The numbers are staggering, and they’re not hypothetical. Stablecoins, digital tokens designed to maintain stable value by being backed by traditional assets like U.S. dollars or Treasury securities, processed in excess of $25 trillion in on-chain transfer volume in 2024, exceeding Visa and Mastercard’s reported payment volumes combined.
This gross transfer value includes exchange arbitrage and settlement flows, not just consumer transactions, but the scale demonstrates rapid infrastructure maturation. The market has grown to approximately $255-270 billion in circulation, roughly doubling since mid-2023.
But here’s what should really capture your focus: approximately 39% of credit union members have owned cryptocurrency (CUNA 2022), compared to about 28% of U.S. adults in recent 2025 surveys. While your institution has been watching from the sidelines, your most engaged members have been adopting digital financial infrastructure that bypasses traditional banking entirely.
The question isn’t whether stablecoins will impact your credit union. They already are.
The Strategic Reality Check
From an enterprise risk management perspective, stablecoins represent “convergent risk,” that is, multiple threat vectors accelerating simultaneously toward your core business model. Payment disintermediation threatens fee income. Deposit migration challenges funding stability. Technology requirements strain operational capacity.
Yet dismissing stablecoins as merely speculative “crypto” misses the strategic picture entirely. The July 2025 GENIUS Act provides explicit federal authority for credit unions to engage in stablecoin activities under NCUA oversight. The Act authorizes, but does not mandate, participation. What was once regulatory gray area is now clear opportunity, with appropriate safeguards.
Strategic Framework
Effective stablecoin strategy requires “strategic opportunism,” moving decisively on opportunities while maintaining disciplined risk management. This means approaching stablecoins through three strategic lenses:
- Business Model: Cross-border payments offer up to 80% cost reduction compared to traditional remittance services. For credit unions serving immigrant communities or commercial members with international operations, this represents competitive necessity.
- Risk Integration: Stablecoin risks intersect with existing enterprise frameworks. Operational risk expands to include private key management and blockchain dependencies. Strategic risk emerges as competitive positioning decisions become irreversible.
- Capability Development: Technology infrastructure, regulatory compliance expertise, and vendor management capabilities all require enhancement. Institutions that begin capability building now will have sustainable advantages.
The ERM Perspective
Successful stablecoin implementation follows predictable patterns. Institutions that struggle typically move too fast without adequate risk assessment, delay too long and miss opportunities, or attempt to build everything internally rather than leveraging proven vendor partnerships.
Traditional banking risk frameworks require adaptation. Operational risk now includes cybersecurity threats specific to blockchain environments and key management procedures with no traditional banking equivalent. While the July 2025 GENIUS Act clarified the regulatory pathway, regulators continue expressing concerns about systemic risk and consumer protection.
Most importantly, strategic risk has shifted from “should we engage?” to “how quickly can we build competitive advantage?” Institutions that delay aren’t avoiding risk, they’re accepting the risk of competitive irrelevance.
Implementation Approach
Effective stablecoin strategy begins with honest institutional assessment: Do you have the necessary expertise, technology infrastructure, risk management capabilities, and governance structures for blockchain-based financial services?
Vendor evaluation requires special attention. The landscape includes established vendors offering integrated stablecoin platforms, specialized blockchain companies, and hybrid providers. Due diligence must address regulatory compliance, infrastructure resilience, and interoperability across multiple stablecoin networks.
Pilot programs with defined guardrails provide the most practical path forward, starting with commercial members who have cross-border payment needs.
Enterprise Risk Management Integration
As credit unions develop stablecoin strategies, integration into existing risk management programs becomes essential. At the enterprise level, stablecoin risks need assessment alongside traditional credit, operational, and strategic risks. This means updating scenario planning, revising vendor risk policies, and ensuring board oversight can govern digital asset activities.
However, enterprise risk management and operational risk assessment serve different purposes. ERM provides strategic framework and governance, while operational risk assessment focuses on implementation specifics, technology integration, compliance capabilities, and vendor procedures.
Once your institution decides to move forward, comprehensive operational risk assessment becomes crucial to evaluate infrastructure readiness, identify compliance gaps, and stress-test procedures under various scenarios.
Strategic Positioning
The stablecoin transformation isn’t a distant possibility – it’s today’s competitive reality. Credit unions that will thrive combine decisive action with disciplined risk management, member-focused innovation with operational excellence.
This requires moving beyond traditional banking comfort zones while maintaining cooperative principles that define credit union value. It means embracing new technology while preserving human relationships that create member loyalty.
The decision isn’t whether stablecoins will matter. They already do. The decision is whether your credit union will lead in shaping their use for members, or cede that role to competitors. Organizations that answer thoughtfully, with expert guidance and appropriate caution, will emerge stronger in the digital economy.
Michael Cannes is Strategy, Risk and Assurance Partner with Rochdale.
