[ARFC] Onboard USDai & sUSDai to Aave V3 Arbitrum Instance

[ARFC] Onboard USDai & sUSDai to Aave V3 Arbitrum Instance

Author: ACI

Date: 2025-10-15

Summary

We propose the onboarding of USDai and sUSDai on Aave V3 Arbitrum Instance.

This listing would initially enable users to deposit USDai and sUSDai to earn yield and borrow.

Motivation

USDai and sUSDai are innovative stable assets backed by AI hardware infrastructure and idle reserve assets, designed to merge real-world infrastructure finance with DeFi.

As emerging stablecoins with strong venture backing and early adoption momentum, USDai and sUSDai represent a differentiated design that expands Aave’s exposure to innovative collateral types while offering users stable units of account and new yield-bearing options.

Key differentiators:

  1. Hardware-backed design: Both tokens leverage GPU/AI compute hardware as collateral, creating a new RWA category.
  2. Dual-token structure:
    • USDai serves as the stablecoin for payments and borrowing.
    • sUSDai accrues yield from lending to AI firms and low-risk asset allocations.
  3. Growing ecosystem:

Arbitrum is Already the main Hub for usd.ai echosystem and Aave is set to take a lion’s share of their liquidity and associated borrowing volume

Specification

Risk Service Providers will provide Risk Parameters and proposal will be updated accordingly.

Incentives:

The USDai team is considering incentive programs to boost adoption and enhance the competitiveness of USDai and sUSDai borrowing rates compared to other stablecoin assets on Aave instances.

Detailed incentive structures will be shared with Aave DAO contributors and the community in the ARFC stage.

Disclosure

ACI are not affiliated with USDai and have not received compensation for the creation and review of this proposal.

Next Steps

  1. Publication of a standard ARFC, collect community & service providers 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 via CC0

1 Like

USDai’s idea of loaning money to companies that provide GPUs as collateral - or rather, some sort of proof of ownership of GPUs as collateral - may work well in times of market exuberance (now) but perform less well if / when the AI bubble pops (soon?).

Current hype around USDai is based around people farming points for a future token - presumably a ā€˜governance’ token. It’s not clear why a stablecoin needs a governance token - USDT and USDC have managed without one - and once the farming is complete I’d expect to see a mass exodus from holding a stablecoin ā€˜backed’ by a claim on rapidly-depreciating-in-value hardware located in a shed somewhere.

(Of the ~$500M currently farming points, $500M has been assigned to an AI cloud - or qloud - outfit named Qumulus; if Qumulus used this money to buy more GPUs, would they be able to use the new GPUs as further collateral with which to borrow more dollars? And then repeat?)

I hope the Risk Service Providers are brutally rigorous in their assessments.

3 Likes

Overview

Chaos Labs conducted an extensive review of the USDai and sUSDai, analyzing their architecture, collateral composition, legal enforceability and liquidity mechanisms. The assessment covered the full operational lifecycle (from minting and staking to redemption, loan origination and default enforcement) as well as dependencies on the M0 infrastructure, cross-chain liquidity management, and the GPU-backed credit layer.

Following this comprehensive evaluation, Chaos Labs does not recommend supporting the listing of USDai or sUSDai at this time on either Arbitrum or Plasma, due to the outlined risks related to peg volatility, redemption liquidity, cross-jurisdictional collateral enforcement, and uncertainty surrounding secondary market demand and pricing resilience of GPUs. However, since USDai is fully backed by short-duration U.S. Treasuries through the M0 infrastructure, it may be reconsidered for listing once the current minting caps are lifted, the supply demand imbalance is resolved and the token demonstrates sustained peg stability.

Permian Labs

Permian Labs is the development team behind the USDai protocol. The company has positioned itself at the intersection of real world asset tokenization, AI, stablecoins and DeFi, with a focus on building legally enforceable credit infrastructure for AI infrastructure, particularly GPU financing.

In August 2025, Permian Labs announced a $13.4 million funding round led by Framework Ventures, with participation from Dragonfly, Arbitrum Foundation, Flowdesk, and other investors. The capital was directed toward building USDai and its supporting components, including CALIBER, FiLo, and QEV.

Permian Labs’ work on USDai builds on its earlier track record of designing financial infrastructure for digital collectables.

Metastreet

Before USDai, Permian Labs created Metastreet, an NFT financialization platform launched in 2021. Metastreet was designed as a lending marketplace for non-fungible tokens, allowing NFT holders to unlock liquidity against their assets.

The technical expertise developed through Metastreet informed the design of USDai. Several of the smart contract components originally built for Metastreet have been adapted and repurposed for the USDai protocol.

USDai Protocol

The USDai Protocol is a structured credit and stablecoin system designed to bridge DeFi with real-world asset financing, specifically the capitalization of AI infrastructure through GPU-backed loans. It integrates three primary frameworks (CALIBER, FiLo, and QEV) which together form a lifecycle of tokenization, collateralization, underwriting and liquidity management.

At a high level, USDai operates as a two-layered system:

  1. USDai: a base stablecoin layer, powered by the M0 Protocol, which provides fully collateralized, T-bill–backed liquidity.
  2. sUSDai: a GPU-backed, overcollateralized lend/borrow layer, where capital is deployed into tokenized GPU loans originated and structured through CALIBER and FiLo.

Integration with the M0 Protocol

USDai is issued as an Extension Token on top of M0, a stablecoin issuance infrastructure platform purpose-built for creating application specific stablecoins. M0 separates stablecoin design into two layers:

  • Value Layer – $M Token: The foundational collateral layer of the M0 Protocol, where each $M token is fully backed 1:1 by eligible collateral such as short-duration U.S. Treasuries or tokenized equivalents like USTB.
  • Application Layer – Extension Tokens: Custom ERC-20 stablecoins, such as USDai and mUSD, that wrap $M to inherit its collateralization, yield and compliance guarantees while adding protocol-specific logic and functionality.

The M0 system operates under a federated model with Minters, Validators, and SPV Operators, ensuring collateral custody and regulatory compliance. Minting and redemption of $M occur exclusively on Ethereum while Extension Tokens like USDai can operate across multiple chains.

A more detailed analysis of the M0 Protocol’s architecture and custody structure is available in Chaos Labs’ prior report, which can be accessed here.

USDai and sUSDai

Within the protocol, there are two key assets: USDai and sUSDai.

  • USDai represents the base stablecoin, backed by tokenized short-duration U.S. Treasuries held through the M0 infrastructure.
  • sUSDai represents the yield-bearing version of USDai. It is designed to generate yield from loans collateralized by GPUs through the CALIBER framework. These GPU-backed loans are originated and underwritten by FiLo Curators, who take first-loss exposure to align incentives.

At present, approximately 99% of sUSDai’s collateral remains allocated to T-bills, as the utilization of sUSDai capital in GPU-backed loans is below 1%. In practice, this means that less than 1% of the capital staked in sUSDai is currently being deployed toward GPU financing, while the vast majority remains in low-risk, yield-bearing Treasury instruments via the M0 infrastructure.

The long-term vision of the protocol is to progressively increase the share of sUSDai capital deployed into GPU-collateralized loans as origination capacity and participation expand. Over time, a greater portion of sUSDai’s backing is expected to consist of tokenized GPU loans rather than T-bills.

This evolution will transform sUSDai from a predominantly Treasury-backed yield instrument into an actively deployed capital vehicle that finances AI infrastructure through secured hardware lending. USDai, by contrast, will remain fully backed by T-bills at all times, serving as the stable, liquid base layer of the system.

Allo Points Program

To encourage participation and reward early adopters, the protocol has introduced the Allo Points Program, which serves as the incentive layer for both USDai and sUSDai holders. Points earned through the program determine user eligibility for upcoming token distributions, including allocations for the ICO and airdrop at the TGE.

  • USDai holders earn points toward ICO allocations, which will account for 70% of the total token supply.
  • sUSDai holders earn both the protocol APY (derived mainly from T-bill yields and partially from GPU-backed loans) as well as points toward the airdrop allocation, which represents 30% of the token supply to be distributed at TGE.

The program offers extra points for holding USDai, which has created an incentive that keeps the staking ratio for sUSDai relatively low. This reduced staking participation amplifies the effective yield for existing sUSDai holders, as T-bill rewards are distributed across a smaller capital base.

AutoUSDai and AutosUSDai

The protocol features two additional vault-based wrappers (autoUSDai and autosUSDai) designed to capital deployment and yield compounding while preserving users’ participation alignment in the Allo Points incentive program.

autoUSDai represents deposits of USDai allocated into the Auto strategy, a curated liquidity and market-making vault operated by Concrete, the protocol’s vault manager. Funds deposited into autoUSDai are automatically routed across a diversified set of strategies, including Uniswap, Balancer, Euler (on Plasma), Fluid, and Curve (on Arbitrum), with the majority of liquidity currently concentrated on the Plasma chain. Out of the total 85.6 million USDai deposited in autoUSDai, approximately 68 million resides on Plasma, with around 52 million held in idle USDai awaiting deployment. Participants in autoUSDai earn a 15Ɨ Allo Points multiplier.

autosUSDai functions analogously for sUSDai deposits. It enables auto-compounding of yield and reward accrual while maintaining users’ alignment with the Airdrop allocation under the Allo Points program. The autosUSDai vault, also managed by Concrete, operates primarily on Arbitrum and currently manages approximately 8 million sUSDai.

Together, the autoUSDai and autosUSDai vaults account for roughly 16% of the total USDai supply, representing the share of system liquidity under Concrete’s management for LP strategies.

CALIBER

CALIBER (Collateralized Asset Ledger: Insurance, Bailment, Evaluation, and Redemption) is a framework to enable the direct tokenization of physical assets, beginning with GPUs. It aims to create enforceable, on-chain ownership for real world assets that is legally recognized, bankruptcy-remote and operationally efficient.

Core Design

1. One-to-One Asset Representation

At the foundation of CALIBER is the principle of direct one-to-one representation of assets. Each GPU, is tokenized as a unique ERC-721 NFT, establishing a one-to-one correspondence between the physical hardware and its digital counterpart. The ERC-721 model ensures that each token embodies a distinct property right tied to an identifiable piece of hardware.

2. Bankruptcy Remote SPVs
To further strengthen collateral protection, CALIBER requires that borrowers contribute GPUs to a bankruptcy remote Special Purpose Vehicle (SPV). The SPV is legally structured and independently managed to ensure that the GPUs remain outside the reach of other creditors if the borrower enters insolvency proceedings. This separation guarantees that collateral pledged into the USDai protocol cannot be clawed back during bankruptcy.

3. Bailment and Custody Structure
Once contributed to the SPV, the GPUs are placed under the custody of datacenters through a Bailment Agreement. In this arrangement, the datacenter functions as Bailee, responsible for safeguarding the physical hardware, while the NFT holder acts as Bailor, retaining ownership rights. Permian Labs, acting as Tokenizing Agent, mints the NFTs that represent these GPUs on-chain. This creates a digital property right anchored in an enforceable custody structure, bridging traditional bailment law with blockchain-based asset management.

UCC Article 7: Legal Foundation

UCC Article 7 is a section of the Uniform Commercial Code, the body of standardized commercial laws that has been adopted across all U.S. states to govern trade and secured transactions. Article 7 specifically addresses documents of title, such as warehouse receipts and bills of lading, which serve as legal instruments proving ownership and the right to control goods in storage or transit. Although the UCC is a model code, its adoption by every state makes Article 7 legally enforceable nationwide within the United States.

UCC Article 7 provides the legal foundation for CALIBER by recognizing the enforceability of documents of title, including their electronic forms. Within this framework, each NFT minted for a GPU operates as an electronic document of title, certifying ownership and establishing enforceable rights over the underlying asset.

By structuring NFTs in this way, CALIBER ensures that holders possess a legally recognized property claim. In the event of default, the NFT holder has the right to repossess or liquidate the collateralized GPU, with enforcement carried out through on-chain auctions rather than protracted court proceedings. This alignment transforms the NFT from a digital representation into a legally binding property right, bridging traditional commercial law with blockchain-based collateralization.

FiLo: First Loss Curators

FiLo, short for First Loss Curators, is the risk-curation layer of the USDai protocol. While CALIBER provides the legal and technical framework for tokenizing GPUs and enforcing ownership, FiLo addresses the challenge of how loans are originated and underwritten. It require curators to take a first-loss position in every loan they originate or onboard. This creates an alignment of incentives: those who originate credit must also bear the highest tranche of risk.

FiLo Curators accept concentrated exposure in exchange for higher yields. Their position ensures that underwriting risk is absorbed first by the curator, protecting depositors and stakers from direct counterparty risk.

In practice, each loan is structured into two tranches: a senior sUSDai tranche covering up to 65% of collateral value, and a junior FiLo tranche extending the total LTV to 70%. This means curators supply roughly 7.1% of total loan principal, representing the top 5% of collateral value, the slice of exposure that takes the first hit if collateral prices fall or a borrower defaults.

By shouldering this 5% collateral risk, FiLo curators provide a built-in credit enhancement for the system, creating a protective buffer for sUSDai depositors while earning elevated returns (typically 20–30% APR) for bearing this subordinate risk.

Unlike traditional structured credit, where senior tranches are repaid first to maximize protection and increase credit enhancement over time, USDai employs pro-rata amortization. Both senior and junior tranches receive repayments proportionally as borrowers make payments, keeping the LTV ratio and first-loss buffer constant throughout the loan’s life. While this design preserves credit alignment and simplifies on-chain operations, it also forgoes the progressive de-risking seniors enjoy in traditional finance.

Risk Alignment and Safeguards

Each loan issued through FiLo includes multiple layers of protection. Borrowers contribute an equity cushion, curators contribute the first-loss tranche and the protocol enforces aggressive amortization schedules that front-load repayments. USDai applies a 3 year depreciation curve. As a result, an initial LTV ratio of 70% can fall to approximately 40% after just one year.

The capital stack resembles the rigid structure of commercial mortgage-backed securities (CMBS): equity from the borrower, a first-loss tranche from the curator and senior debt provided by sUSDai holders. Missed payments result in immediate forfeiture and recovery, without discretionary interventions.

Collateral valuation is supported by third-party appraisals from providers such as Evertas and Blockware, which supply secondary market pricing benchmarks. The semi-fungibility of high-end GPUs like the B200 and GB200 series allows for standardized valuation models across asset classes. Unlike tokenized DeFi collateral, live pricing oracles are not used. Instead, conservative amortization schedules, underwriter commitments and independent appraisals serve as the primary safeguards against collateral mispricing.

By requiring curators to take on first-loss risk, the protocol aligns incentives between originators and depositors. By embedding aggressive amortization, independent valuations and automated enforcement once a borrower misses a payment, it ensures that sUSDai remains a senior tranche.

QEV

Queue Extractable Value, or QEV, is a liquidity primitive introduced by USD.AI to solve one of the problems in finance: how to manage withdrawals against long-dated, illiquid collateral.

Most stablecoins promise instant liquidity, relying on collateral such as USDC or ETH that can be liquidated immediately. In contrast, USD.AI is backed by fixed-rate, amortizing GPU loans. These loans are safe in terms of repayment, but their cash flows are scheduled over time rather than instantly available.

In banking and DeFi alike, collapses often stem not from insolvency but from illiquidity. When more depositors ask for their money back than the system can immediately provide, confidence evaporates and tokens trade below par. For USD.AI, the challenge is monthly GPU loan repayments provide a steady stream of cash, but redemptions may spike unpredictably. The system needs a way to manage the sequencing of withdrawals without breaking fairness or stability.

How QEV Works

Each month, as borrowers repay principal and interest, the protocol knows in advance how much liquidity will be available for redemptions. This amount, denoted Ī”, is released to service withdrawal requests of sUSDai. If redemption requests are smaller than Ī”, all exits are honored in order and the queue clears. If requests exceed Ī”, the queue transitions into an auction.

In these cases, sUSDai holders who wish to redeem bid privately for priority access. The sealed-bid system, powered by zero-knowledge proofs, prevents last-minute sniping. The higher the bid relative to others, the greater the share of Ī” allocated to that redeemer. Importantly, the funds spent on bids are recycled back into the protocol, rewarding patient holders who wait their turn.

QEV is still in the design phase and has not yet been implemented on-chain. The current system instead uses a 30-day FIFO redemption queue, where withdrawal requests are processed sequentially at the redemption share price once the timelock expires. This indicates that QEV remains a planned future upgrade intended to replace the existing queue-based model with an auction-driven liquidity mechanism.

GPU Backed Overcollateralized Loans

The USDai protocol’s credit architecture is designed to finance real-world GPU infrastructure through a on-chain, legally enforceable and overcollateralized lending system. It connects three key layers: CALIBER for asset tokenization and legal structuring, FiLo for underwriting and risk alignment, and the USDai/sUSDai liquidity layer for capital provision.

In this section we bring these components together and explain, step by step, how the protocol operates end to end: from loan origination and collateral preparation, to on chain borrowing and monthly amortization, and through to default handling, repossession, and bankruptcy scenarios. Together, these elements form a closed loop that transforms physical GPUs into tokenized collateral capable of supporting decentralized credit issuance.

Loan Origination Process

  1. Purchase Order and Bridge Financing

The process begins when a borrower (e.g AI infrastructure company, datacenter operator, cloud provider) places a purchase order for GPUs from a manufacturer.

This purchase is initially financed through external short-term bridge capital, provided by traditional lenders or private financiers, not by the USDai protocol.

The purpose of this interim financing is to enable the borrower to secure and deploy the hardware without committing long-term capital at the procurement stage. Once the GPUs are delivered, installed and verified, the borrower transitions to permanent, on-chain financing through USDai.

  1. Shipment and Installation

Once manufactured, the GPUs are shipped and installed at an accredited data center, typically within six to eight weeks.

At this stage, the hardware becomes operational and begins generating verifiable economic output.

  1. SPV Formation

To qualify for borrowing through the USDai protocol, the borrower must establish a bankruptcy-remote SPV and contribute the GPUs to it.

The SPV serves as a legally segregated entity, distinct from the borrower’s corporate balance sheet, ensuring that the GPU assets remain outside the reach of other creditors in the event of borrower insolvency.

By transferring ownership to the SPV, the borrower effectively isolates the collateral, creating a clean and enforceable structure for the protocol to lend against.

  1. NFT Minting and Digital Title Creation

Permian Labs, acting as the Tokenizing Agent, mints ERC-721 NFTs that represent each GPU or batch of GPUs.

Each NFT functions as an electronic document of title under UCC Article 7, embedding enforceable property rights directly into the token.

These NFTs serve as the on-chain collateral representation and are the bridge between real-world legal title and digital financialization.

  1. Bailment Agreement with Data Center

The SPV enters into a Bailment Agreement with the data center that physically hosts the GPUs.

Under this agreement:

  • The data center acts as the Bailee, responsible for the safekeeping, operation, and maintenance of the equipment.
  • The NFT holder acts as the Bailor, retaining full legal ownership and control over the hardware through the electronic document of title.

This arrangement ensures that even though the GPUs are physically managed by the data center, legal ownership remains tied to the NFT itself, enabling enforceable claims, repossession, or transfer of ownership entirely on-chain.

  1. Underwriting by FiLo Curators

A FiLo Curator evaluates the borrower and the collateral.

Curators apply their domain expertise to assess borrower creditworthiness, operational capacity, and hardware valuation. They also determine whether the loan meets the protocol’s risk standards, ensuring that underwriting aligns with the protocol’s 70% LTV policy.

  1. Collateral Valuation by Third-Party Appraisers

Independent valuation firms such as Evertas and Blockware provide third-party appraisals of the GPU hardware.

Their assessments establish the fair market value used to calculate loan size and LTV ratios. The semi-fungibility of modern GPUs (e.g., NVIDIA B200, GB200) enables standardized pricing models and benchmarking across deals.

  1. On-Chain Loan Generation

Once the loan terms and collateral have been approved, the borrower initiates an on-chain borrow transaction through the protocol’s pool contract.

In this transaction, two actions occur:

  1. The NFT representing the GPU’s electronic document of title is transferred from the borrower to the pool contract, which becomes the legal and technical custodian of the collateral for the duration of the loan.
  2. The borrower simultaneously receives USDC drawn from the pool, representing the disbursement of the overcollateralized loan.

This process formalizes the transfer of digital title under UCC Article 7, with the pool holding the NFT in escrow until full repayment or liquidation.

The loan is financed through a two-tranche capital structure:

  • Senior Tranche (sUSDai Holders):
    • Represents approximately 92.9% of total loan principal, covering up to 65% of collateral value (LTV).
    • Capital originates from sUSDai holders, protocol supply liquidity by redeeming an equivalent amount of USDai from the staking contract.
    • The redeemed USDai is unwrapped into $M tokens via the M0 protocol and converted into USDC, which funds the senior tranche of the pool.
  • Junior Tranche (FiLo Curators):
    • Represents approximately 7.1% of total loan principal, corresponding to the top 5% of collateral value.
    • FiLo Curators deposit USDC directly into the pool as first-loss capital, absorbing any valuation shocks or default-related losses before they impact sUSDai depositors.

The borrow function executes both the collateral transfer and the loan disbursement in a single atomic call.

Upon completion, the pool contract holds the NFT as the custodian of the GPU’s digital title, while the borrower receives USDC liquidity. The NFT remains immobilized within the protocol until the borrower fully repays or a default triggers liquidation.

Loan Repayment Process

Once originated, each loan follows a 3 year amortization schedule designed to steadily reduce outstanding principal while maintaining full overcollateralization. Borrowers make monthly repayments that include both principal and interest, paid directly to the protocol’s pool contract.

Each loan is structured as a fully amortizing term loan with a 36 month duration and a fixed annual interest rate, currently around 15%, but adjustable over time based on market conditions and protocol risk parameters. Payments occur every 30 days, combining principal and interest in a single installment.

Repayments are front-loaded, meaning a larger portion of each payment goes toward principal during the early months of the loan term. For a standard three-year loan at 15% APR:

  • Approximately 4% of principal is repaid in the first month.
  • This gradually declines to around 2.8% by the final month as the interest component decreases.

All repayments are distributed pro-rata between the senior (sUSDai) and junior (FiLo) tranches based on their respective share of the total loan principal.

  • FiLo Curators receive their portion of principal and interest directly in USDC, realizing higher returns that reflect their first-loss exposure.
  • sUSDai holders benefit from the inflow of repayments, which replenish liquidity available for future GPU loans or support sUSDai redemptions.

Default, Repossession and Bankruptcy Scenarios

The USDai protocol enforces rules-based liquidation framework designed to preserve the solvency of the lending pool. Defaults are handled through an automated and legally enforceable process that integrates on-chain liquidation mechanisms with off-chain legal protections established under UCC Article 7.

A borrower is considered in default when a scheduled 30 day principal and interest payment is not made within the designated grace period. Once a default condition is triggered, the loan automatically transitions to a default state within the protocol’s pool contract, and liquidation is initiated without discretionary governance intervention.

The liquidation process is executed through the EnglishAuctionCollateralLiquidator contract. The defaulted NFT is transferred from the pool contract to the liquidator, and a seven-day auction begins. Bids are placed and the winning bidder acquires full legal ownership of the NFT and, by extension, the underlying hardware. In most cases, a FiLo curator expected to act as a stalking horse bidder, setting a minimum price for auctioned GPUs. The data center, acting as Bailee, is legally expected to follow the instructions of the NFT’s new holder, either maintaining the GPUs under existing hosting terms or preparing them for delivery.

If a borrower’s parent entity enters bankruptcy, the bankruptcy-remote SPV structure prevents contagion by isolating collateral ownership from the borrower’s general liabilities. The GPUs, which are legally held by the SPV, are not part of the borrower’s bankruptcy estate and cannot be claimed by other creditors. The NFTs representing these GPUs remain immobilized within the USDai protocol, enabling liquidation and repayment to continue uninterrupted regardless of external insolvency proceedings. This separation make sure that all hardware pledged to the protocol remains available for enforcement and that lender rights are preserved.

USDai

USDai is an ERC-20 stablecoin fully backed by short-duration U.S. Treasuries through the M0 Protocol infrastructure.

It is currently live on Arbitrum and Plasma, with minting and redemption operations exclusively supported on Arbitrum.

The token’s supply is capped at 500 million, a limit that has already been reached, contributing to its consistent secondary market premium, further amplified by incentives from the Allo Points Program.

Under the hood, USDai is backed by M0’s $M tokens, which represent fully collateralized digital dollars redeemable 1:1 against tokenized U.S. Treasury holdings.

Market Capitalization

USDai’s total market capitalization currently stands at approximately 500 million, the maximum supply permitted under its current minting cap.

The majority of circulating supply (around 410 million, or more than 80%) resides on Arbitrum, which serves as the primary network for minting and redemption operations. Within Arbitrum, roughly 55% of USDai supply is deployed across Pendle PT markets, while approximately 40% is locked in the sUSDai staking contract, contributing to the protocol’s lending liquidity for GPU financing.

Following the recent launch of Plasma, USDai has become a multichain asset, extending beyond Arbitrum. Approximately 90 million of the total supply now circulates on Plasma.

Liquidity

Total on-chain liquidity for USDai on Arbitrum is approximately $32 million, distributed across several decentralized exchanges. However, the composition of this liquidity is highly imbalanced, with the vast majority of depth concentrated on the USDC side of trading pairs, reflecting persistent secondary market demand and USDai’s premium relative to parity.

Most available pools pair USDai against USDC, spanning multiple venues. On Uniswap v3, there are four active pools across different fee tiers, though each displays limited USDai-side depth due to concentrated liquidity positioning. On Curve, a single pool holds around $7.5 million, but its composition is also highly imbalanced, with the majority of assets held in USDC rather than USDai. The largest nominal liquidity resides on Fluid, with approximately $20.5 million in total pool size, yet over 99% of this liquidity consists of USDC, as USDai’s premium discourages two-sided market-making. Additionally, PancakeSwap hosts a small USDai–USDC pool with roughly $270,000 in liquidity.

USDai’s deployment on Plasma has introduced substantial nominal liquidity, with total depth across USDai–USDT0 pairs reaching approximately $182 million. Despite this headline figure, the liquidity composition mirrors the imbalance observed on Arbitrum, only about 3% of the TVL is in USDai, with the remaining 97% is in USDT0. This skew reflects USDai’s persistent premium and the limited supply available due to the protocol’s 500 million mint cap.

Mint and Redemption

USDai minting and redemption occur exclusively on Arbitrum. Both operations are atomic. To facilitate issuance on M0 infrastructure, the team maintains a dedicated Uniswap v3 USDC–$M 0.01% redemption pool on Arbitrum. When a user mints USDai with USDC, the flow swaps USDC for $M in that pool, and the acquired $M is then used within the same call to mint USDai.

Under the hood, the USDai contract relies on a SwapAdapter that routes between USDC and M0’s base asset ($M). USDai is minted only after the adapter has delivered the base token to the USDai contract. Likewise, redemptions burn USDai and route back through the adapter to return the requested asset to the user.

Liquidity Management for Mint and Redemption

The USDai team is the sole liquidity provider in the USDC–$M 0.01% redemption pool, maintaining tight operational control over the mint and redemption pipeline.

As minting activity dominates (given that redemptions are rare due to USDai’s persistent secondary market premium), the pool’s balance naturally skews toward excess USDC and depleted $M liquidity. This occurs because users continuously swap USDC for $M to mint new USDai, drawing down the available $M reserves in the pool.

To rebalance liquidity, the team periodically withdraws excess USDC from the pool on Arbitrum and bridges it to Ethereum mainnet, where M0’s core contracts reside.

On mainnet, the USDC is used to acquire $M tokens directly through the M0 protocol, the only network where $M creation and redemption are supported.

Acquired $M tokens are then bridged back to Arbitrum and redeposited into the Uniswap v3 pool, restoring equilibrium between USDC and $M liquidity.

It also underscores that liquidity synchronization with M0’s mainnet infrastructure remains operationally managed by the team.

Mint Flow

Below is the on chain sequence for minting USDai, centered on the USDai contract:

  1. User calls deposit on USDai contract. This is the primary entry point for minting.
  2. USDai pulls the input asset from the user. The contract transfers depositAmount of depositToken from msg.sender to itself using SafeERC20.safeTransferFrom.
  3. If the input asset is not the base token ($M), USDai swaps into the base token via the Uniswap v3 SwapAdapter. Most of the cases, depositToken is USDC and the adapter routes through the Uniswap v3 USDC–$M pool to acquire $M.
    • The pool operates on a 0.01% fee tier, meaning each swap incurs a trading fee.
    • The amount of $M received depends on current pool depth and execution price, so the final USDai minted reflects the effective post fee and post price impact amount of $M obtained.
    • If the input is already the base token ($M), the contract skips the swap entirely and mints USDai on a 1:1 basis.
  4. The acquired $M becomes the underlying collateral recorded on the contract balance. This $M will remain in custody of the USDai contract until redemption occurs.
  5. Checks that the supply cap is not exceeded, and prepares the USDai amount to mint. The cap enforcement is applied unless the caller has the DEPOSIT_ADMIN_ROLE.
  6. The contract calls _mint and emits a Deposited event. The entire path from user call to mint is atomic. If any step fails, the transaction reverts.

Redemption Flow

Below is the on chain sequence for redeeming USDai, centered on the USDai contract:

  1. User calls withdraw on USDai, this is the primary entry point for redeeming USDai back into supported stablecoin i.e USDC.
  2. The contract calls _burn(msg.sender, usdaiAmount) to remove the tokens from circulation, reducing total supply proportionally.
  3. If the output asset is not $M, USDai swaps out via the Uniswap v3 SwapAdapter.
    • The contract withdraws an equivalent amount of $M from its own holdings.
    • It approves the SwapAdapter to perform a swap from $M to USDC via the Uniswap v3 $M–USDC pool.
    • The swap is subject to the same 0.01% fee tier and any price impact.
  4. After completing the swap, the contract sends the resulting USDC to the user and emits a Withdrawn event.

The entire burn, swap and transfer sequence executes atomically. The USDai contract first withdraws $M from its holdings, swaps it for USDC and transfers it to the user, all within one transaction.

Peg Performance

Since mid-August, USDai has consistently traded above its intended $1.00 peg, reflecting excess market demand relative to its fixed minting cap. The premium first appeared as the cap was reached on Arbitrum, but it intensified following the launch of USDai on Plasma, where additional incentive programs accelerated capital inflows.

During early October, the over-peg reached levels of up to 6% on both Arbitrum and Plasma, with USDai frequently trading between $1.03 and $1.06 across DEXs. This sustained premium created secondary effects in lending markets that integrated USDai as a borrowable asset.

In response, a lending protocol coordinated with the USDai team to adjust parameters and announce a forthcoming increase to the protocol’s minting cap, as referenced in USDai’s public communication. Following this announcement, USDai’s premium began to moderate, declining from 6% to approximately 3% above peg.

As of the latest observations, USDai continues to trade around $1.03, maintaining a moderate over-peg due to persistent demand and the still-active supply cap. The token is not expected to fully revert to par until additional mint capacity is introduced.

sUSDai

sUSDai is the yield-bearing version of USDai, functioning as the capital deployment layer of the USDai ecosystem. While USDai serves as the fully collateralized, liquid base stablecoin, sUSDai represents staked USDai that is actively utilized to generate yield from both GPU-backed credit issuance and Treasury bill–backed reserves.

When users stake USDai into the sUSDai contract on Arbitrum, the tokens are locked and become part of the protocol’s lending liquidity. Although sUSDai is live on Plasma, all staking and unstaking operations occur exclusively on Arbitrum, where the underlying USDai collateral is managed. The USDai staked in the contract serves as the primary source of capital for GPU-backed loans originated through the USDai protocol.

In return for providing this capital, sUSDai holders are entitled to the protocol’s aggregate yield, which is composed of two income streams:

  1. T-bill yield from the underlying USDai collateral held through the M0 infrastructure, and
  2. Interest repayments from active GPU-backed loans, which are overcollateralized through the CALIBER and FiLo frameworks.

While USDai is designed to maintain a stable, low-risk profile, sUSDai carries a more dynamic and risk-sensitive exposure. Its yield potential scales with the proportion of total capital deployed into GPU financing, but so does its risk, since defaults or collateral depreciation in GPU-backed loans could impact sUSDai’s backing and redemption liquidity.

At present, approximately 30% of total USDai supply is staked in the sUSDai contract.

Of this amount, only 0.9% of the backing is currently deployed toward active GPU loans, while the remaining 99% remains passively held as USDai. However, this utilization ratio is expected to rise sharply as additional GPU loan facilities are onboarded. The protocol anticipates utilization to increase from 0.9% to over 20% by October, reflecting the next phase of capital deployment.

The long-term vision for sUSDai is to transition from a predominantly T-bill–backed instrument into one where GPU-backed loans constitute the majority of yield generation. This transition is expected to enhance overall returns for stakers but also introduces structural challenges. As a greater share of staked USDai is lent out for 3 year GPU financing, the available liquidity for sUSDai redemptions will decrease.

Although the protocol currently enforces a 30-day unstaking cooldown period, sustained increases in loan utilization will naturally make it progressively harder to service all redemptions within that window. This could result in temporary liquidity imbalances or market depegs on secondary venues during periods of high redemption demand.

Active GPU-Backed Loans

As of October 2025, two GPU-backed loan positions are active within the USDai ecosystem, representing the first real-world deployments of the protocol’s CALIBER framework. Together, they total approximately $1.27 million in principal exposure. Both positions are structured as Equipment Purchase and Sale Agreements (PSAs) between Permian Labs, Inc. and the respective GPU operators (Tactical Compute Holding Ltd and Compute Labs Inc), using blockchain-based Electronic Documents of Title compliant with UCC Article 7.

1. Tactical Compute Holding Limited

  • Jurisdiction: Abu Dhabi Global Market (ADGM), UAE
  • Loan Size (Protocol Proceeds): $620,243.86 USDC
  • Fixed Payments: $17,229.00 per 30 days for 36 months
  • Variable Payments: ~1.23% monthly (ā‰ˆ 15% annualized)

Business and relationship context:

Tactical Compute is not an unrelated borrower, it is a joint venture between Aethir, Beam Foundation and MetaStreet (Permian Labs). The venture operates as a $40 million AI compute initiative, aiming to finance and deploy GPU-based compute infrastructure for Web3 and AI applications. Tactical Compute acts as a bridge between Aethir’s decentralized GPU network (43,000+ GPUs across North America, Europe, and Asia) and Permian’s credit structuring layer, using USDai as the financing medium.

Risk considerations:

While counterparty creditworthiness benefits from the backing of entities (Aethir, Beam, MetaStreet), the loan carries cross-jurisdictional enforcement risk, since the GPUs are physically located outside the U.S. and the bailee operates under ADGM law. If Tactical Compute defaulted, enforcing title recovery under UCC Article 7 may be challenging in foreign courts.

2. Compute Labs, Inc.

  • Jurisdiction: Delaware, United States
  • Loan Size (Protocol Proceeds): $649,600 USDC
  • Fixed Payments: $18,044.44 per 30 days for 36 months
  • Variable Payments: ~1.23 % monthly (ā‰ˆ 15 % annualized)

Business and credit profile:

Compute Labs is a U.S. based AI-infrastructure company focused on tokenizing and financing GPU hardware through blockchain. The firm develops compute-backed financing solutions that enable investors to gain exposure to real-world compute capacity. It operates under Delaware jurisdiction.

Market Capitalization

The total supply of sUSDai has reached over 160 million, representing approximately 30% of all circulating USDai currently staked in the protocol’s yield-bearing contract.

The majority of this supply (around 135 million sUSDai, or 85% of the total) resides on Arbitrum, which serves as the primary network for staking and redemption operations. The remaining 25 million is deployed on Plasma.

This staked capital forms the core lending pool of the USDai ecosystem, liquidity that can be mobilized to finance GPU-backed loans originated through the protocol’s CALIBER and FiLo frameworks.

Liquidity

Total on-chain liquidity for sUSDai on Arbitrum stands at approximately $40 million, distributed across several DEXs.

The vast majority, around 80% of this liquidity, is concentrated in a Curve pool against USDC, which serves as the primary trading venue for sUSDai. While this pool provides the deepest market depth, its composition is notably imbalanced, with the majority of assets held in USDC rather than sUSDai, reflecting persistent secondary market demand and sUSDai’s recurring premium above parity.

This structural imbalance is consistent across other venues on Arbitrum, where liquidity provisioning remains skewed toward the stable side of the pair. As a result, only about 10% of the total DEX liquidity on Arbitrum is composed of sUSDai itself.

On Plasma, sUSDai liquidity remains comparatively limited, with approximately $4 million in total DEX depth. Nearly all of this liquidity is concentrated in a Balancer pool against USDT0, which serves as the primary market venue for the asset on the network.

Unlike on Arbitrum, the liquidity composition within this pool is more evenly balanced between sUSDai and USDT0, despite sUSDai also trading at a premium on Plasma.

Mint and Redemption

Minting sUSDai with USDai is an atomic operation, executed directly through the staking contract on Arbitrum. When users deposit USDai, the protocol immediately locks the tokens and issues an equivalent amount of sUSDai, representing a claim on the pooled capital that underpins both T-bill–backed reserves and GPU financing.

Redemption, by contrast, is subject to a 30-day cooldown period. This mechanism governs the process of converting sUSDai back into USDai, introducing a time buffer helps the protocol to manage liquidity between redemption demand and longer-term GPU-backed credit positions.

Importantly, the cooldown period does not guarantee redemption within 30 days. Since sUSDai’s backing is partially deployed into 3 year amortizing GPU loans, redemptions are fulfilled strictly from available liquidity at hand. The protocol does not liquidate active GPU loans to satisfy redemptions.

As a result, during periods of high redemption demand and/or elevated loan utilization, users may experience longer exit durations, with actual redemption timelines determined by the system’s liquidity composition and the maturity profile of outstanding loans.

Mint Flow

When a user decides to stake USDai to receive sUSDai, the process is executed atomically within the StakedUSDai contract on Arbitrum.

The sequence begins when the user calls the deposit() function on the StakedUSDai contract, specifying the amount of USDai to stake and the address that should receive the newly minted sUSDai.

Upon receiving the call, the contract first verifies that deposits are currently enabled. The contract calls its internal _sharePrice() function (via depositSharePrice()) to determine the current exchange rate between USDai and sUSDai.

This share price is computed as:

sharePrice = totalAssets / (totalSupply + bridgedSupply + pendingRedemptions)

Where,

  • totalSupply refers to the sUSDai circulating on Arbitrum,
  • bridgedSupply represents the sUSDai bridged to Plasma (and future chains), and
  • pendingRedemptions accounts for the tokens already submitted for withdrawal but still in the cooldown queue.

On the numerator side, totalAssets aggregates all USDai-equivalent value backing sUSDai shares:

totalAssets = basePositionAssets + poolPositionAssets + idleUsdaiBalance

Where,

  • basePositionAssets represents the yield accrued from the T-bill backed USDai reserves. It captures the ongoing income generated by the M0 layer, reflecting the realized T-bill yield.
  • poolPositionAssets measures the capital actively deployed into GPU-backed loan pools managed through the protocol’s lending infrastructure. These assets include all outstanding loan principal, accrued interest and recovered amounts, representing the productive portion of sUSDai capital that finances real-world GPU infrastructure.
  • idleUsdaiBalance denotes the unallocated USDai held directly by the StakedUSDai contract. This balance acts as an immediate liquidity buffer to facilitate redemptions and/or fund new loan allocations.

Once the share amount is determined, the contract transfers the user’s USDai from their wallet into the staking contract using SafeERC20.safeTransferFrom. The transferred USDai immediately becomes part of the pool’s total assets and is available for allocation to upcoming loan originations.

After receiving the USDai, the contract mints the calculated number of sUSDai tokens to the specified receiver’s address.

The contract emits a Deposit event that logs the transaction details: the depositor’s address, receiver, deposit amount and minted share quantity.

The newly deposited USDai is now held within the StakedUSDai contract and can be allocated by the protocol’s liquidity management module PoolPositionManager toward into GPU-backed loans.

Redemption Flow

When a user decides to redeem sUSDai back into USDai, the process unfolds in two phases (a redemption request and a later withdrawal) coordinated through the RedemptionLogic module and the on-chain redemption queue.

The sequence begins when the user calls the requestRedeem() function on the StakedUSDai contract, specifying the amount of sUSDai shares to redeem. The user can submit the request directly or through an authorized operator set via setOperator().

Upon receiving the call, the contract validates that redemptions are enabled, verifies the user’s sUSDai balance and burns the specified shares from their wallet. The redemption request is then recorded in the on-chain queue through RedemptionLogic._requestRedeem().

Each request is assigned a unique redemption ID and timestamped with a cliff time, determined by the global timelock parameter (currently 30 days).

This timelock defines the minimum period a user must wait before their redemption becomes claimable. During this cooldown, the request is added to the queue and tracked as pending shares, included in the pendingRedemptions value that contributes to the share price calculation.

Once the cooldown period has expired and liquidity becomes available, the queued requests can be serviced.

Servicing is initiated by the protocol’s strategy admin, who calls serviceRedemptions() to process pending requests in the on-chain queue.

This triggers RedemptionLogic._processRedemptions(), which fulfills requests in strict FIFO order. There is no discretionary control over which redemptions are processed first until the previously discussed QEV mechanism is implemented.

Crucially, the serviceRedemptions() function includes an explicit safeguard to ensure that only redemptions that can be fully backed by available liquidity are processed:

if (amountProcessed > _usdaiBalance()) revert InsufficientBalance();

This means the strategy admin cannot process redemptions if the contract’s idle USDai balance is insufficient, even if some requests have completed their 30-day cooldown.

As a result, redemption servicing is entirely liquidity-dependent: if cash is not yet available from monthly GPU loan repayments, idle USDai balance or T-bill yield the queue remains paused until sufficient funds accumulate.

Once redemptions are processed and liquidity allocated, users can claim their USDai by calling redeem() . This functions internally invoke RedemptionLogic._redeem(), which transfer the corresponding USDai to the user’s wallet and emit a Withdraw event recording the transaction details.

Since launch, on-chain redemption activity has remained low. The strategy admin has serviced the queue once, on September 19, 2025, processing 83 redemption requests in a single batch. Of these, 38 requests have been claimed by users.

In total, 142 redemption requests have been submitted. The limited servicing frequency and low claim ratio reflect minimal reliance on the native redemption mechanism, largely because sUSDai has consistently traded at a premium, allowing users to exit through secondary markets instead of waiting for the cooldown period.

Peg Performance

sUSDai has consistently traded at a premium to its intended exchange rate with USDai.

At its highest point, the secondary market premium reached approximately 4.2%, before moderating to around 2%.

This behavior closely mirrors that of USDai, which itself trades above $1.00 due to its fixed minting cap. Because sUSDai can only be created by staking USDai, the two assets share the same supply limitations.

Risks

Both USDai and sUSDai introduce new design trade-offs relative to conventional stablecoins and yield-bearing assets.

While the system is fully collateralized and legally structured to minimize insolvency risk, it remains exposed to several categories of market, liquidity and operational risks.

1. Peg Volatility and Secondary Market Dynamics - USDai

The fixed 500 million minting cap creates an inherent supply bottleneck. As demand for USDai rises, the lack of new issuance pushes the token to trade at a premium above $1, a pattern already observed across both Arbitrum and Plasma. While this premium indicates strong demand, it introduces peg volatility that can disrupt integrations with lending protocols.

When USDai trades above par, liquidators are disincentivized to repay USDai-denominated debt, as they would need to repurchase USDai on the secondary market at a higher price than the protocol’s internal pricing, making liquidations economically less attractive.

This friction complicates USDai’s use as a borrowable asset in collateralized lending protocols.

2. Liquidity Management and Operational Risk – USDai

USDai’s mint and redemption pipeline relies on a Uniswap v3 USDC–$M pool on Arbitrum, which serves as the primary on-chain venue for converting between M0’s base asset ($M) and USDai’s deposit currency (USDC).

While the system is designed for atomic issuance and redemption, it introduces several operational dependencies that can affect liquidity availability and redemption timelines:

Liquidity Pool Dependence:

All redemptions route through the Uniswap v3 pool, where executions are subject to the prevailing pool depth, swap fees (0.01%) and price impact. Under conditions of thin $M liquidity, redemptions may experience slippage or temporarily limited capacity until liquidity is replenished.

Cross-Chain Liquidity Rebalancing:

The USDai team is the sole liquidity provider in this pool and manually manages its balance. When persistent minting activity depletes $M reserves, the team withdraws excess USDC, bridges it to Ethereum mainnet, mints new $M through the M0 protocol, and bridges the $M back to Arbitrum. This process introduces an operational reliance on manual cross-chain rebalancing.

In periods of high redemption demand or network congestion, cross-chain bridging delays or temporary bottlenecks in M0’s mainnet minting capacity could pause or slow USDai redemptions, breaking the assumption of atomic liquidity on Arbitrum.

Until the team completes a new liquidity cycle, redemption processing could temporarily stall.

These factors introduce a layer of operational and timing risk to USDai’s otherwise fully collateralized design.

While not solvency-related, such dependencies could create short-term redemption delays or localized slippage during peak on-chain activity or sustained imbalance between USDC and $M liquidity.

3. Liquidity and Redemption Risk - sUSDai

sUSDai’s redemption model is designed to prioritize long-term stability for borrowers rather than instant liquidity for lenders.

While only ~1% of the current collateral base is deployed into GPU-backed loans, the protocol expects utilization to rise substantially over time.

As utilization increases, a greater portion of sUSDai will be backed by illiquid, amortizing loans, which cannot be liquidated to service withdrawals if borrower is not defaulted.

Redemptions are expected to fulfilled solely through idle USDai balances and monthly loan repayments.

During periods of high redemption demand, the protocol may be able to service only a fraction of queued requests, extending withdrawal timelines well beyond the nominal 30 day cooldown.

This structural liquidity lag increases the likelihood that sUSDai could trade below its exchange rate to USDai during stress events.

4. Collateral Value and Depreciation Risk - sUSDai

As the protocol expands GPU-backed lending, sUSDai’s collateral composition will become increasingly sensitive to the market value of GPUs.

While GPUs are currently in high demand, their prices can decline sharply due to new model releases, technological obsolescence or reduced AI infrastructure spending.

If GPU valuations fall faster than expected, the protocol’s collateral coverage could weaken, reducing the effective backing of sUSDai and amplifying redemption pressure.

5. Credit and Counterparty Risk - sUSDai

The sUSDai system involves multiple counterparties whose collective performance determines credit quality:

  • Borrowers may default or enter bankruptcy, triggering on-chain liquidations.
  • FiLo Curators may extend credit to financially weak or speculative GPU purchasers whose cash flows are insufficient to service debt, resulting in poor underwriting quality and potential first-loss absorption that diminishes the protection of the senior sUSDai tranche.
  • Data centers and SPVs introduce operational dependencies for custody, maintenance and legal enforcement. Although SPVs is structured to be bankruptcy-remote and enforceable under UCC Article 7, practical enforcement can become complex when counterparties or data centers operate outside U.S. jurisdiction. In such cases, the legal recognition of electronic documents of title and bailment agreements may not be uniformly upheld, potentially complicating repossession or collateral recovery.

Furthermore, because on-chain liquidation of physical GPU claims has no historical precedent, the secondary market for repossessed GPU NFTs remains untested and may exhibit limited liquidity in distressed scenarios. Although the team is in contact with GPU resellers for potential liquidation pathways, such mechanisms have yet to be validated in practice.

These factors collectively introduce material counterparty and enforcement risk that could affect recovery rates in the event of borrower default.

Conclusion

While the USDai protocol represents a sophisticated attempt to bridge DeFi liquidity with real-world compute infrastructure, the system’s reliance on GPU-backed lending introduces additional layers of liquidity, operational, and enforcement complexity. These challenges are further compounded by the limited visibility into secondary market demand and resale liquidity for GPUs, which could materially affect collateral recovery and loan performance under stress conditions.

Chaos Labs recommends deferring the listing of both USDai and sUSDai and reassessing at a later stage, once the ecosystem and GPU market dynamics have matured, the USDai minting caps are lifted and a reliable redemption mechanism is demonstrated.

Disclaimer

Chaos Labs has not been compensated by any third party for publishing this recommendation.

Copyright

Copyright and related rights waived via CC0

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Summary

LlamaRisk does not support the onboarding of USDai and sUSDai at this time. Key risks surrounding these assets relate to asset categorization, GPU collateral liquidity uncertainty, peg instability, and legal design concerns. USDai is a synthetic dollar backed by U.S Treasury Bills, and sUSDai is a yield-bearing lending pool share token that generates yield from T-Bills and GPU loans, primarily targeted to the AI industry. While USDai falls into the category of reserve-backed stablecoins, we believe sUSDai would represent a new category of assets that needs to be pre-approved.

sUSDai’s model of financing GPUs presents liquidity concerns in the event of loan defaults. The 7-day liquidation window introduces greater liquidity constraints relative to other onboarded assets. USDai describes utilizing onchain and offchain components to manage liquidations, e.g., Primary and secondary resellers; however, critical elements to the process are yet to be finalized, which limit visibility on the resale value and possibilities of the underlying asset under live onchain conditions. At the time of writing, sUSDai is 99.8% collateralized by U.S. T-Bills and 0.2% by initial GPU loans. Additional loans are lined up for later this month.

USDai’s current supply cap also makes it an unfavorable asset to onboard due to the unstable peg borne from the supply cap set to ~$580M. Any future onboarding should be dependent on caps being removed to facilitate a more aligned peg to the Dollar. Lastly, the legal design of the USDAI protocol, while novel and coherent, lacks a track record of tested outcomes for us to support onboarding on these grounds.

1. Asset Fundamental Characteristics

1.1 Asset

USDai is a non-yield bearing stablecoin backed by $M, an M0 protocol-issued token that U.S. Treasury Bills back. $M’s current reserve composition consists of U.S. Treasuries (up to 90 days) and Superstate’s USTB. wM is USDai’s base asset, $M’s non-rebasing wrapper.

Staked USDai (sUSDai) is a yield-bearing ERC4626 token that earns yield from USDai M emissions and AI infrastructure loans - primarily GPUs. The funding of underlying assets involves a tokenization process that purchases GPUs and transfers title ownership to USD.AI until the loans are fully repaid. Loan terms are fixed to 3 years, and assets are ā€˜leased’ to borrowers for their operations.


Source: Loan funding process, USDai Docs

Yields accrue to sUSDai only, with yields currently sourced primarily from $M emissions. Currently, only 2 loans have been issued collectively worth $1.2M, making up less than 0.2% of reserve allocation, with an additional 5 loans expected, the first of which is scheduled to start on October 29th (labeled ā€œclosingā€ stage).

1.2 Architecture

5 core components enable the USD.AI protocol:

  • CALIBER: an RWA tokenization framework
  • FiLo: an underwriting and loan generation layer
  • QEV: a market-based redemption queue management system
  • Metastreet: Lending pool and auction layer protocol
  • M0 Protocol: Extensions wrap/unwrap for underlying $M collateral for custom stablecoin deployments.
  • Offchain Components

CALIBER

USD.AI utilizes its own system for collateralizing physical assets called CALIBER (Collateralized Asset Ledger: Insurance, Bailment, Evaluation, and Redemption), a tokenization model that is intended to improve collateral rights enforcement and risk management.

The framework follows Uniform Commercial Code Section 7 (Article 7). UCC compiles laws that govern commercial transactions in the U.S., which have been adopted and are enforceable across U.S. jurisdictions. Article 7 focuses on documents of title for property involved in commercial transactions. Under CALIBER, ownership of underlying assets (in this case, GPUs) is direct, and, given UCC 7 requirements, ownership is represented in a 1:1 ratio as ERC721s. This enables the enforcement of ownership, redemption, and embeds insurance.

Key differentiating features of CALIBER relative to traditional RWA frameworks:

Feature CALIBER Traditional RWAs
Ownership Direct, 1:1 asset ownership via an ERC-721 NFT. No direct control via fungible ERC-20 tokens.
Enforcement Onchain repossession and resale. Legal processes, debt restructuring, and court involvement.
Insurance Warehouse coverage. Per-deal insurance onboarding.
Default Process Onchain auctions within a 14-day redemption window. Legal action is required, involving bankruptcy courts.

Source: CALIBER, USD.AI docs

CALIBER GPU tokenization-to-loan process:

  1. A Borrower sets up a bankruptcy-remote SPV and transfers GPU ownership to the entity.
  2. The SPV enters into a Bailment Agreement with the Datacenter, where the GPUs are housed and maintained. Permian Labs (USD.AI) tokenizes the agreement (NFT), which represents the ā€œElectronic Documents of Titleā€. GPUs remain operational for the borrower.
  3. Borrower deposits the NFT as collateral into USD.AI’s lending pool and borrows USDC up to 70% Loan-to-Value. Loans have a 3-year term, with repayments made every 30 days. Loans are exclusively for collateral only.
  4. LTVs are adjusted linearly as hardware ages.


Source: Loan Execution, USD.AI docs

FiLo

First Loss Curators (FiLo) are used to originate and verify loans for the USD.AI protocol, receiving an incentivized 3-10% admin fee for underwriting. Curators take first-loss positions in the event of defaults in exchange for higher yields. Curators are onboarded to a whitelist via a governance process before they can underwrite loans. Permian Labs is currently the only FiLo curator, with additional curators being vetted (USD.AI indicated to us that this would be disclosed in the future).

USD.AI uses Metastreet’s lending pool infrastructure to create loans and manage liquidations (see Metastreet section below). All loans issued are required to include a first-loss tranche (5% of the 70% LTV). Loans issued by the protocol have an equity cushion of 30%, with an additional 5% for non-FiLo lending pool participants. A small set of curators is planned initially, and loans are only issued for tokenized insured assets and not for other purposes, such as business loans or purchase orders.

Hardware loans are available for both new and used assets. New GPU prices are relatively standardized from OEMs with minimal variations. Secondary market prices are sourced from hardware partners, namely, Evertas, Blockware, and Procurri (see ā€˜Hardware Partners’ section below). Valuations of used GPUs present more price variability than new GPUs due to the introduction of additional factors, such as usage, condition, and model age.


Source: First Loss Curation Model, USD.AI docs

If a borrower defaults (i.e., misses a payment and one 30-day grace period)

  1. The deposited NFT is sold via the lending pool’s permissionless auction contract.
  2. The new holder of the document of title can claim the GPUs or enter into a new colocation agreement with the datacenter.

Collateral from defaults enters a 7-day English auction (highest bidder). Post settlement, NFT redemptions from datacenters require a 14-day notice period, with holders being required to pass independent KYCs. Hardware partners and FiLo curators are intended to facilitate the resale process, participating directly and indirectly in the resale process. The USD.AI team informed us that they plan on creating a GPU market maker for a more aligned resale process post-ICO.

USD.AI states that they are currently onboarding hardware partners for the resale process of GPUs, with FiLo curators to provide initial bids. GPUs are not appraised before being liquidated, and market prices are provided by USD.AI’s hardware partners, with proceeds going to sUSDai’s NAV. Additionally, an ICO is planned for the USD.AI protocol, with funds generated used as buffer reserves to fund purchases of defaulted loans for short-dated holding periods. The funds will be used in a revolving credit facility to amplify reserves; the status and value of the ICO is still in development, with the Allo Points program determining access and allocation to the ICO underway (the team has communicated that arrangements are being made with counterparties).

At the time of writing, 99% of deployed funds are currently invested in US T-Bills (via $M underlying collateral), with GPU loans accounting for a marginal percentage of deployed funds (0.2%). GPU auctions, therefore, are yet to be demonstrated as presented by USD.AI.

QEV

Queue Extractable Value (QEV) is a dynamic pricing mechanism that will manage access to available liquidity and withdrawal queues, ordering redemptions through an auction-based model. The aim of this is to address the challenge that illiquid assets, such as RWAs, pose when holders want to redeem but are hindered by liquidity constraints due to the rigid redemption cycles of these assets.

Given the predefined repayments of USD.AI loans, withdrawals are scheduled incrementally in sync with amortization schedules. QEV sums distributions based on a 30-day cycle until an auction, creating visibility on predefined liquidity flows. Redemption slots are dynamically priced and tradeable.

QEV will be synchronized to 30-day intervals that sum all the distributions (inflows and outflows) between auction periods, managing liquidity for repayments and withdrawals based on a 30-day epoch. Limited redemption liquidity is prioritized via a bidding process. If no bids are made in an epoch, then queuing works on a FIFO ordering system. If no redemptions are logged, then liquidity is reinvested into new loans or T-Bills.

Source: QEV Redemption Queue, USD.AI docs

This process structures sUSDai withdrawals on fixed intervals, making direct instant withdrawals unavailable as a possible venue for Aave liquidations. QEV is not yet active.

Metastreet

Loans are enabled by Metastreet’s Automatic Tranche Maker (ATM), a permissionless lending protocol, allowing USD.AI to create lending pools against NFT collateral. Pools can be exposed to more than 1 NFT (bundled wrappers), with lender positions/shares in each pool represented by Liquid Credit Tokens (LCTs), liquid ERC20 tokens.

The lending pool infrastructure allows USD.AI to determine pool parameters, such as the maximum loan limits (LTV), loan durations, and interest rates. At the time of writing, 2 USDAI loan pools are currently active on Metastreet markets (USDAITH / USDC 1 and USDAI-TH/USDC 2).

  • Repayments

Onchain loans are structured as zero-coupon loans that are repaid and rolled over every 30 days with protocol-facilitated flashloans. The fixed term of the loan is maintained as loans are paid off and periodic new loans are initiated with refinanced conditions representing the balance of the loan. Repayments that periodically service loans call the refinance function in the lending pool contract, updating loan terms and debt position remains open (see a transaction example here). In contrast, repay calls close the loan and return collateral.

  • Defaults

Overdue loans can be liquidated by anyone after a single grace period, and the collateral of defaulted loans is transferred to an auction liquidator contract. Onchain liquidations follow English auctions.

To date, no USD.AI loans have been liquidated. Metastreet auction history indicates varying default rates and auction profits, i.e., proceeds less outstanding debt (recent auction profits ranged between -99% and +261% but have largely seen positive returns).


Source: Metastreet, Dune, October 15th, 2025

M0 Protocol

USDai forms part of M0 protocol custom stablecoins, which are built using M0 Extensions. Extension architecture involves wrapping $M to collateralize USDai and unwrapping in a 1:1 atomic conversion process. Extensions inherit the security and yield properties of $M tokens while allowing projects to add their own features, branding, and business logic. For a more extensive analysis of the M0 protocol, see our onboarding assessment of mUSD here.

Offchain Components

USD.AI relies on several offchain/real-world components to enable sUSDai:

  • Datacenters: Tokenized GPUs are required to be colocated in datacenters that are compliant with USD.AI’s insurance policy with their insurance provider Evertas. Tier 3 or Tier 4.) datacenters are automatically approved, while Tier 1 and 2 datacenters require a site visit and an insurance policy from Evertas.
  • Hardware Partners: This consists of offchain organisations that USD.AI engages with in relation to GPUs.
    • Original Equipment Manufacturers (OEMS): facilitate procurement of hardware, e.g., NVIDIA, SuperMicro, and Dell.
    • Brokers: Supports the origination of loans and sourcing hardware, e.g., Hydrahost
    • Insurance Services: Physical insurance coverage provider, e.g., Evertas
    • Primary Resale Purchasers: Participate in default auctions, e.g., cloud server marketplaces.
    • Intermediaries Market Makers: providing resale pricing and market-making services, operating as outright buyers of used GPUs and on consignment with an economic partner. E.g., Blockware, Procurri, FarmGPU, and Dataslayer.

Risk Profiles

USDai and sUSDai represent differing risk profiles, with USDai functioning more akin to a fiat-pegged, reserve-backed stablecoin. sUSDai, in contrast, functions as a lending pool share token, collateralized by RWA loans. sUSDai stands out as an asset that falls outside of the Aaca categories; initial approval of this type of asset should be determined.

1.3 Tokenomics

USDai is minted when supported stablecoins (e.g., USDC, USDT) are deposited and swapped for the base token $M. Swaps through Uniswap are facilitated by the SwapAdapter contract. Redemptions function similarly, with USDai being deposited, burned, and $M swapped for USDC/USDT. Conversions occur on an instant 1:1 basis; however, during high withdrawal periods, liquidity will be made available within 24 business hours through M0.

USDai currently has a deposit cap of $581.2M which has been filled. The USD.AI notified us that the cap would be lifted post the expiry of the 20Nov2025 Pendle pool.


Source: Minting USDai, USDai docs

sUSDai is minted when USDai is staked at a quoted deposit share price. Deposited USDai is burned for underlying M tokens, which are then swapped for the lending pool’s base token. Redemptions unstake sUSDai for USDai at the prevailing redemption share price following a 30-day timelock.

Redemptions are currently on a FIFO basis, but will change to an auction system as loans are introduced (as described in the QEV section).


Source: Minting sUSDai, USDai docs

USDai and sUSDai are issued on Arbitrum, with bridged deployments available on Plasma. The LayerZero OFT standard is used as a bridging mechanism, which represents an established standard accepted by Aave.

NAV and Share Pricing

The Net Asset Value (NAV) of sUSDai is the combined value of unallocated USDai and the total value of debt positions. Lending pool debt positions are estimated conservatively or optimistically.

  1. Conservative: estimates only include the principal of loans, in the case of default and liquidation.
  2. Optimistic: estimates principal plus real-time accrued interest of loans, in the case of repaymen.t

Realized interest is compounded back into the lending pool for new loan principals. The deposit share price quotes the optimistic NAV, while the redemption share price quotes the conservative NAV. Generally, the deposit share price is equal to or greater than the redemption share price. If there are no active lending positions, they are equal. This approach protects and incentivizes long-term investors, as they remain exposed to default risk, and prevents potential runs on pool liquidity.

Yield Accrual

Position Managers - BasePositionManager and PoolPositionManager - are responsible for harvesting M emissions from USDai and managing lending pool positions. sUSDai yield accruals are represented as the NAV increases less admin fee (yield is converted into sUSDai’s base asset USDai).

Admin fees

Lending admin fees are charged on loan repayments, based on a fixed percentage of the total interest on a loan. The current admin fee rate is set to 13.73%. In the event of a loan default, the admin fees are used to offset liquidation losses. Lending pool fees accrue to the Metastreet. A fee share of 36.4%, which splits a portion of the admin fee, is currently attributed to a Permian Labs-linked EOA.
A 10% sUSDai admin fee is charged for yields generated, with fees directed to a Multisig - 841F.

1.3.1 Token Holder Concentration

  • USDai

418.7M USDai is currently available on Arbitrum with 2,688 total holders. Supply is concentrated in a Pendle SY-USDai contract (~54%) and staked in sUSDai (~41%). The highest EOA holds ~0.3%.


Source: USDai holders, Arbiscan, October 16th, 2025

159.2M USDai is currently available on Plasma with 1,373 holders. Supply is concentrated in a Pendle SY-USDai contract (~54%). The second and third highest holders represent ~18% (2/5 Multisig) and ~13% (Uniswap USDai/USDT0 pool), while the highest EOA holds ~1.2%.


Source: USDai holders, Plasmascan, October 16th, 2025

  • sUSDai

136.5M sUSDai is currently available on Arbitrum with 2,462 holders. Supply is concentrated in a Pendle SY-sUSDai contract (~82%). The second and third highest holders represent ~2% each, while the highest EOA holds ~1.6%.


Source: sUSDai holders, Arbiscan, October 16th, 2025

30.4M sUSDai is currently available on Plasma with 996 holders. Supply is concentrated in a Pendle SY-USDai contract (~63%). The second and third highest holders represent ~19% (Euler Vault) and ~6% (EOA).


Source: USDai holders, Plasmascan, October 16th, 2025

2. Market Risk

2.1 Liquidity

2.1.1 Liquidity Venue Concentration

USDai liquidity on Plasma is concentrated in a single Balancer pool, with over $40M in TVL, while Arbitrum liquidity is spread between Curve, Fluid, and Uniswap pools.

Token Network Venue Pair TVL
USDai Plasma Balancer USDai/USDT0 $41.72M
Arbitrum Fluid USDai/USDC $20.9m
Uniswap USDai/USDC $5.34M
Curve USDai/USDC $5.15M
Uniswap USDai/USDC $766K

Source: USDai liquidity pools, GeckoTerminal, October 17th, 2025

sUSDai exhibits a similar pattern for venue distribution on Plasma and Arbitrum, as shown for USDai

Token Network Venue Pair TVL
sUSDai Plasma Balancer sUSDai/USDT $2.44M
Arbitrum Curve sUSDai/USDC $12.8M
Fluid sUSDai/USDC $2.79M
Uniswap sUSDai/USDT $1.66M

Source: sUSDai liquidity pools, GeckoTerminal, October 17th, 2025

2.2 Volatility

USDai

Since September 2025, USDai has consistently traded at a premium on both Arbitrum and Plasma. The lack of stability around the Dollar peg would represent onboarding an asset with a high-risk market feed, given its volatility.


Source: USDai/USDC (Arbitrum), Geckoterminal, October 18th 2025


Source: USDai/USDT (Plasma), GeckoTerminal, October 18th, 2025


Source: USDai Price Volatility vs Other Stablecoins, Entropy Advisors - Dune, October 18th, 2025

sUSDai

sUSDai appreciated in line with its internal yield accrual mechanism initially; however, October has seen more divergent fluctuations less in line with sUSDai’s underlying yield accrual.


Source: sUSDai/USDT (Arbitrum), GeckoTerminal, October 18th, 2025


Source: sUSDai/USDT (Plasma), GeckoTerminal, October 18th, 2025

2.3 Exchanges

Neither USDai nor sUSDai is currently available on centralized exchanges.

2.4 Growth

USDai has seen significant growth over the last 3 months, representing over $570M across Plasma and Arbitrum.


Source: USDai Circulating Supply, Entropy Advisors - Dune, October 18th, 2025

Current Staked USDai represents a 29% staking ratio and an expected utilization of 23% (upcoming loans). The team indicated that they have set an initial utilization of 50%, with a long-term target of 80% post-TGE.

3. Technological Risk

3.1 Smart Contract Risk

2 audits have been completed for USD.AI protocol. The following issue findings are summarized below:

  • Kais Tlili - Independent Auditor (May 14, 2025): 1 medium, 1 low, 2 informational
  • Cantina (May 12, 2025): 1 medium, 8 low, 1 gas optimization, and 10 informational

Metastreet audits:

  • Cantina (June 22, 2023): 6 medium, 7 low, 14 gas optimization, 16 informational
  • Cantina (October 3, 2023): 1 low, 2 gas optimization, 7 informational
  • Cantina (November 25, 2023): 1 low, 2 gas optimization, 7 informational
  • Cantina (April 30, 2024): 1 high, 2 low, 10 informational

M0 Protocol has undergone extensive audits, relevant audits to USDai, and their findings include:

  • M0 Protocol and TTG
    • Quantstamp (January 29, 2024): 1 medium, 9 low, and 11 informational
    • Three Sigma (February 2, 2024): 2 high, 2 medium, 11 low, and 17 informational
    • OpenZeppelin (February 15, 2024): 1 high, 6 medium, 7 low, and 8 informational
    • Prototech Labs (March 8, 2024): 3 critical, 4 high, 5 medium, 9 low, and 11 informational
    • Kirill Fedoseev (March 8, 2024): 1 high, 2 medium, 4 low, and 10 informational
    • Sherlock (March 27, 2024): 3 medium
    • Certora (April 2024): 2 critical, 1 high, 2 low, and 8 informational
    • ChainSecurity (April 24, 2024): 6 medium and 22 low
  • EVM M0 Extensions
    • Certora (July 2025): 2 high, 2 medium, 5 low, and 5 informational
    • ChainSecurity (July 21, 2025): 1 high, 4 medium, and 5 low
    • Guardian (August 5, 2025): 1 high, 4 medium, and 33 low

All issues were either fixed or acknowledged.

3.2 Bug Bounty Program

A Cantina-hosted bug bounty is active for USDai, with a max bounty of $100,000. Additionally, a MetaStreet bounty program with a max bounty of $50,000 is also available on Immunefi. M0 protocol currently does not have a bug bounty.

3.3 Price Feed Risk

USDai has a Chainlink USDAI / USD price feed on both Arbitrum and Plasma, while sUSDai only has an SUSDAI/USDAI exchange feed on Plasma.

USDai: Peg Stability Concerns

USDai’s deposit cap and utilization in sUSDai make the asset’s dollar peg potentially unstable. Since supply is capped, USDAI’s ability to restabilize through mint and redemption mechanisms is limited. As shown in section 2.2, USDai has persistently traded at a premium despite its underlying Dollar peg. The imposed supply cap prohibits the minting of new USDai, which would enable arbitrage opportunities that would help stabilize USDai on the open market. Inversely, should USDai trade at a discount, the assets redemption mechanism may be limited if USDai utilization in sUSDai loans is excessively high and during high liquidity demands.

sUSDai: Liquidation Concerns

Given that sUSDai’s NAV is the combined value of unallocated USDai and the total value of debt positions, should loans default and collateral sell below valuations, the drop in NAV once updated could lead to a series of sudden bad debt positions for Aave. This design introduces some uncertainty, given the time lag associated with repayments and 7-day liquidations.

USD.AI sources secondary market prices from hardware partners; however, price discovery visibility is limited for potential external liquidators without transparent marketplaces. This information asymmetry may hinder effective liquidations, limiting sUSDai to a limited set of liquidators.

3.4 Dependency Risk

Metastreet

sUSDai relies on Metastreets lending pool smart contracts for proper accounting and securing positions. Loan repayments are a critical part of ensuring that funds remain collateralized and yields are accrued. Failure to account for repayments, loan disbursements, or acceptance of incorrect collateral would increase counterparty risk and affect returns.

M0 Protocol

Like in our findings for mUSD, we note similar dependencies for M0. USDai inherits both the regulatory posture and technical architecture of the protocol. Consequently, any changes to M0 governance, particularly those affecting the $M token, which underpins USDai’s base liquidity and collateral structure, can directly impact USDai’s stability and functionality. M0-approved Minters (Bridge) and Validators (Chronicle) are trusted to operate cohesively, minting $M only with approved collateral, which directly affects USDai’s backing.


Source: M0, October 20th, 2025

According to the M0 dashboard, ~$10.3M USDai is held as reserve liquidity (a 2% over-collateralization buffer).

Superstate

A key dependency risk arises from Superstate’s USTB, which currently comprises around 41% of the $M reserves. The health of $M, and by extension USDai and other M0 Extensions, relies heavily on the operational and regulatory soundness of Superstate’s product.


Source: Superstate USTB Holdings, October 10th, 2025

LayerZero

Bridged USDai and sUSDai utilize LayerZero Omnichain Adapters to enable the cross-chain transfers as OFTs. OAdapters use a mint and burn system, utilizing LayerZero endpoints for cross-chain messaging. Bridging relies on the efficient operations of _debit (sender) and _credit (receiver) function calls through LayerZero infrastructure.

Datacenters

Organizations that assign tiers to datacenters, such as the Uptime Institute, determine the grade that datacenters are given based on several factors, such as redundancy, uptime, and sustainability. Should datacenters fall below the Tier 3 or 4 rankings required by USD.AI, then insured collateral may lose its coverage, potentially affecting the asset’s value and security.

Hardware Partners

USD.AI relies on external organizations in its offchain processes; in many instances, these dependencies are layered, form critical parts of USD.AI’s operations (e.g., pricing and resale service providers), and in one instance contingent (e.g., securing funds for revolving credit). Should a partner fail to perform liquidations effectively or discontinue the arrangement with USD.AI, this would severely impact the protocol’s ability to operate as designed.

4. Counterparty Risk

4.1 Governance and Regulatory Risk

USD.AI’s governance process is not fully defined in their documentation; however, sections indicate that governance may influence liquidity allocation, underwriting, interest rate controls, and sUSDai utilization caps.

ToS Review

USDai’s formally operative end-user instrument is its Terms of Service. The Terms select Delaware law as the governing law and, subject to matters preempted by the Federal Arbitration Act, designate Delaware as the forum for disputes. They regulate user access to and use of the USD.ai online services, website, software, and accompanying documentation provided in connection with the platform (collectively, the ā€œServiceā€). Operationally, the protocol and front end are described as being operated and maintained by Permian Labs DBA ā€œUSD.AI.ā€

The Terms do not expressly characterize USDai as a security, e-money, or any other regulated financial instrument. Instead, they deploy broad disclaimers, waivers, and limitations of liability—an approach consistent with avoiding treatment as a regulated securities or e-money offering under U.S. law—while carefully framing the relationship as access to a software service rather than participation in an issuer-backed financial product.

Functionally, USDai is positioned as a ā€œfully-backed synthetic dollarā€ designed for ā€œinstantā€ redemption at all times, while being deliberately distinguished from fiat-referenced stablecoins. Yield is not distributed at the USDai layer; rather, it is concentrated in a separate staked token, sUSDai. The public materials describe idle capital as being held in T-bills and lower-risk stablecoins, with sUSDai returns sourced from loans secured by tokenized hard assets used in AI/DePIN infrastructure. The off-chain collateralization and enforceability stack is framed under ā€œCALIBER,ā€ a UCC Article 7-style bailment and warehouse-receipt regime in which hardware is tokenized via NFTs (for example, negotiable warehouse-receipt tokens for GPUs) and structured to be bankruptcy-remote at the borrower level. Those CALIBER mechanics secure loans made to borrowers; they do not confer direct, off-chain property rights in such collateral on USDai or sUSDai holders.

Under the Terms, users are granted a limited, non-exclusive, non-transferable, and revocable license to access and use the Service. Access is conditioned on continued compliance and may be limited, suspended, or withdrawn by USD.AI in its discretion. No proprietary rights in the platform, its software, or its content are conveyed to users, and the Terms do not create any specific property interest or claim over particular assets, over USDai tokens themselves, or over any underlying reserve.

There is no clause granting users a contractual right, vis-Ć -vis the operator, to mint or redeem USDai on demand. The Terms are silent on hard reserve-maintenance obligations, on a binding 1:1 redemption covenant, and on any formal mechanism to convert USDai into fiat or other assets directly through the operator pursuant to an off-chain promise.

Likewise, the Terms contain no express representation that USDai will be maintained at a fixed U.S. dollar peg or that any particular reserve methodology will be upheld. While they acknowledge market volatility, potential protocol upgrades, and chain forks, they stop short of imposing an obligation to defend a peg or to provide specific reserves. As drafted, users have no operator-level right to redemption and no contractual claim against USD.AI or Permian Labs for delivery of fiat, collateral, or other backing assets.

In practice, USDai holders rely on in-protocol. These smart-contract mechanics reflect an on-chain claim to the protocol’s pooled stablecoin reserves, typically expressed as the ability to redeem USDai for approved deposit currencies via the contracts. That entitlement functions economically like a bearer-style redemption right within the code environment. The Terms of Service, however, do not create an additional, off-chain undertaking by the operator to redeem or to make holders whole outside the protocol.

By contrast, sUSDai holders obtain a smart-contract claim on the loan portfolio’s pooled economics and cash flows, subject to the defined unstaking period, the Queue Extractable Value (QEV) priority process, and the stated loss waterfall, which places borrower equity and first-loss curator capital ahead of stakers in absorbing losses. There is no direct, individualized property interest in collateralized GPUs or other hardware in favor of sUSDai holders; remedies on borrower default are pursued through the CALIBER framework and the designated underwriters or agents, not through direct enforcement actions by retail stakers.

CALIBER framework

As reflected in the privately shared document kit, CALIBER collateralization proceeds through a title-and-bailment sequence. An SPV LLC operating agreement establishes a Delaware single-purpose, bankruptcy-remote vehicle intended to hold title to the GPUs and interface with the USD.AI protocol. The borrower’s operating company effects a true sale of the GPUs to this SPV under a Sale and Contribution Agreement that expressly states absolute transfer intent, while installing a precautionary, first-priority UCC Article 9 security interest should any court recharacterize the conveyance as secured financing, coupled with segregation of collections into a designated account. This combination moves the assets off the operating company’s balance sheet and ring-fences them for financing within the SPV.

Once the SPV holds record title, the datacenter issues a negotiable Electronic Warehouse Receipt naming itself as bailee and acknowledging physical possession at the specified premises. The receipt designates the Arbitrum mint address as the authoritative copy and links ā€œcontrolā€ to UCC § 7-106, so that the on-chain controller is the ā€œBearerā€ entitled to demand delivery. The instrument also pre-wires the protocol’s enforcement pathway: a transfer executed via the USD.AI Vault Contract’s liquidate() function constitutes a transfer of the receipt, automatically vesting Bearer status in the transferee. New York law and forum are selected to govern the receipt, and the paper sets operational terms—fourteen-day delivery procedures, prohibitions on relocation absent Bearer consent, storage-charge mechanics, and a bailee warranty/liability cap—consistent with UCC Article 7 practice.

Under the Permian Customer Agreement, Permian mints the receipt-token, coordinates SPV formation and independent-manager onboarding, and supports deposit of the token into the USD.AI protocol to draw proceeds. Following funding, the SPV is obligated to make 30-day fixed payments plus variable components; it retains the right to reclaim the token upon payment in full of all accrued and unpaid amounts, but a missed installment opens a 30-day grace window, after which the token is liquidated under protocol rules and the reclamation right terminates. The protocol architecture is intended to prevent the token from leaving controlled custody except in two cases: (i) full payoff and return to the SPV, or (ii) liquidation transfer to the enforcement transferee.

The borrower’s obligations are split between financing covenants at the SPV level and duties under the warehouse bailment. On the financing side, the Customer Agreement requires a valid SPV organization, perfected transfer of title into the SPV, satisfactory warehousing that yields a tokenized document of title, completion of KYC, representations of good and unencumbered title (with a covenant to clear any liens from protocol proceeds), and indemnities favoring Permian and the independent manager. On the bailment side, the Bearer must pay storage and ancillary charges, maintain full-replacement-value insurance on a primary, non-contributory basis with a waiver of subrogation against the bailee, keep the goods at the contracted premises absent Bearer-approved relocation, and comply with the stated delivery procedure when demanding release.

Defaults and liquidations follow a mechanical, pre-agreed sequence. Failure to make a required 30-day payment triggers a 30-day grace period at an increased variable rate; failure to cure by its expiry authorizes liquidation ā€œaccording to the Protocol rules,ā€ permanently extinguishing the SPV’s right to reclaim. The liquidation call transfers on-chain control of the negotiable receipt; by the receipt’s express terms, the transferee becomes Bearer and may instruct the bailee to deliver the equipment or dispose of it for value. In effect, on-chain default logic is translated into an off-chain delivery entitlement under UCC Article 7 without a separate court process to perfect or foreclose.

Where the borrower is a non-U.S. entity, the structure remains viable provided two conflict-of-laws pivots are respected. First, the goods and the bailment relationship must be sited in the United States so the warehouse receipt sits squarely within UCC Article 7, ensuring New York law governs possession, negotiability, lien priority, and delivery rights against third parties. Second, the sale by the foreign seller into the Delaware SPV must constitute a ā€œtrue saleā€ both under U.S. bankruptcy jurisprudence (as reflected in the Sale & Contribution Agreement) and under the seller’s home property and insolvency law; in practice, that requires bailee attornment to the SPV and any local perfection or notice steps needed to resist claw-back by a foreign insolvency officeholder.

Two frictions in the current forms limit the degree of protection until they are completed:

  1. The warehouse receipt preserves the bailee’s statutory warehouse lien and authorizes a public sale after sixty days of non-payment; without a negotiated lien waiver or subordination in favor of the secured claim, together with lender’s loss-payable endorsements on the required insurance, that senior statutory lien can erode recoveries that would otherwise support the 1:1 collateralization story.
  2. The control before default is not yet fully specified. The receipt ties ā€œcontrolā€ to UCC § 7-106 and recognizes that liquidate() effects a transfer, but the papers do not appoint a collateral agent as the ā€œperson in controlā€ of the authoritative electronic copy while pledged, nor do they append a technical annex mapping the protocol’s control mechanics to § 7-106’s reliability criteria. A further purity concern arises if the datacenter functions as more than a storer: the receipt obliges the bailee to ā€œprovide access … for the use of the Property,ā€ and the LLC agreement contemplates separate ā€œUsage Agreements.ā€ The more the bailee or third parties ā€œuseā€ the equipment under warehouse paper, the greater the risk to a clean UCC Article 7 characterization. If operational use is contemplated, it should be housed in stand-alone use agreements with rent streams payable to the SPV. At the same time, the warehouse receipt remains a pure document of title and the bailee acts strictly as bailee. Until these completions are documented—and, ideally, supported by a focused legal opinion—the perfection and priority narrative rests more on design intent than on a fully tested control arrangement.

Legal Design Concerns

Based on the documents and architecture reviewed, our view is that several headline assertions are directionally credible yet legally under-specified. The materials at points conflate ā€œon-chain functionalityā€ with ā€œoff-chain enforceability,ā€ which are distinct questions and must be addressed separately. This gap gives rise to the legal concerns set out below.

  1. Positioning USDai and sUSDai as ā€œpermissionlessā€ and ā€œdecentralizedā€ does not resolve the threshold issues of legal characterization. A compliant posture requires a clear statement of what each instrument is as a matter of law, which body of law governs holder rights and remedies, and where—if anywhere—off-chain obligations are undertaken by an identifiable legal person. The absence of a reasoned U.S. securities/commodities and money-transmission analysis for USDai and sUSDai leaves regulatory risk unmitigated.
  2. The lack of targeted legal opinions on the CALIBER construct is understandable for a nascent deployment, but leaves material risks unaddressed. For a structure that explicitly relies on UCC negotiability and an authoritative electronic copy, market practice is to obtain a relevant opinion. Without such, the distinction between commercial appetite and legal resilience remains unproven.
  3. Dependence on wM (M0) for undeployed capital introduces a second-order legal and operational dependency that requires explicit, granular disclosure. If wM evidences claims on T-bill custodial arrangements administered by third parties, reserve quality and liquidity for USDai are partly a function of M0’s governance, custody chain, licensing posture, gate/notice mechanics, and redemption terms. That dependency is not disqualifying, but it is a look-through risk that must be surfaced with precision in the Terms, user disclosures, etc. As of this review, the level of transparency regarding wM reliance is insufficient to substantiate the backing claim.

In conclusion, while we recognize the coherence and ambition of the legal architecture, its novelty and limited practical provenance (absence of tested outcomes or maturity), together with the deficiencies identified above, prevent us from endorsing onboarding at this time from a legal-risk perspective.

4.2 Access Control Risk

4.2.1 Contract Modification Options

The controlling wallets for USD.AI:

  • 2/3 Multisig A: Default Admin

USDai and sUSDai are deployed behind ERC1967 Proxies that utilize a role-based access control system.

USDai roles:

  • DEFAULT_ADMIN_ROLE: ability to grant/revoke all other roles, can adjust the total supply cap, and call other role functions.
  • BRIDGE_ADMIN_ROLE: manages mint/burn bridging operations
  • DEPOSIT_ADMIN_ROLE: privileges for deposit operations

sUSDai roles:

  • DEFAULT_ADMIN_ROLE: ability to grant/revoke all other roles, call all role-protected functions, and control redemption timelock period.
  • BLACKLIST_ADMIN_ROLE: blacklist/whitelist privileges
  • STRATEGY_ADMIN_ROLE: manages redemption queue, and manages BasePositionManager and PoolPositionManager contracts
  • PAUSE_ADMIN_ROLE: pause/unpause sUSDai contract
  • BRIDGE_ADMIN_ROLE: mint/burn controls associated with the bridging process

Key contracts to USDai’s functionality

  • USDai: ERC20
  • SwapAdapter: swaps between whitelisted tokens (USDC & USDT) and $M tokens, using Uniswap pools. Managed by DEFAULT_ADMIN_ROLE.

Key contracts to sUSDai’s functionality

  • sUSDai: ERC20
  • BasePositionManager: harvests M emissions from the USDai contract.
  • PoolPositionManager: manages Metastreet lending pool liquidity.
  • PriceOracle: Chainlink price feed used to convert lending pool value denominated in USDC and USDT into USDai for NAV calculations (using the USDC / USD and USDT / USD price feeds). The DEFAULT_ADMIN_ROLE can add/remove price feeds.

USDai and sUSDai OAdapters are owned by Multisig A. The adapter manages token transfer limits between chains.

Key Metastreet contracts:

4.2.2 Timelock Duration and Function

No timelock has been implemented for either USDai or sUSDai, indicating that admin changes and upgrades may be implemented without giving holders sufficient time to opt-out.

4.2.3 Multisig Threshold / Signer identity

Multisig A 2/3
0xe982B3F68981eFEA221F5B4F843757dEd2c0a69C

0x986868c921075f31514015E6ecdbB4A6526579b2

0xD1Affe275f09cD11bfDf38F3c9b85c016F47b75e

Contrasting GPU Outlook

GPU Lifespan and Market Value Concerns

GPUs used in AI experience high utilization, running under heavy computational loads and prolonged thermal stress. As a result of wear and tear, their performance and economic value decline over time. USD.AI cites an average lifespan of 5–7 years for top-tier GPUs. Other sources indicate that most datacenter GPUs have shorter lifespans, ranging from 1-3 years for peak performance and 3-5 years with lower utilization rates, before units are either used for less intensive work or replaced.

These alternative estimates indicate that the peak performance years for GPUs under high utilization are likely within the first 3 years. This would mean that USD.AI’s 3-year loan amortization schedule coincides with the optimal period for AI GPU performance and likely the steepest value declines during this period (i.e., a narrower margin of safety than proposed).

Other AI sector factors, such as the price impact that new models have on older models, should also be factored in. GPU performance and efficiency improvements have historically doubled approximately every 2.6 years, and compute usage in AI has doubled approximately every 6 months. AI GPUs face accelerated rates of obsolescence as benchmarks improve. This necessitates the replacement of legacy systems at a faster rate for businesses in this sector to remain competitive.

These considerations offer a dampened outlook on the secondary market demand and value of AI GPUs. In the event of a loan default, collateral may be sold at a lower market value relative to the expected value reported by USD.AI.

Aave V3 Specific Parameters

N/A

Price feed Recommendation

N/A

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.

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