[ARFC] Onboard frxUSD to Aave V3 Core Instance on Ethereum


Title: [ARFC] Onboard frxUSD to Aave V3 Core Instance on Ethereum
Author: @ACI
Date: 2025-12-08

Proposal updated with latest risk parameters, provided by Risk Service Providers 2025-12-26


Summary

This ARFC proposes onboarding frxUSD to the Aave V3 Ethereum Core instance.

Motivation

Frax has upgraded the frxUSD architecture, improving transparency, collateral quality, and risk controls. The stablecoin is backed by real-world financial assets such as U.S. Treasuries and cash-equivalents, with reserves publicly tracked and are now Genius Compliant. This results in a more predictable and resilient model suitable for Aave.

Furthermore, Frax has committed to leverage the yield generated by its RFR Treasury reserves, to support and incentivize usage on Aave. This yield is derived from short-duration U.S. Treasuries and other cash-equivalent instruments and will be redistributed in two ways:

  • Yield top-ups for aFrxUSD suppliers: If Aave’s organic supply APY is below the RFR yield, Frax will distribute part of this yield to aFrxUSD holders to bring their APY up to that RFR benchmark. This ensures that depositors receive a stable, competitive baseline yield, independent of borrowing demand on Aave.
  • 25% of RFR Yield shared with sGHO holders: A portion of the Treasury yield will also be directed to sGHO holders, reinforcing strategic alignment with Aave’s ecosystem.

These mechanisms create stronger alignment between Frax and Aave, improve yield stability for depositors, and support healthier liquidity conditions on Aave V3 Ethereum

Specifications

frxUSD Token Contract Address:

Ethereum: 0xCAcd6fd266aF91b8AeD52aCCc382b4e165586E29

Chain: Ethereum

Risk Parameters

Parameter Value
Asset frxUSD
Isolation Mode No
Borrowable Yes
Collateral Enabled No
Supply Cap 60,000,000
Borrow Cap 55,000,000
Debt Ceiling -
LTV -
LT -
Liquidation Bonus -
Liquidation Protocol Fee 10%
Variable Base 0%
Variable Slope1 5.5%
Variable Slope2 50%
Uoptimal 80%
Reserve Factor 10%

frxUSD E-Mode

Asset frxUSD USDC USDT USDe GHO
Collateral Yes No No No No
Borrowable No Yes Yes Yes Yes
Max LTV 75% - - - -
Liquidation Threshold 78% - - - -
Liquidation Bonus 4.5% - - - -

Useful Links

Disclaimer

ACI is not directly affiliated with Frax and did not receive compensation for creating this proposal. Some ACI employees may hold FRAX tokens.

Next Steps

  1. Publication of a standard ARFC to continue collecting community & service provider feedback before escalating proposal to ARFC snapshot stage.
  2. If the ARFC snapshot outcome is YAE, publish an AIP vote for final confirmation and enforcement of the proposal.

Copyright

Copyright and related rights waived under CC0

2 Likes

Marc, question: What changed during the 1.5 months from this [TEMP CHECK] Onboard frxUSD to Aave v3 Ethereum Core Instance - #4 by ACI

ACI said : A major concern lies in the market cap of $82.92M. I see 100M here https://defillama.com/stablecoin/frax-usd

ACI also said: we do not believe that onboarding this asset would result in growth and revenue that would justify onboarding.

I mean, that was 54 days ago. What changed?

Hey @JosueMpia

Over the last 1.5 months, several material conditions changed:

– Chaos Labs completed an independent proof-of-reserve oracle, giving Aave the external verification that was missing in the first vote.
– Total circulating supply expanded from ~83m to ~113m, reducing concentration risk and pushing frxUSD into the size range ACI previously referenced.
– frxUSD was accepted as the only GENIUS-compliant stablecoin in StableChain’s pre-deposit vaults, strengthening the regulatory-aligned profile.
– Curve selected frxUSD as a peg-keeping counterasset for crvUSD alongside USDC and USDT, demonstrating market trust in stability and redemption mechanics.
– Multiple synthetic and CDP stablecoin issuers added frxUSD as their peg-keeping liquidity, broadening ecosystem demand and reducing tail-risk scenarios.

So we believe The combination of external validation, increased supply scale, and expanded real integrations changes the condition versus the state at the previous TEMP CHECK.

3 Likes

allow me to point out the “motivation” section of this proposal.

2 Likes

Awesome. Thanks guys.

1 Like

Hello,

This time I am supportive of this proposal.
Last time I mentioned the small market cap as an argument against adding the asset.
Also the additional rewards for sGHO holder make it more attractive for the DAO and GHO itself.

Happy to see that frxUSD market cap has been growing and hopefully continues to do so.

3 Likes

I guess it’s a good thing decentralized stablecoins support each other.

No decentralized => stupid comment. Sorry.

But I’m no expert to measure associated risks

Summary

LlamaRisk supports onboarding frxUSD to the Aave V3 Ethereum Core instance. Since our previous analysis, frxUSD has improved across several dimensions, including the completion of third-party audits, the establishment of a separate balance sheet for frxUSD and legacy FRAX, and fully transparent, publicly verifiable on-chain reserves. DEX liquidity has also improved in recent months; however, moderate LP concentration remains, with nearly all depth residing on a single venue, namely Curve.

Some other risks include the absence of a bug bounty program with a recognized third-party provider (the current program is internal), limited transparency around changes to reserve composition, and the lack of a timelock mechanism for contract upgrades. In light of these considerations, we recommend onboarding frxUSD with collateral disabled on Aave.

1. Asset Fundamental Characteristics

1.1 Asset

According to the Aave Asset Class Allowlist (AAcA), Frax USD (frxUSD) is categorized as a reserve-backed stablecoin, as it is pegged to the USD and backed by tokenized U.S. Treasury funds. These reserves consist of Superstate’s USTB, WisdomTree’s WTGXX, Securitize’s BUIDL, Bridge’s USDB, and Circle’s USDC, with their respective compositions shown below. frxUSD currently maintains a collateralization ratio of 102.38%.


Source: frxUSD Reserve Composition, Frax, December 12, 2025

1.2 Architecture

frxUSD is an ERC-20 stablecoin natively minted on Ethereum and backed by tokenized U.S. Treasury funds. These reserves are held by “enshrined custodians,” who are responsible for managing the minting and burning of frxUSD and are mandated to maintain sufficient cash and cash equivalents to back the outstanding supply. Mint and redeem requests are processed either intra–business day or by the next business day, depending on the custodian and the timing of the request. Currently, frxUSD is backed by five assets, as shown below:

Custodian Asset frxUSD Mint Fee frxUSD Redeem Fee frxUSD Mint Cap
Superstate USTB 0 bps 1 bps 50M
WisdomTree WTGXX 0 bps 1 bps 0.1M
Securitize BUIDL 0 bps 1 bps 0.1M
Bridge USDB 0 bps 1 bps 0.1M
frxUSD Redemption Contract USDC 0 bps 0 bps 200M

Minting
The flow of funds for minting begins when a whitelisted user initiates a request to mint frxUSD with a custodian by depositing accepted RWA. Upon receiving the deposit, the custodian mints frxUSD equivalent to the deposited RWA and transfers the newly minted frxUSD to the user. As shown in the table above, the frxUSD minting fee is zero.

Redemption
frxUSD is redeemable on demand for any custodian asset via one of the designated frxUSDCustodian contracts shown in the table above. The redemption process begins when a whitelisted user sends frxUSD to the custodian to initiate redemption. The custodian burns the received frxUSD, after which RWA equivalent to the burned frxUSD is transferred back to the user. A redemption fee of 1 bps applies for USTB, WTGXX, and BUIDL, while redemptions for USDC incur no fee.


Source: frxUSD Mint-Redemption Flow, LlamaRisk

FraxNet
In addition to primary mint and redeem flows, frxUSD has launched FraxNet, which facilitates cross-chain transfers using LayerZero and CCTP. Through FraxNet, users can complete KYB/KYC and participate in revenue sharing from T-Bill yield, while also gaining the ability to directly redeem frxUSD into fiat to their linked U.S. bank accounts via ACH wire. While FraxNet addresses have already been deployed, further details regarding on- and off-ramp partners are still awaited.

1.3 Tokenomics

As of December 12, 2025, frxUSD has a total supply of 111.72M, of which 103M is held on Ethereum. The supply of frxUSD is not fixed and can increase or decrease based on mint and redemption activity by whitelisted users depositing or withdrawing collateral through the enshrined custodians.

1.3.1 Token Holder Concentration


Source: Etherscan, December 12, 2025

The top 5 holders of frxUSD are:

The top 10 holders collectively own 94.76% of frxUSD on Ethereum; however, since these holdings are distributed across various DeFi applications, the associated concentration risk is low.

2. Market Risk

2.1 Liquidity


Source: frxUSD/USDC Swap Liquidity, DeFiLlama, December 12, 2025

Users can swap $26.3M frxUSD for USDC within a price impact of 7.5%.

2.1.1 Liquidity Venue Concentration


Source: LlamaRisk, December 13, 2025

The DEX liquidity for frxUSD is primarily composed of various stablecoins and is almost entirely concentrated on Curve, with the only other venue being a single Fraxswap WFRAX/frxUSD pool with approximately $3M in TVL. The largest frxUSD liquidity pool is the Curve crvUSD/frxUSD pool, which has $38.1M in TVL. Notably, there is an absence of direct, deep USDC or USDT sell-side liquidity.

2.1.2 DEX LP Concentration

frxUSD liquidity on Ethereum is moderately concentrated among a small number of entities, with the majority of liquidity provided by Frax Finance. This concentration reduces the likelihood of an abrupt liquidity withdrawal, as protocol-aligned liquidity is generally more stable and less prone to sudden outflows. Below is the breakdown for the top 5 pools by TVL on Ethereum (as of December 13, 2025):

2.2 Volatility


Source: frxUSD Secondary Market Price, LlamaRisk, December 13, 2025

The frxUSD price on Curve has generally maintained a relatively tight peg, except on June 26, 2025, when it temporarily depegged by 9.74% to $0.9026 due to a momentary depletion of sell-side liquidity in the pool. Since then, DEX liquidity has increased materially, particularly following the launch and growth of the Curve crvUSD/frxUSD pool, and frxUSD has consistently maintained its peg on secondary markets.

2.3 Exchanges

frxUSD is exclusively traded on DEXs and is not currently listed on any centralized exchange.

2.4 Growth


Source: LlamaRisk, December 12, 2025

The total supply of frxUSD on Ethereum stands at 103.15M, marking an all-time high following a recent surge between October 22 and October 24, 2025, during which the supply nearly doubled over the span of a few days. Of this amount, 89.52M is in free float, while the remaining 13.63M is locked, comprising 10.88M in the Fraxtal L1 Standard Bridge and 2.75M in the Frax Comptroller.

3. Technological Risk

3.1 Smart Contract Risk

All contracts influencing the frxUSD architecture on Ethereum have undergone independent audits by third-party security firms, and the findings were as follows:

  • FraxNet - Zellic (July 7, 2025): 1 medium, 5 low, and 2 informational, with all issues fixed except for one low-severity finding which was acknowledged by the team.
  • Frax0 Mesh - Zellic (September 24, 2025): 1 medium, 1 low, and 6 informational, with all issues resolved except for one informational finding.

3.2 Bug Bounty Program

Frax Finance continues to operate an internal Bug Bounty Program where participants can reach out anonymously to disclose vulnerabilities. Any contract deployed by FRAX-Deployer is in scope, including frxUSD and sfrxUSD. The bounty is calculated as the lower value of 10% of the total possible exploit or $10 million worth of FRAX+FXS (evenly split), with a “no questions asked” policy.

We recommend using a third-party provider that offers guarantees to whitehats, ensuring their findings will be treated in the fairest possible manner. This approach increases the likelihood of responsible disclosure and successful user deposit protection by involving a third party.

3.3 Price Feed Risk

Chainlink has a frxUSD/USD price feed live on Ethereum Mainnet since April 2025. This feed is categorized as high-market risk with a deviation threshold of 0.5% and a heartbeat of 86400 seconds. The price history of the oracle is shown below.


Source: LlamaRisk, December 12, 2025

The lowest price reported by the feed, 0.990154 on June 26, 2025, coincides with the period of extremely low secondary market liquidity and the depeg observed in the Curve crvUSD/frxUSD pool, as discussed earlier. The volatility parameters are as follows:

Std Dev Price Avg Abs Change Max Jump Size
7.22 bps 2.5 bps 93.57 bps

Given the stable behavior of the oracle alongside improving secondary market liquidity since November 2025, this feed can be considered suitable for pricing frxUSD on Aave.

3.4 Dependency Risk

Custodian Risk
frxUSD’s solvency depends on the institutional partners onboarded to back the asset. Currently, Superstate’s USTB and WisdomTree’s WTGXX together account for roughly 85% of the frxUSD backing, as shown in the balance sheet below. Users must rely on custodians to safely hold and manage the underlying assets. As a result, frxUSD’s dependency risk is primarily driven by the operational soundness, concentration, and transparency of its custodians, with the balance sheet disclosures and Chaos Labs’ proof-of-reserve feeds serving as key mitigants that provide transparency but do not eliminate this reliance.


Source: frxUSD Balance Sheet, Frax, December 12, 2025

Centralized Reserve Management
Following the successful passage of FIP-432, the Frax DAO delegated issuer-level compliance and collateral management for frxUSD to Frax Inc., making it responsible for custodian oversight, reserve composition, audits, and attestations. As a result, the reserve and custodian selection process has become more opaque. Since our previous analysis, there has been a material change in the backing composition, with Bridge’s USDB onboarded and USCC, AUSD, and JTRSY offboarded, without a prior disclosure. This limited transparency around reserve changes may reduce stakeholders’ visibility into potential shifts in backing composition, which can modestly increase collateral risk due to the absence of clear guidance on forthcoming adjustments.

That said, given Frax’s stated intention to align frxUSD with GENIUS Act compliance, we expect future reserve additions to focus on highly liquid, tokenized U.S. Treasury-based assets supported by regulated custodians, which should help constrain the risk profile of frxUSD backing over time.

Solana Exposure
Approximately $2M of Bridge’s USDB reserves backing frxUSD are held on Solana. According to the frxUSD balance sheet, the protocol currently maintains a surplus of approximately $2.84M, representing the difference between total assets (reserves) and liabilities (frxUSD supply). In the event of an exploit on Solana, the loss of the USDB backing would not render frxUSD insolvent. However, it would reduce the collateralization ratio to approximately 100.76%. Looking ahead, if RWA backing becomes increasingly distributed across multiple chains, the overall risk surface would correspondingly increase.

4. Counterparty Risk

4.1 Governance and Regulatory Risk

The governance and regulatory risk profile remains broadly consistent with our previous analysis, with recent changes reflecting frxUSD’s efforts to comply with the GENIUS Act, including the separation of the frxUSD balance sheet from legacy FRAX. However, these regulatory alignments also coincide with a shift toward more centralized decision-making, as issuer-level compliance, reserve management, and related operational responsibilities now reside with Frax Inc. solely after the implementation of FIP-432.

4.2 Access Control Risk

4.2.1 Contract Modification Options

Here are the controlling wallets:

  • Multisig A: 3/5 Safe multisig also serving as Frax’s Comptroller with ownership, minter management, freeze/unfreeze, and protocol pause/unpause functionalities.

The frxUSD architecture is powered by the following contracts, and all of them are controlled by Multisig A:

  • frxUSD: Upgradeable ERC20 contract for the frxUSD token.
  • frxUSD-USDB Custodian Proxy: Upgradeable ERC4626 vault enabling minting/burning of frxUSD via depositing/redemption of USDB collateral.
  • frxUSD-WTGXX Custodian Proxy: Upgradeable ERC4626 vault enabling minting/burning of frxUSD via depositing/redemption of WTGXX collateral.
  • frxUSD-BUIDL Custodian Proxy: Upgradeable ERC4626 vault enabling minting/burning of frxUSD via depositing/redemption of BUIDL collateral.
  • frxUSD-USDC Custodian Proxy: Upgradeable ERC4626 vault enabling minting/burning of frxUSD via depositing/redemption of USDC collateral.
  • frxUSD-USTB Custodian Proxy: Upgradeable ERC4626 vault enabling minting/burning of frxUSD via depositing/redemption of USTB collateral.

4.2.2 Timelock Duration and Function

No timelock mechanism is implemented for the above contracts, meaning administrative actions can be executed immediately without any enforced delay.

4.2.3 Multisig Threshold / Signer identity

The Multisig A, controlled by Frax Inc., is the owner of all frxUSD-related contracts and also functions as the Frax Finance Comptroller. It is a 3-of-5 Safe multisig with the following signers:

  • 0x6933BCC3e96f1C4d2cb73Cb391d854b18Ab7A4F2
  • 0xcbc616D595D38483e6AdC45C7E426f44bF230928
  • 0x17e06ce6914E3969f7BD37D8b2a563890cA1c96e
  • 0xc8dE9f45601DA8C76158b8CAF3E56E8A037F2228
  • 0x6e74053a3798e0fC9a9775F7995316b27f21c4D2

Note: This assessment follows the LLR-Aave Framework, a comprehensive methodology for asset onboarding and parameterization in Aave V3. This framework is continuously updated and available here.

Aave V3 Specific Parameters

Parameters will be presented jointly with @ChaosLabs

Price feed Recommendation

We recommend using the Chainlink frxUSD/USD feed with CAPO.

Disclaimer

This review was independently prepared by LlamaRisk, a DeFi risk service provider funded in part by the Aave DAO. LlamaRisk is not directly affiliated with the protocol(s) reviewed in this assessment and did not receive any compensation from the protocol(s) or their affiliated entities for this work.

The information provided should not be construed as legal, financial, tax, or professional advice.

3 Likes

Overview

Chaos Labs supports the listing of frxUSD on the Aave v3 Core Instance as a borrowable asset with collateral capacity limited to a narrow set of E-Modes. The following post covers the details of the recommendation. We have additionally worked directly with Frax’s team to complete a mechanism-design review of frxUSD’s mint/redeem and custody architecture and deployed a Proof of Reserves feed to deliver independent, on-chain verification of cross-chain supply versus backing.

frxUSD

frxUSD is a fully collateralized, fiat-redeemable stablecoin issued by the Frax ecosystem. Each unit is backed 1:1 by cash and cash-equivalent assets held with regulated U.S. custodians. A companion token, sfrxUSD, captures the yield generated by the underlying reserve portfolio through a dynamic allocation strategy.

Minting and redemption occur through governance-approved “enshrined custodians,” each mapped to a specific reserve asset, with Ethereum and Fraxtal serving as the primary chains for issuance and redemption. On other chains, frxUSD is implemented via the LayerZero OFT standard to maintain a unified cross-chain supply.

The following sections expand on the topics of backing, operations, mint and redeem mechanics, bridging, on-chain liquidity, and a risk parameter recommendation for deployment on the Ethereum Core instance of Aave v3.

Backing

frxUSD reserves are diversified across multiple instruments and issuers, all targeting short-duration, high-quality government exposure or fully collateralized fiat. The primary backing instruments are USTB, WTGXX, BUIDL, USDB, and USDC, as shown in the chart below.

USTB

USTB is issued by Superstate, with tokenization and portfolio management handled by Federated Hermes and custody at UMB Bank. The fund holds at least 95 percent in short-term US Treasury bills and a small cash buffer, with on-chain NAV accrual and real-time yield accounting. Reputation and credit quality are strong given the underlying assets and service providers, but redemptions are permissioned, transfers are restricted to whitelisted wallets, and peg stability depends on a relatively small set of intermediaries and an instant USDC buffer that is finite in size.

WTGXX

WTGXX is a regulated money market fund issued by WisdomTree Digital Management and managed by Voya Investment Management, with BNY Mellon as custodian. The portfolio invests exclusively in US Treasuries, government securities, and fully collateralized repo, targeting a stable one-dollar NAV with same-day or next-day redemption. It benefits from a long track record and strong institutional counterparts, but access is restricted to investors onboarded through WisdomTree’s infrastructure, and wallet eligibility is controlled via a non-transferable token, which concentrates operational and access risk in a narrow institutional channel.

BUIDL

BUIDL is a tokenized fund issued by BlackRock and distributed via Securitize, with custody at Bank of New York Mellon. It holds cash and cash-equivalent US government instruments such as Treasury bills, notes, and REPOs, and supports conversion into USDC through integrated channels. BlackRock’s scale, BNY Mellon’s role, and PwC auditing make credit and operational reputation very strong, yet mints and redemptions are limited to whitelisted accredited investors and rely on traditional transfer-agent and banking rails, so arbitrage and redemption are concentrated in a small set of qualified participants.

USDB

USDB is a fiat-backed stablecoin originally issued by Bridge (now part of Stripe), backed by 5 to 10 percent cash in segregated bank accounts and 90 to 95 percent short-duration US Treasuries managed by BlackRock. Redemptions are orchestrated via Bridge’s internal systems and generally settle same-day or within T+1 to T+2 in line with regulatory guidance. The association with Stripe and the use of high-quality collateral are positives for reputation, but the system relies heavily on proprietary orchestration and monthly attestations that are not yet fully transparent, which introduces additional operational and disclosure risk.

USDC

USDC is a fiat-backed stablecoin issued by Circle and backed by a mix of cash and short-term US government securities held with regulated banking and custodial partners. It is widely used across centralized exchanges, DeFi, and payments, with regular reserve attestations and a long public track record during multiple market stress events. While USDC is still exposed to banking-system and regulatory risk in the United States, its scale, transparency practices, and central role in on-chain markets make it one of the most reputable and liquid components of the frxUSD reserves.

Mint & Redeem

Due to the economic design of the frxUSD, the mint and redemption operations present some operational complexity, as frxUSD is backed by a broad set of RWA assets; the mint and redemption mechanics rely on the underlying pricing strategies associated with the backing assets. As the stablecoin is redeemable for other stablecoins and RWA assets, the question of pricing the underlying for the mint/redeem conversion naturally arises, as some price fluctuations in the open market may occur, even between frxUSD and USDC, for example.

In practice, the protocol utilizes hardcoded price values for the redemption of assets such as USDC and BUIDL, which are typically facilitated by contracts like FraxUSDCustodianUSDC. In the case of USDC, specifically, the contract has a hardcoded price, which can be obtained externally via pricePerShare() call, during the mint/redeem operations, and computed the price of shares based on the price of assets, taking into account only the decimal conversions. The code snippet from the mentioned FraxUSDCustodianUSDC is attached below:

/// @dev Internal conversion function [from shares(frxUSD) to assets(USDC)] with support for rounding direction
/// @param _shares Amount of shares(frxUSD) to convert to underlying tokens
/// @param _rounding Math.Rounding rounding direction
/// @return _assets Amount of underlying tokens(USDC) represented by the given number of shares
function _convertToAssets(uint256 _shares, Math.Rounding _rounding) 
				 internal view virtual returns (uint256 _assets) {
	_assets = Math.mulDiv(_shares, uint256(10 ** custodianTknDecimals), uint256(10 ** frxUSDDecimals), _rounding);
}

Given that USDC is effectively hardcoded, the mint and redemption functionality presents exposure to both market and systemic risks. If USDC were to temporarily depeg, a sophisticated user could mint frxUSD for USDC, effectively arbitraging the depeg of USDC against frxUSD. These risks can be limited by either calling setMintCap() to reduce new mints of frxUSD from any specific custodian, or by introducing a substantial fee to limit the profitability of the arbitrage until market conditions are restored.

/// @notice Set the mint cap for frxUSD minting
/// @param _mintCap The new mint cap
function setMintCap(uint256 _mintCap) public onlyOwner {
  mintCap = _mintCap;
  emit MintCapSet(_mintCap);
}

Design-wise, such logic has likely been established to effectively peg a much smaller frxUSD (market cap of $125 million) to the second-largest stablecoin — USDC, as users can redeem frxUSD for USDC, thereby pushing its price up in case of temporary market fluctuations.

When the custodian asset is not designed to trade at a fixed $1.00 peg, as is the case for USTB, which currently trades around $10.92 per token, the simple decimal-based conversion used in FrxUSDCustodian is no longer fit. Instead, the mint and redemption flows must incorporate the USD notional value of the backing asset to maintain the peg of frxUSD.

Such functionality is facilitated with FrxUSDCustodianWithOracle, which is an extended version of FrxUSDCustodian. In this configuration, frxUSD remains a dollar-tracking stablecoin, but the underlying custodian token has a floating NAV. To reconcile this, FrxUSDCustodianWithOracle integrates an external price oracle into the ERC-4626 conversion logic, such that deposit and redemption operations provide accurate pricing of both assets. Specifically, the redemption rate of frxUSD for USTB is provided by the following function:

/// @dev Internal conversion function (from shares to assets) with support for rounding direction
/// @param _shares Amount of shares to convert to underlying tokens
/// @param _rounding Math.Rounding rounding direction
/// @return _assets Amount of underlying tokens represented by the given number of shares
function _convertToAssets(uint256 _shares, Math.Rounding _rounding)
    internal
    view
    override
    returns (uint256 _assets)
{
    _assets = Math.mulDiv(
        super._convertToAssets(_shares, _rounding),
        (10 ** oracleDecimals),
        getCustodianOraclePrice(),
        _rounding
    );
}

As can be noted, the internal _convertToAssets() fetches the last reported price from the SuperstateOracle. The oracle is being updated directly by an address associated with the deployment of USTB, as can be observed in this transaction.

Redemption liquidity is further complicated by the diversified nature of frxUSD’s backing. While the aggregate reserves are sized to accommodate the full outstanding supply across all custodians, there is no guarantee that any specific reserve asset will remain available for redemption at all times. In particular, only a limited share of total backing is held as USDC. Once the USDC custodian’s reserves are exhausted, additional redemptions must route through other custodians holding instruments such as USTB, BUIDL, or WTGXX, some of which are permissioned and require KYC or whitelisting at the underlying issuer level. If a user attempts to route a redemption through a frxUSDCustodian contract with insufficient reserves, the transaction will revert.

 /// @notice Redeem a specified amount of shares for the underlying tokens. Make sure to approve _owner's shares to this contract first.
  /// @param _sharesIn Number of shares to redeem
  /// @param _receiver Recipient of the underlying asset tokens
  /// @param _owner Owner of the shares being redeemed. Must be msg.sender.
  /// @return _assetsOut Amount of underlying tokens out
  /// @dev See {IERC4626-redeem}. Leaving _owner param for ABI compatibility
  function redeem(uint256 _sharesIn, address _receiver, address _owner) public virtual returns (uint256 _assetsOut) {
    // Make sure _owner is msg.sender
    if (_owner != msg.sender) revert TokenOwnerShouldBeSender();

    // See how many shares the owner can redeem
    uint256 _maxShares = maxRedeem(_owner);

    // Revert if you are trying to redeem too many shares
    if (_sharesIn > _maxShares) {
      revert ERC4626ExceededMaxRedeem(_owner, _sharesIn, _maxShares);
    }

    // See how many asset tokens are expected
    _assetsOut = previewRedeem(_sharesIn);

    // Do the redemption
    _withdraw(msg.sender, _receiver, _owner, _assetsOut, _sharesIn);
  }

In practice, this means that atomic redemption liquidity is highly variable, path-dependent, and may be uneven across reserve assets: early redeemers may access USDC directly, while later redeemers may receive tokenized Treasuries or other RWA instruments instead, subject to off-chain eligibility constraints. This dynamic can be further exemplified by the high volatility of USDC reserves in the frxUSDCustodianUSDC, which exhibits sharp fluctuations in liquidity inflows and outflows as entities mint and redeem the asset.

Redemption Capacity and Fees

Given the diversity of reserves, the backing configuration of the asset implies substantial variation in permission-based constraints, atomicity of redemptions, and reserve liquidity. As mentioned previously, the redemptions are processed via the frxUSDCustodian contracts, which have a configurable redemption fee, said fee can be accessed by calling the redeemFee() read function on the respective contract.

asset contractAddress frxUSDCustodian redeemFee()
USDC 0xa0b86991c6218b36c1d19d4a2e9eb0ce3606eb48 0x4F95C5bA0C7c69FB2f9340E190cCeE890B3bd87c 0.00%
USTB 0x43415eb6ff9db7e26a15b704e7a3edce97d31c4e 0x5fbAa3A3B489199338fbD85F7E3D444dc0504F33 0.01%
BUIDL 0x7712c34205737192402172409a8f7ccef8aa2aec 0xe827abf9f462ac4f147753d86bc5f91e186e4e9c 0.01%
WTGXX 0x1fecf3d9d4fee7f2c02917a66028a48c6706c179 0x860Cc723935FC9A15fF8b1A94237a711DFeF7857 0.01%
USDB 0xeac4269c9a01190b1400c4dc728864e61895fdf3 0xFE2Ea8dE262d956e852F12DE108fda57171a0a29 0.01%

As can be observed, the fees listed present minimal barriers for conversion of frxUSD to the underlying reserves; nevertheless, additional operational constraints exist. Specifically, some of the reserves cannot be redeemed for USDC permissionlessly. One such example is BUIDL, which, as can be observed from the ERC20 transactions, has not been redeemed for USDC for over 200 days. Instead, as signaled by the emitted burn events and lack of corresponding USDC inflows, the asset has been redeemed off-chain. While frxUSD → BUIDL → USD redemptions may incur additional BUIDL → USD redemption fees, according to rwa.xyz, such fees are currently waived.

Additionally, the Frax team has introduced a streamlined option to redeem frxUSD to USDC atomically via USTB. This is facilitated by the RWARedemptionCoordinator, which burns the frxUSD upon receipt and redeems it for USTB. A whitelisted entity receives USDC and returns the funds to the initial frxUSD redeemer, net of 1 basis point in fees.

In addition to these pathways, WTGXX-backed redemptions further illustrate the distinction between on-chain redemption mechanics and effective stablecoin liquidity. While the frxUSDCustodian for WTGXX applies a fixed 1 basis point redemption fee and executes the frxUSD burn atomically on-chain, the subsequent non-atomic conversion of WTGXX into USDC follows if redeemWtgxx is called by the WTGXX custodian on the USDC custodian. In practice, redeemed WTGXX is transferred to a Frax-controlled receiver address and settles off-chain through WisdomTree and its custodial partners’ EOAs, after which USDC is minted and transferred to the Frax USDC custodian by Circle. This redemption flow illustrates operational complexities associated with the frxUSD → WTGXX → USDC redemption path, which is only partially on-chain, with the USDC settlement time shifter by a few hours.

DEX Liquidity

The primary liquidity venue for frxUSD is the Curve V2 frxUSD/crvUSD pool, which currently has a TVL of approximately $37 million. The pool’s design and substantial depth limit observed dislocations from the oracle price. Over the past 60 days, dislocations have been minimal, with the largest reaching 20 basis points. The mean dislocation over this period was less than five basis points, signaling a substantial level of asset stability.

Pricing

We recommend pricing the asset using a market-based frxUSD/USD oracle feed. This approach is appropriate as the market price is generally expected to closely track the peg, while the use of a CAPO limiting the price of frxUSD to 1.04 USD significantly constrains the risk of overpricing, which is critical for limiting the accumulation of bad debt. Additionally, we expect the market price to be more reliable than a typical secondary-market feed due to the diversity of the collateral backing frxUSD and the presence of on-chain atomic redemptions into USDC or other reserve assets, which should enable rapid arbitrage and keep secondary market prices tightly aligned with the peg.

However, reliance on a market price oracle introduces residual risk if the feed becomes insufficiently liquid or temporarily manipulable, potentially causing liquidations and enabling borrowing against an underpriced oracle value. To mitigate such risks, this design could be complemented with a freezing or circuit-breaker risk oracle that leverages Proof of Reserves signals, preventing risky operations during periods where market prices materially diverge from the underlying backing value.

Asset Parameters

Collateral Parameters

Given the relatively low maturity of the asset, along with a high probability of substantial asset concentration within the Core instance of Aave v3, given the market cap of approximately $125 million, we recommend limiting the collateralization utility of the asset within a set of established stablecoins facilitated by a dedicated E-Mode. We recommend constraining the mentioned set of frxUSD-borrowable assets to highly correlated stablecoins, while preserving conservative collateral parameters such that frxUSD can borrow stablecoins at the same capital efficiency as USDC. The recommendation to provide frxUSD with the same collateralization power as USDC is motivated by its redeemability and strictly enforced liquidity-dependent peg configuration. As mentioned previously in the analysis, as long as frxUSDCustodianUSDC has ample liquidity across its reserves, the assets are convertible one-to-one, ensuring efficient secondary market pricing of frxUSD.

Additionally, we recommend enabling the asset as borrowable, as we expect the primary demand to originate from this use case. Given the recent depreciation of the collateral utility of volatile, low-demand assets following the October 10 market crash and the recent introduction of Aave v3.6, we conclude that the risk associated with uncorrelated borrowing is minimal, as the majority of demand is expected to come from matured ‘blue-chip’ assets.

Supply & Borrow Caps

For the time being, we recommend a supply cap of 60 million frxUSD and a borrow cap of 55 million frxUSD. While conservative relative to the liquidity, these values reflect the risk of high concentration of the asset within Aave, as the current supply stands at approximately 125 million, while also taking into account the secondary market liquidity and direct redemption capacity via permissionless venues.

Interest Rate

We recommend aligning the interest rate configuration of frxUSD with the broader stablecoin market while proposing a slightly more conservative optimal utilization. Specifically, we propose a base rate of 0%, a slope 1 of 5.5%, a slope 2 of 50%, and an 80% UOptimal.

Specification

Parameter Value
Asset frxUSD
Isolation Mode No
Borrowable Yes
Collateral Enabled No
Supply Cap 60,000,000
Borrow Cap 55,000,000
Debt Ceiling -
LTV -
LT -
Liquidation Bonus -
Liquidation Protocol Fee 10%
Variable Base 0%
Variable Slope1 5.5%
Variable Slope2 50%
Uoptimal 80%
Reserve Factor 10%

frxUSD E-Mode

Asset frxUSD USDC USDT USDe GHO
Collateral Yes No No No No
Borrowable No Yes Yes Yes Yes
Max LTV 75% - - - -
Liquidation Threshold 78% - - - -
Liquidation Bonus 4.5% - - - -
4 Likes

Dear @ACI , From our side, the proposal is complete and addresses the outstanding points raised during discussion. We believe it is ready to be advanced to the voting stage.

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Looking forward to this integration!

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