MARLBOROUGH, Mass.–The Cooperative Credit Union Association has formally submitted four comment letters to the related to its proposed rule to implement the GENIUS Act, as well as three proposals issued as “Round Five” of the agency’s ongoing Deregulation Project—including taking a firmer stand on charter conversions and mergers than other associations have.
The comment letters by the CCUA, which represents credit unions in Massachusetts, New Hampshire, Rhode Island and Delaware, include:
Investments in Permitted Payment Stablecoins (GENIUS Act):
“We urge the NCUA to ensure a level competitive playing field with banks regarding stablecoins. Specifically, we advocate for a 25% ownership threshold to define ‘control’ of an issuer—aligning with the Bank Holding Company Act—rather than the proposed 10%,” the CCUA said. “We also oppose the implementation of application or investigation fees to help spur innovation in this space.”
Chartering and Field of Membership (IRPS 06-1):
“The Association supports the rescission of Interpretive Ruling and Policy Statement 06-1. This rule is redundant with existing requirements in the Chartering and Field of Membership Manual, and removing it simplifies the regulatory landscape for credit unions seeking to expand service to underserved areas.”
“We oppose the proposal to weaken protections for members during credit-union-to-bank conversions. There is concern with removing ‘clear and conspicuous’ notice requirements or limit members’ ability to communicate with one another during these existential transitions, as these safeguards have successfully protected member equity for two decades,” the association said.
Mergers and Termination of Share Insurance:
“While we support liberalizing formatting requirements for federal share insurance termination notices, we oppose the elimination of the member-to-member communication process for mergers,” the CCUA wrote. “Members, as owners, should retain the right to share views on proposed mergers, especially since current data shows the regulatory burden of this process is already quite low.”
