WASHINGTON — The Defense Credit Union Council (DCUC) is urging the Senate Banking Committee to revise digital asset legislation to ensure credit unions receive equal authority with banks and additional protections for military members before the measure advances.
In comments submitted to the Senate Committee on Banking, Housing, and Urban Affairs, DCUC said it supports H.R. 3633, the Digital Asset Market Clarity Act, and the Senate substitute amendment (EHF26374), while recommending several changes to strengthen the legislation. The association, which represents credit unions serving military and veteran communities, said its recommendations are intended to provide regulatory parity for credit unions and enhance consumer protections, according to DCUC.
“Financial readiness is inseparable from mission readiness,” DCUC President and CEO Anthony Hernandez, a retired U.S. Air Force colonel, said in a statement. “Service members and defense personnel are frequently targeted by digital-asset scams and aggressive offshore platforms. A safe, clear, and technology-neutral federal framework allows trusted credit unions to pair responsible innovation with robust fraud intervention and human support.”
Praise for Section 401
DCUC praised Section 401 of the Senate substitute, which would authorize federally and state-chartered credit unions to use digital assets and distributed ledger technology for permissible financial services, including custody, payments, lending facilitation and operating blockchain network nodes.
However, the association said lawmakers should make several changes before giving the bill final approval.
Among its recommendations, DCUC called for preserving Section 401 as a technology-neutral provision that explicitly allows credit unions to engage in authorized digital asset activities without requiring separate bank or broker-dealer charters. The group also asked Congress to extend the authority to credit union service organizations (CUSOs), subsidiaries and shared-service providers, arguing that many smaller credit unions depend on cooperative networks to deliver new services.
DCUC also urged lawmakers to ensure regulatory parity by requiring the National Credit Union Administration and state credit union regulators to participate in joint rulemakings and supervisory efforts alongside the Federal Reserve, Office of the Comptroller of the Currency and Federal Deposit Insurance Corp.
Additional Recommendations
Additional recommendations included
- Tightening restrictions on payment stablecoin interest to prevent platforms from disguising investment returns as rewards
- Protecting traditional credit union share accounts from synthetic deposit substitutes
- Ensuring military personnel, civilian defense employees and their dependents stationed overseas continue to qualify as U.S. persons under federal stablecoin protections.
- A call for clearer rules governing custody of digital assets, capital treatment and insolvency, saying member-owned digital assets held in custody should remain customer property, be excluded from credit union capital calculations and receive protection under NCUA liquidation rules.
- Extending the implementation timeline from 60 days after final rulemaking to 18 to 24 months, and ensuring credit unions have equal access to digital settlement infrastructure, innovation pilot programs and representation on a proposed Joint Advisory Committee on Digital Assets.
Not Seeking Preferential Treatment
“Regulatory parity is not a request for preferential treatment,” DCUC Chief Advocacy Officer Jason Stverak said in a statement. “When a member-owned credit union performs the same function, manages the same risk, and meets the same high regulatory standard as a bank, it must receive equivalent authority and access under the law.”
DCUC said the proposed changes would help ensure credit unions can safely participate in the evolving digital asset marketplace while continuing to serve military members, veterans and their families.
