CU Trade Groups Offer Their Two Cents on Stablecoin Proposal

WASHINGTON—The credit union trade groups have weighed in with what they want to see around rules for stablecoins.

America’s Credit Unions is urging the National Credit Union Administration to refine and expand its proposed framework for licensing and overseeing payment stablecoin issuers, arguing the agency must ensure the process is workable for credit unions while additional key regulatory standards are still under development.

In a comment letter dated April 13, the trade group said it supports the NCUA’s effort to implement the stablecoin provisions of the GENIUS Act and reiterated its long-standing position that credit unions should have equal access to emerging payment systems. 

However, America’s Credit Unions emphasized that the current proposal is limited largely to the application and licensing process for “permitted payment stablecoin issuers,” and does not yet address critical prudential standards such as capital, liquidity, reserves and risk management. 

Because of that, the group told the agency it is difficult for credit unions to fully evaluate the framework or determine whether participation in stablecoin activities would be feasible.

‘Clear, Timely & Workable’

The letter calls on the NCUA to ensure the application process is “clear, timely and workable” for institutions of all sizes, and to avoid creating barriers that could limit participation by smaller credit unions, according to America’s Credit Unions. 

The organization also raised concerns about operational and structural aspects of the proposal, including how credit unions would invest in or partner with licensed stablecoin issuers and how the framework would accommodate collaborative or consortium models, which regulators have indicated may be common. 

Under the proposed rule, federally insured credit unions would be limited to investing in NCUA-licensed issuers and would be required to engage in stablecoin activity through subsidiaries rather than issuing tokens directly. 

America’s Credit Unions said it generally supports that approach but urged the agency to provide additional clarity around ownership structures, application requirements and supervisory expectations.

Agency Coordination Urged

The group also encouraged the NCUA to coordinate closely with other federal regulators to avoid duplicative or inconsistent requirements, noting that multiple agencies share oversight responsibilities under the GENIUS Act.

The NCUA’s proposal represents the first phase of its rulemaking and is intended to establish a licensing framework for stablecoin issuers affiliated with credit unions, with additional proposals expected to address operational and prudential standards.

DCUC: Greater Flexibility Urged

Separately, the Defense Credit Union Council also provided its input.

“We appreciate the NCUA’s leadership in advancing a regulatory framework to implement the GENIUS Act and bring greater clarity to the evolving digital asset marketplace,” Chief Advocacy Officer Jason Stverak said in a statement. “For credit unions, it is critical that this framework remains flexible, risk-appropriate, and consistent across the broader financial regulatory landscape. With targeted refinements, this rule can empower credit unions to responsibly engage in innovation, expand member services, and ensure they are not left behind as payment technologies continue to evolve.”

DCUC’s recommendations included greater flexibility in subsidiary structures, consistency with other federal regulators, transparent and efficient supervisory processes, and preserving pathways for credit unions to invest in permitted payment stablecoin issuers across regulatory regimes.

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