In-Depth: Latest Asset Risk Assessment Analysis of Stablecoin TrueUSD (TUSD)

Author of the article: LLAMARISK
Article compilation: Block unicorn
 Relationship with Curve
TrueUSD (TUSD) plays an important role in crvUSD as one of the Pegkeeper pools (crvUSD/TUSD), along with USDC, USDT and USDP. Pegkeepers algorithmically control crvUSD to reach a peg of $1 by minting or burning crvUSD tokens based on market conditions, essentially backing the outstanding crvUSD supply with a portion of their Pegkeeper pairing.
Pegkeeper enforces balance in each Pegkeeper pool, so if the peg value of a Pegkeeper asset falls below $1, it will cause too much crvUSD to enter circulation, causing crvUSD to unpeg. Curve intends to launch an improved version of Pegkeeper that will check a token’s price against other tokens. This will provide better protection by preventing crvUSD deposits from entering the unanchored Pegkeeper pool. Currently, crvUSD’s stability depends on strong confidence that its Pegkeeper pairing is solid and that the stablecoin is low-risk.
There are some criticisms regarding TUSD’s transparency policy in the context of Pegkeeper as crvUSD’s asset, which are worth highlighting. TUSD’s transparency falls short in many areas, including custody partners, reserve management, validation, on-chain operations, and ownership structure. This report will cover the most concerning issues surrounding the status of the TUSD reserve and should provide DAO voters with information to determine whether action is needed to limit crvUSD’s exposure to TUSD.
 Introduction to TUSD
Issuer and Custodian
At a high level, TUSD is a custodial stablecoin backed by fiat currency. TUSD is designed to maintain a 1:1 peg to the U.S. dollar, providing stability in the volatile crypto market. The original issuer of TUSD was TrueCoin, LLC (a subsidiary of Archblock, Inc.), but ownership was transferred to Techteryx on December 15, 2020.
According to a TUSD representative, Techteryx is described as an Asian head office with operations in Hong Kong, Singapore, Guangzhou, Shenzhen, Beijing and other places, involving traditional real estate, entertainment, environment and information technology industries.
However, rather than billing itself as an Asian parent company, Techteryx Ltd. appears on the BVI (British Virgin Islands) Financial Services Commission's registration list. There is little public information about Techteryx, fueling speculation about the ultimate beneficial ownership of its subsidiaries and TUSD.
As of July 13, 2023, Techteryx has assumed full management of all offshore operations and services related to TUSD, including minting, redemptions, customer registration, compliance and oversight of banking and fiduciary relationships.
TUSD has three custody partners, which are described in the audit report as the Hong Kong Depository, the Swiss Depository, and the Bahamas Depository (the audit report can be downloaded from tusd.io).
The reserve mix is ​​not disclosed specifically but is described as: U.S. dollar cash, cash equivalents and short-term, highly liquid investments of sufficient credit quality that can be readily converted into known amounts of cash. The Hong Kong Depository also invests in other instruments to generate income and, in each case, cash equivalents and recorded costs of the other instruments.
TUSD’s primary source of revenue is the interest earned on fiat reserves held as collateral. Revenue generated from these activities helps cover the operating costs of maintaining stablecoin infrastructure, the cost of complying with regulations, and supporting the growth and development of TUSD. develop.
 Minting/Redemption Process
The system architecture of TUSD is as follows:
Users wishing to mint TUSD must have an account at https://tusd.io/ and undergo KYC/AML checks. Users then wire USD to a designated bank account managed by a fiduciary partner. Techteryx emphasizes that fund management is entirely done by its custodian and the issuer never has the authority to handle user funds.
TUSD provides real-time access through cooperation with The Network Firm LLP and Chainlink Proof of Reserve (PoR). TUSD can only be minted when the total TUSD supply + newly minted TUSD is less than Chainlink’s reported reserves (provided by The Network Firm). Deposits confirmed by minting checks are then tokenized and the corresponding amount of TUSD is issued to the receiving wallet specified by the user.
Instead, when a user wishes to exchange their TUSD for USD, they first initiate the redemption process with the stablecoin issuer by passing KYC/AML checks and specifying their Ethereum and bank wire addresses. TUSD tokens are destroyed by sending them to the TUSD smart contract, and the corresponding amount of USD is transferred back to the user's bank account.
 March 2023, TUSD expansion
Until March 2023, TUSD was a smaller stablecoin with limited trading activity, accounting for less than 1% of the overall stablecoin market share. However, Binance decided to make TUSD the successor to BUSD and subsequently promoted the BTC-TUSD trading pair with zero trading fees, which significantly increased its visibility and trading volume, and its market share increased in just a few months It quickly expanded from less than 1% to 19%.
Suddenly, two large transactions worth US$1 billion each appeared, both coming from the same address and sent directly to the Binance exchange. These events occurred on March 12 and June 16 respectively (data dates in the picture below: June 27).
TUSD’s meteoric rise may be related to Binance’s zero-fee trading promotion and general promotion of TUSD on the exchange, which Binance announced on June 21. Observers may also note that TUSD’s unusual growth trend coincides with the period before its Prime Trust custody partner shut down in mid-June.
Binance switched to supporting the TUSD stablecoin after the New York Department of Financial Services (NYDFS) ordered BUSD issuer Paxos to stop issuing its BUSD stablecoin. This is because Paxos’ regulatory issues regarding BUSD issued by Binance have not yet been resolved. Binance’s move appears to be an attempt to maintain market share in the stablecoin space and reduce reliance on a single stablecoin. The move to promote TUSD resulted in Binance becoming the largest holder of TUSD. It’s worth noting that most of TUSD’s trading volume is currently concentrated in Binance’s BTC-TUSD trading pair.
 Token distribution
According to data from Nansen on July 19, the vast majority of TUSD’s supply is stored on centralized exchanges (CEX), with 94% of the token supply associated with CEX addresses. As shown below, the vast majority of TUSD is actually held on Binance.
As of writing, the vast majority of TUSD’s token supply is held in TRON (73.56%), worth approximately $2.035 billion. TUSD’s official website promotes its use on TRON, Ethereum, Avalanche, Binance BNB Beacon Chain (BNB), and Binance BNB Smart Chain (BSC), and it compiles the token supply on these chains into its certification report (The picture below is from DeFiLlama data on July 19).
 Distribution – TUSD on TRON
On TRON, the vast majority of TUSD is held by Binance (94.7%), with a small amount deposited on DeFi lending platforms JustLend (3.5%) and Gate.io (1.2%).
 Distribution - TUSD on Ethereum
On Ethereum, the distribution of TUSD token holders is heavily biased towards Binance, which holds 83.53% of the total tokens. Curve, OKX, and Aave have smaller shares of 1.12%, 0.73%, and 0.60% respectively. Curve’s crvUSD/TUSD Pegkeeper pool contains the largest number of TUSD tokens of any contract on Ethereum.
 crvUSD Pegkeeper and decoupling risks
1.TUSD/crvUSD pool contract
2.TUSD Pegkeeper Contract
3. AggregatorStablePrice contract
Pegkeeper stabilizes the anchoring of crvUSD by algorithmically supplying and withdrawing crvUSD from the designated Pegkeeper pool. There are currently four pools, namely crvUSD/USDT, crvUSD/USDC, crvUSD/USDP and crvUSD/TUSD. Each Pegkeeper is assigned a maximum debt that can be supplied to its corresponding pool. Currently, the maximum debt per Pegkeeper is 25 million crvUSD, and the maximum total debt of Pegkeeper is 100 million crvUSD.
The AggregatorStablePrice contract is critical to Pegkeeper as it aggregates the price of crvUSD from at least three price sources (currently four Pegkeeper pools). Pegkeeper will only supply crvUSD if the crvUSD price quoted by Aggregator is greater than $1.
Taking TUSD as an example, the following conditions must be met for Pegkeepers to supply crvUSD:
More than 15 minutes have passed since the last update.
The TUSD balance in the pool is greater than the crvUSD balance.
The crvUSD price quoted by the aggregator is greater than $1.
If the conditions are met, supply an amount of crvUSD equal to 1/5 of the balance difference.
The chart below shows crvUSD supply by source over time. The blue bar represents crvUSD supplied by Pegkeepers, which reached a peak of 40.6 million crvUSD in mid-August (utilization rate 40.6%). The recent rise in Pegkeeper utilization coincides with a sharp decline in the cryptocurrency market, driving up demand for crvUSD. As of August 18, the total crvUSD supply was 125.5 million, with 85 million borrowed from collateral. This equates to 32.27% of crvUSD supplied by Pegkeepers and 67.73% lent from collateral.
Any Pegkeeper asset (such as TUSD) losing its anchor, whether permanently or for an extended period of time, will have undesirable consequences. Because the aggregator checks the pool balance to determine the crvUSD price, it may mistakenly set the crvUSD quote to >$1 when the Pegkeeper asset is unpegged. This will allow Pegkeeper to supply crvUSD to the pool up to its maximum debt amount. The chart below shows a simulation of how quickly Pegkeeper might supply crvUSD under different unanchoring severities:
These were collected by simulating a loss of anchor in Brownie during the August 8th pool state. Regardless of the degree of anchor loss, nearly all available Pegkeeper debt is introduced during a anchor loss event lasting 4-5 hours.
It is important to note that this data is in isolation and in reality would cause liquidity providers of other crvUSD pools to reduce their crvUSD exposure, resulting in a loss of peg proportional to the amount of unsupported crvUSD entering circulation. Losing the anchor will reduce the price quoted by AggregatorStablePrice, limit additional Pegkeeper crvUSD from entering circulation, and enable the DAO to take mitigation measures. The crvUSD provided by the Pegkeeper pool that loses the anchor will become bad debt on the protocol (assuming the loss of anchor is permanent) .
crvUSD depends not only on its Pegkeeper pool to maintain stability, but also on them to ensure crvUSD’s continued solvency. Therefore, it is crucial to evaluate the protocol’s exposure to potential Pegkeeper debt (i.e., maximum debt) in proportion to the total crvUSD supply, and to consider the peg confidence of each Pegkeeper asset.
Criticisms of TUSD transparency issues:
1. Opaque Reserve Management: TUSD provides significantly less transparency than its competitors regarding its custody partners and reserve portfolio.
2. Opaque verification: TUSD provides relatively few details in its certification documents, which calls into question the effectiveness of its reserve certification system and may give users a false sense of security.
Criticism 1: Opaque reserve management
Obfuscation of Reserve Accounts
TUSD's supporting documents do not specifically mention the name of its reserve account, but generally describe that its reserves are held at a Hong Kong reserve institution (previously disclosed as First Digital Trust), a Bahamas reserve institution (previously disclosed as Capital Union Bank) and a Swiss Reserve.
The escrow account structure has become more ambiguous as significant portions of TUSD reserves have been transferred to offshore entities. TokenInsight reported on March 16, 2023 that TrueUSD’s previous operator Archblock had transferred $1 billion of the token’s reserves to Capital Union Bank in the Bahamas due to worsening banking conditions for U.S. crypto businesses. Capital Union Bank, located in Lyford Cay, Nassau, is an independent banking institution that provides private banking services and is regulated by the Central Bank of The Bahamas and the Securities Commission.
Additionally, a recently added note in supporting documents indicates that Techteryx opened a corporate account with a Swiss reserve institution on April 21. The supporting documentation disclosed that the terms of the account did not explicitly provide important protections for TUSD holders, namely:
Funds in the account are held in trust on behalf of TUSD token holders.
The agent does not have access to the funds in the account at any time.
Any amounts deposited into the Account do not become the property of Techteryx, its agents or any other entity.
Any amounts deposited into this account will not be subject to any debt, lien or encumbrance of Techteryx, its agents or any other entity.
An excerpt from the proof is as follows:
The recent addition of this account further highlights the issue of reserves held by Techeryx partners and the lack of clarity between issuer and user funds. Such a setup could easily lead to the commingling of customer deposits or misuse of corporate account funds.
To the extent that assets are held with unnamed custodians, the portfolio supporting TUSD is disclosed in general terms as consisting of: U.S. dollar cash, cash equivalents, and highly liquid, short-term, investments of sufficient credit quality to be readily redeemable For known amounts of cash, the Hong Kong custodian also invests in other instruments to generate income.
There is no further detail regarding the portfolio asset balances or amounts held with each custodian, beyond this general description. The Hong Kong account used the vague phrase "other tools." The risk nature of the assets in this account is not clearly marked, and because the accounting statements used for the vouchers are disclosed at "cost," the investments may have experienced considerable depreciation that is not reflected in the vouchers. come out.
Readers are advised to compare TUSD’s credentials (available on TUSD’s website) with the latest credentials of major competitors USDC (June 2023), USDT (June 2023), and USDP (June 2023). In contrast, these issuers disclose more information about their custodians and reserve asset portfolios.
 Market panic in June 2023: Prime Trust collapses
Prime Trust is a Nevada-chartered trust company that provides B2B custody, custody, compliance, statutory processing, trading software and other financial services. TUSD has had an ongoing relationship with Prime Trust since August 2019, when the partnership agreement was first announced. It utilizes Prime Trust for 24/7 fiat currency transfers for its stablecoin products, including TrueUSD (TUSD), TrueGBP (TGBP), TrueAUD (TAUD), and TrueCAD (TCAD).
On June 21, 2023, the Financial Institutions Division (FID) of the Nevada Department of Industry and Commerce ordered Prime Trust to cease all activities because it was found to have violated state regulations. The company's financial condition was found to be extremely deficient, resulting in its inability to honor customer withdrawals and protect the assets held in its custody.
In 2020, problems with an upgrade to its wallet management system apparently led to a discovery in December 2021 that Prime Trust had rendered funds in its legacy wallet inaccessible. Prime Trust allegedly began using other users’ deposits to purchase cryptocurrency to satisfy withdrawal requests. The Nevada Department of Financial Institutions found that the custodian owed customers $85 million in fiat currency and had only $3 million on hand. It claims Prime Trust has negative shareholder equity of $12 million and has become de facto insolvent.
TUSD exposed to Prime Trust risk
Before Nevada’s financial regulator issued a shutdown order, rumors circulated about TUSD’s insolvency. TUSD announced on June 9 that minting through Prime Trust will be suspended until further notice (other minting/redemption services are still available). The news triggered a relatively brief market panic.
Subsequently, TUSD sharply detached from its peg on Binance US, falling to lows of $0.80. It is worth noting that this is not a market-wide de-anchoring event. Binance US’s battle with the U.S. Securities and Exchange Commission, troubles finding a banking partner, and its own risks from Prime Trust have put the exchange’s reliable deposits and withdrawals at risk.
TUSD initially announced on June 22 that they did not have any exposure to Prime Trust following the issuance of the cease-and-desist order. But in the June 28 TUSD funding report, it appears that $26,000 of TUSD exposure appeared. Although this amount was insignificant, users at the time reported being unable to mint/redeem TUSD, which continued to cause panic in the market as market participants remained wary of the potential for additional undisclosed exposure.
According to a TUSD representative, the $26,000 came from random users’ funds in Prime Trust, and auditors included it on TUSD’s balance sheet, emphasizing that the amount was actually unrelated to TUSD.
Redemption failure report
Around the time of the Prime Trust issues in mid-June, reports began to come out claiming that multiple users seemed unable to cash out their TUSD and instead had their TUSD returned to their wallets. This is contrary to TUSD’s announcement on June 9, which claimed that although minting through Prime Trust was suspended, all other custody partners were intact and there was no interruption in minting or redemption services.
Prime Trust was shut down on June 21, coinciding with reports of redemption issues. Blockchain analytics firm @Chainargos and @willmorriss4, who claims to be a former TUSD employee, provided on-chain transaction records of failed redemption attempts between June 10 and June 23:
Representatives from TUSD responded that these transactions were transactions that users were trying to send to Prime Trust, even though they had publicly announced that minting/redemption through Prime Trust had been suspended. They further emphasized that anyone can still redeem TUSD through other custody partners 24/7 without restrictions.
Criticism 2: Opaque verification
LedgerLens System
Real-time confirmation is provided by The Network Firm LLP through their LedgerLens system providing real-time reserve data. The service performs daily queries on the total supply of TUSD across all chains (ETH, AVAX, BNB, TRON, BSC), as well as the total account balances of Techteryx’s custody partners across multiple depositories, as shown below, from Confirmation report on July 28:
Ripcord is an alerting system embedded in the validation service that is used to define blocking conditions for automatic validation updates. They are used for instrumentation systems because sometimes the external API used for validation may be unavailable due to maintenance, outage, or inaccuracy.
There are four types of Ripcord (emphasis on the "balance" Ripcord):
1. Management: During the previous reporting interval, management made unacknowledged statements, statements, or unacknowledged terms of the participation agreement.
2. Integration: During the last reporting interval, the smart contract call returned an error, and excluding this error triggers the balance Ripcord (see below).
3. Pricing: Confirmation is irrelevant for stablecoins. Indicates an API error or unresponsiveness when applying a USD (or other fiat-denominated) value from a pricing source to a collateral asset.
4. Balance: During the previous reporting interval, responses, errors or non-responsiveness from third-party systems or accounts resulted in total liabilities being greater than total assets. This may be a temporary imbalance due to normal operations, such as a customer opening a bank account that has not yet been integrated, or it may be due to an actual liability and asset imbalance.
As the situation with Prime Trust gradually emerged, the "Management" Ripcord was triggered on June 13th, followed by the "Balance" Ripcord on June 20th. TrueUSD clarified on June 22 that the trigger was caused by a delay in the API interface of the new banking partner (presumably an unnamed "Swiss depositary"), and that by that time, confirmations had returned to normal. . A TUSD representative also mentioned that they are the only stablecoin with real-time confirmations and that the bank’s API cannot reflect amounts in real time.
Previous criticism in March 2023 noted that confirmations for other stablecoin products, including TrueAUD, TrueHKD, TrueCAD, and TrueGBP, had become increasingly outdated, raising concerns about transparency. At the time of writing, confirmations for these stablecoins were last updated on June 22, and the “managed” Ripcord is currently triggered.
Chainlink PoR Integration Introduction
TrueUSD uses Chainlink’s Proof of Reserve (PoR) technology to increase the transparency and reliability of TUSD by regularly verifying the full collateralization of the stablecoin.
As shown in the diagram above, the minting and redemption process depends on available reserves and involves the following steps:
1. The Network Firm, an independent accounting firm, uses its LedgerLens attestation service to request U.S. dollar reserve data from TUSD’s custodian bank account.
2. Obtain the USD reserve balance in the escrow bank account.
3. The decentralized oracle network Chainlink queries The Network Firm’s API off-chain.
4. Chainlink retrieves the USD reserve balance reported by The Network Firm API.
5. If there is a deviation in the account balance, execute an on-chain transaction to update the TUSD Proof of Reserve contract.
6. The TUSD token contract independently verifies reserves when needed.
7. Availability of TUSD mints depends on reserves compared to TUSD supply:
If the TUSD supply exceeds available reserves, minting of new TUSD tokens will stop to ensure the stablecoin remains fully collateralized.
If the TUSD supply is less than or equal to the reserve, minting of TUSD tokens will be allowed, up to a maximum of unutilized reserves, maintaining the appropriate collateral ratio.
As shown below, TUSD's _mint function checks whether the reserve value passed in from chainReserveFeed is sufficient before allowing TUSD to be minted:
The integration with Chainlink claims to provide users with accurate and transparent information about the reserves backing TUSD, making it a more reliable method of staking and payments in the DeFi space.
Stablecoin verification: Insufficient information
There is limited transparency in TUSD’s The Network Firm’s reserve reporting provided via Chainlink’s PoR, with no specific details revealed, such as:
The full extent of the company's liabilities
bank relationship
Portfolio composition
Market value of reserves (reserves are calculated at "cost")
This makes it difficult for users to fully assess the stability and legality of reserves.
The purpose of stablecoin verification is to prove that the entire stablecoin supply is fully redeemable. Proof of solvency can be achieved by ensuring that reserves and liabilities are fully accounted for.
Proof of solvency = Proof of reserves + Proof of liabilities
Although most TUSD liabilities can be found on-chain (i.e., issued TUSD), there may be significant off-chain liabilities. Audit providers of stablecoins, including The Network Firm (TNF), often provide snapshots of reserves that do not capture the full extent of a company’s liabilities. Hidden or undisclosed liabilities may impact the availability and backing of a stablecoin, making definitive proof of solvency more complex.
As mentioned earlier, the depositories controlling TUSD reserves were described in the audit only as the Hong Kong Depository, the Bahamas Depository, and the Swiss Depository. The investment portfolio backing TUSD is similarly vague, disclosing only that it contains U.S. dollar cash, cash equivalents and short-term, highly liquid investments with sufficient credit quality to be easily converted into known amounts of cash (the Hong Kong depository also invests in other generating income tools).
The Network Firm LLP’s Trust Assumptions
According to the disclosure of TUSD in the Chainlink PoR data source, the audit data relied entirely on The Network Firm LLP. The auditor’s credibility and independence have been called into question, especially given The Network Firm’s ties to Armanino, who has come under scrutiny for his former business relationship with FTX US.
The Network Firm responded to questions about its association with Armanino, calling it an "accidental or intentional misrepresentation" and emphasizing that The Network Firm is an independent accounting firm specializing in the field of digital assets and is distinct from Armanino. . Many current team members are founding members of Armanino’s Digital Asset Industry Practice. Following the failure and controversy of FTX, Armanino decided to reduce audit services in the digital asset space. The Network Firm LLP was formed in October 2022 with no equity stake in Armanino and only one founding member who worked on FTX US’s 2021 financial statement audit.
A representative of TUSD responded that the premise of treating this association as malicious communication (FUD) is untenable because Armanino has a business relationship with FTX US, but the latter did not lose customer funds. Armanino is also an auditor for large crypto platforms such as Kraken. Armanino remains confident in the results of its partnership with FTX US, and aside from adverse media reports related to this association, there is no evidence that Armanino or The Network Firm failed to meet their responsibilities or committed any wrongdoing.
A final note on PoR While verification of stablecoins is far from perfect and requires trusting auditors and stablecoin issuers to provide correct data and run their businesses responsibly, they are positive steps towards promoting transparency and accountability. By voluntarily conducting and publishing verifications, TUSD demonstrates an effort to build trust between users and regulators, and it demonstrates a commitment to financial transparency and responsible practices.
On the other hand, some key information has not been made public, involving custody partners and relative risk exposures with each institution, the asset portfolio supporting TUSD, and the company's liabilities, which may affect TUSD's support. Users need to understand the trust assumptions involved when this information is not public, especially being aware of the limited use of proof-of-reserve systems like Chainlink PoR when much of the information remains public.
 Risk advice
TUSD has made significant efforts to build trust in solvency through real-time verification and proof of on-chain reserves. It features as the first U.S. dollar-backed stablecoin with minting limits programmed into off-chain reserves.
However, there are legitimate criticisms that Techteryx’s transparency policy is insufficient, as the issuer provides no reasonable guarantees regarding the solvency of the stablecoin. Compared with its competitors, TUSD provides little information on the status of its reserves. It does not disclose the name of the custodian, the balances of each custodian, or the details of the portfolio. TUSD is currently the only Pegkeeper that does not disclose such information (compare to recent verifications of USDC, USDT and USDP).
The current Pegkeeper model may cause crvUSD to become unanchored or the protocol to accumulate bad debt in the event that Pegkeeper assets become unanchored. Given the importance of Pegkeepers to crvUSD stability, these assets must be specially scrutinized and minimum requirements set. Generally speaking, Pegkeeper candidates need to meet the following criteria:
1. Confidence in anchoring at the technical, operational and regulatory levels is strong enough;
2. Candidates should complement the Pegkeeper asset basket by bringing in diversity of issuers, custodians, and geographic jurisdictions.
To achieve this, candidates should be convertible stablecoins, have efficient arbitrage paths, and should be compliant with regulations in the jurisdictions in which they operate. Overall, the Pegkeeper asset basket should not be concentrated in any single jurisdiction, nor should it be concentrated in white label products with the same issuer and/or custodian (such as Paxos USDP and PYUSD).
We believe that TUSD should not be included in crvUSD Pegkeepers until the crvUSD Pegkeepers are upgraded and precautions are taken to mitigate the negative impact of unanchored Pegkeeper assets. Our reasoning is that given Techteryx’s current transparency policy, we cannot feel confident in TUSD’s solvency or its anchor. Reducing the maximum debt of TUSD as a Pegkeeper to zero will not have a huge impact on the overall situation (meaning that even if TUSD cannot continue to act as a Pegkeeper, there are other Pegkeepers that can continue to function and remain stable), because there are other 3 Pegkeepers, with a total maximum debt of $75 million. Since May, crvUSD’s largest Pegkeeper debt utilization in history was $40.6 million (on August 18).
One argument for lowering the maximum debt, rather than lowering it to zero, might be to ensure geographic diversity of Pegkeepers. Increasing the proportion of Pegkeeper assets established in the United States may increase risks associated with U.S. stablecoin regulation. If the DAO agrees with this reasoning, it is recommended to set the maximum debt of TUSD Pegkeeper to a conservative value, such as $5 million.