By Becky Reed
The CU charter already supports “trust-like” activity—it’s just underused
Under the credit union charter, credit unions can:
- Act as payment intermediaries
- Hold and manage pooled member funds
- Operate CUSOs to isolate specialized risk
In practice, a credit union + CUSO model can replicate much of what a national trust bank does—with member ownership instead of shareholder extraction. What’s missing isn’t legal authority. It’s regulatory clarity and confidence.
NCUA could explicitly recognize a “Digital Asset / Payments-Focused CU Charter.” The agency doesn’t need to copy the OCC, but it could:
- Define a limited-purpose or specialized charter (payments, custody, tokenized deposits)
- Set clear capital, liquidity, and governance requirements
- Require on-chain transparency and real-time auditability
- Limit activities to member-benefit use cases (payments, liquidity, settlement)
- This would mirror what the OCC just did—without creating a new class of bank.
The cooperative structure is actually better aligned with on-chain infrastructure
National trust banks are still shareholder-driven, proprietary, and competitive by default.
Literally The Credit Union Model
The DeFi rails, tokenized liquidity, and shared settlement networks all thrive on:
- Network participation
- Shared governance
- Aligned incentives
- Transparency by design
That is literally the credit union model—if NCUA lets it operate at digital speed.
A CU-led model avoids regulatory arbitrage. One risk of the OCC path is fragmentation in that there are trust banks here and state charters there, with fintechs stitching it all together.
In contrast, a credit-union-based alternative could:
- Keep deposits, payments, and settlement inside the cooperative system
- Reduce reliance on third-party trust banks
- Preserve member relationships instead of outsourcing them
That’s regulatory coherence—not avoidance.
Leaning In
The real unlock: CUSOs as regulated infrastructure operators. NCUA could lean hard into:
- Multi-CU CUSOs operating shared digital rails
- Tokenized liquidity networks owned by participating CUs
- Payments and custody infrastructure governed cooperatively
This gives regulators a single supervised entity and preserves CU ownership.
The Hard Truth
If NCUA doesn’t modernize its chartering posture, credit unions will become customers of OCC-chartered trust banks and value creation will move outside the cooperative system. “Relevance” will be talked about instead of built.
Moreover, if NCUA does act:
- Credit unions could become the most trusted on-chain financial institutions in the U.S.
- Member-owned digital money becomes a differentiator
- Cooperative finance finally scales for the internet era
The OCC just proved regulators are willing to move. Now the question is whether NCUA leads—or watches from the sidelines.
Becky Reed is COO with BankSocial.
