant performance. He said he expects many of those services to be powered by artificial intelligence that acts as an orchestration layer for regulated capital flows.
Potential beneficiaries include decentralized finance (DeFi) infrastructure providers, vault curators, collateral management platforms, automated treasury services, lending marketplaces, and reward systems.
“All of this can be automated through AI in a regulated market,” he said.
The underlying technology stack already exists, Vollono said, pointing to smart contracts, oracles, DeFi rails and API-based infrastructure that could be adapted to fit within a regulated framework.
“This creates a whole new world,” he said.
Legislation
The debate around the legislation has also exposed tensions between traditional banks and the cryptocurrency industry, particularly around stablecoins and deposit migration.
“There’s a lot at stake,” Vollono said. “Banks are worried about deposit flight, but I think that concern is largely overblown.”
He said the traditional fractional reserve banking model depends on banks maintaining large capital bases that can be lent out to create credit and liquidity. If deposits migrate to tokenized dollars or yielding blockchain products, that model could come under pressure.
Still, Vollono said he believes the eventual compromise will be beneficial to the incumbents rather than an existential threat.
“The smart incumbents are going to compete,” he said. “Banks don’t necessarily have to give up their market share.”
He suggested that banks could eventually secure reserves to issue their own stablecoins and generate compliant returns under the Clarity framework, opening the door to entirely new business models.
Stablecoin 2.0
That dynamic is fundamental to STBL’s own discourse.
The company describes itself as “stablecoin 2.0,” advocating a move away from the traditional centralized issuer model that dominates the market today.
Instead, STBL is building an infrastructure that allows users to mint stablecoins backed by real-world assets while retaining the economics generated by the underlying reserves.
“Users who add value to the ecosystem should participate in the economy,” Vollono said.
The company’s infrastructure is designed to support compliant yield management while allowing users, rather than centralized issuers, to capture the yield generated by reserve assets.
For Vollono, the Clarity Law could provide the regulatory framework necessary to accelerate that transition. “I will tell you what the law makes clear: money as a service has arrived,” he added.
Read more: Crypto Clarity Bill Has a 30% Chance of Passing This Year, Wintermute’s Hammond Says
