Original Article Title: "Ye Kai: Rethinking Asset Liquidity — How RWA Reshapes Data Asset Management Models | China Data Asset Management 50+ Forum"

Original Source: Shanghai Data Exchange

1. High RWA Financing Cost in Hong Kong

The current RWA market in Hong Kong faces high financing costs. From a cost perspective, the financing cost for high-quality domestic enterprises through bank channels generally remains in the range of 3.5%-4%, while the comprehensive cost of issuing RWAs in Hong Kong (including HKD 4-5 million issuance expenses) is as high as 10%, showing a clear cost inversion phenomenon. In this context, the core appeal for listed companies to participate in RWA has shifted from simple financing to market value management. A typical case shows that a technology company, after issuing RWA, saw its market value climb from HKD 6.7 billion to HKD 14.6 billion within three to four months.

The transitional nature of the Hong Kong regulatory framework is particularly prominent. According to current regulations, debt-based RWAs are limited to professional investors (PIs) participation, and licensed trading platforms cannot open a secondary retail market. This restriction objectively drives the market to form a "securitization-first, tokenization-follow-up" Web2.5 model: companies need to first transform assets into fund products regulated by a Type 9 license before undergoing tokenization by licensed institutions. Although liquidity is constrained in the short term, it creates an opportunity to build a multi-level cross-border market system.

2. Multi-level Market Collaborative Architecture

The key to unlocking the liquidity dilemma in the Hong Kong market lies in establishing a cross-border collaborative mechanism, such as establishing a three-layer experimental architecture for Mainland China-Hong Kong-Singapore.

· The first layer is the onshore ownership layer, where data asset trading platforms in Mainland China conduct data asset standardization processing, prepare assets through a sandbox mechanism, and ensure onshore ownership of core data, among other operations.

· The second layer is the offshore issuance layer, where Hong Kong licensed institutions package processed data assets into compliant fund products and conduct private placements based on a Type 9 license.

· The third layer is the global circulation layer, where Singapore leverages the advantage of an RMO license to accommodate secondary market circulation, achieving compliant cross-border circulation through the China-Singapore international data channel.

The innovative value of this architecture lies in three dimensions: first, the onshore link strictly observes data security bottom line to avoid risks of Regulation 38; second, Hong Kong leverages the professional advantages of licensed institutions, focusing on primary market issuance; third, Singapore opens the secondary retail market, activating global capital participation.

3. Structured Financial Design Thinking

Mere asset tokenization cannot form effective financial products; instead, structured financial product design is needed. Taking BlackRock's fund operation model as an example, BlackRock combines mid-term US Treasury ETFs with smart contract collateralization to ensure a base return of 6-8% while unlocking premium floating space through native token issuance. This model has successfully attracted over 30% of crypto-native capital allocation demand.

Offshore support system is equally important. For example, in the Hainan Free Trade Port, the VIE structure + FT account combination can be tested to achieve cross-border asset transfer and fund circulation in a physically isolated framework. The "regulatory sandbox + whitelist network" design provides a solution for the circulation of sensitive assets. This model uses the VIE structure to achieve the outbound transfer of asset ownership in a legal sense, utilizes the FT account system to build a firewall for fund flow, and establishes a dedicated network channel to overcome cross-border operational barriers.

IV. Wall Street Stair-step Penetration Strategy

BlackRock's stair-step penetration strategy is worthy of special attention. From a Bitcoin spot ETF (with over $30 billion in AUM) to tokenized money market funds (BUIDL Fund surpassing $1 billion in scale), and then collaborating with Circle to issue the stablecoin USDB, its development path demonstrates a seamless transition from the institutional market to the retail market. Even more disruptive is the institution's plan to transform $11.6 trillion in medium to long-term assets into on-chain liquidity through collateralization, potentially reshaping the global fund circulation paradigm.

A Distributed Digital Identity (DID) system constitutes a strategic fulcrum. BlackRock explicitly positions DID as the infrastructure for inclusive finance in public documents, attempting to break down barriers between institutional and retail markets through a verifiable credit system. The insight for Hong Kong is that RWA development should not be limited to the professional investor market but should encompass forward-looking initiatives such as digital identity authentication and on-chain settlement capabilities.

V. Development Assessment and Path Selection

The Hong Kong RWA ecosystem is currently in a phase where regulatory arbitrage opportunities overlap with the key period of model standardization. The breakthrough direction presents three major trends: first, optimizing market structure to consolidate Hong Kong's position in the primary issuance market and complementing Singapore's secondary market. Second, upgrading product capabilities from simple asset securitization to structured designs such as ABS tranching and revenue rights passthrough. Third, prioritizing digital infrastructure development, accelerating the construction of DID systems, smart contract clearing platforms, and other foundational infrastructure.

For domestic businesses, the priorities are firstly to innovate development models by establishing a standardized process for "domestic asset preparation - offshore financial issuance," secondly to cultivate cross-border structured product design capabilities to gain a competitive advantage, and thirdly to focus on stablecoin and collateral derivative innovation to prevent overseas liquidity suction effects.

Original Article Link

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