Circle had its worst day as a public company on Tuesday. CRCL fell 20%, erasing $5 billion in market cap on volume nearly 4x its 90-day average. Coinbase dropped 11% in sympathy.

The catalyst: a new draft of the CLARITY Act that would ban passive yield on stablecoin balances. Since 95.5% of Circle’s revenue comes from interest on USDC reserves, the market treated the bill as an existential threat.

Bernstein, the Wall Street research firm with a $190 price target on CRCL, thinks the market is reading it wrong. The question is whether a 20% haircut on an already volatile stock is a rational repricing or a gift.

However, the CLARITY Act might be the best thing that ever happened to Circle’s margins. 

In this issue, we’ll go over:

  • The issuer vs. distributor distinction that Bernstein says the market is botching, and why the bill’s real target is Coinbase’s leverage, not Circle’s revenue
  • The $908 million question: how Circle’s revenue-sharing deal actually works, why it likely renews in five months, and what a few points of margin improvement means at scale
  • Our own bottom-up valuation using Citi’s stablecoin TAM, actual Fed dot plot data, and Circle’s reported financials, with bear, base, and bull scenarios
  • Why AI agent payments and Circle’s own blockchain sit outside the model entirely, but could rewrite the multiple
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