Chaos. It’s a strong word that triggers many different emotions and reactions, and maybe it’s definition of “complete disorder and confusion” doesn’t exactly describe 2026—yet. There is, however, a physics-based perspective on chaos that might be more aligned to how 2026 has felt so far:
“Behavior so unpredictable it appears random, owing to great sensitivity to small changes in conditions”
This unpredictability is showing up in unique and different ways this year; whether it be political, legislative, or through the continuous pace of innovation across payments and technology industries that directly influences how we as credit unions show up and support our members and the communities we serve.
So where is the unpredictable behavior of chaos showing up most? For my span of care, it is within payments.
Digital assets
The passing of the GENIUS Act last year provided much needed regulatory clarity for crypto and digital asset markets but still left open a loophole allowing rewards and yield payment though exchanges. At the heart of this issue, which is already on lawmaker’s agenda, is the opportunity for a parallel banking system without all the necessary regulatory framework to emerge, which could put at risk $6.6 trillion dollars of deposits. If this were to happen, credit unions would not only risk losing assets on their balance sheets, but the financial system could also face increased systemic risk—directly impacting everyday Americans if existing regulatory safeguards don’t apply when things go wrong.
While many initial Stablecoin use cases focus on cross-border speed and efficiency, on and off ramp access for digital assets, and the ability to pay recipients in a stable USD based payment, the outcome of the above may inform the importance and relevance of stablecoins and tokenized deposits for credit union balance sheets.
These developments are also fueling new applications for National Trust Banking Licenses from the Office of the Comptroller of the Currency (OCC) for digital asset banks, which include Ripple (Ripple National Trust Bank), Circle (First National Digital Currency Bank), BitGo (BitGo Bank & Trust, N.A.), Fidelity Digital Assets(Fidelity Digital Assets, N.A.), and Paxos (Paxos Trust Company, N.A.). This may change the competitive landscape for banking—where we all compete for the attention of younger generations growing up with digital assets.
Interchange & credit cards
President Trump has made affordability a policy issue for the current Administration and has credit card company practices and payment network economics on his radar of ways he can deliver on this promise to the American people. This intention was made evident on January 9 when he announced via social media his proposal for credit card companies to limit interest rates to 10% for a period of twelve months, with an implementation that was set for January 20 to align with the first anniversary of his second presidential term.
Separately, and perhaps in response to feedback about the unintended impacts a rate cap would have on everyday Americans who rely on access to credit, President Trump pivoted his focus on affordability from credit card interest rates to interchange.
A public endorsement by President Trump of previous attempts to make credit card industries more competitive lead to the reintroduction of the Credit Card Competition Act to Congress, targeting the largest credit card issuers with over $600B in assets who issue over 80% of all credit cards to everyday Americans, and would require them to support more than one payment network for credit cards issued on Visa and Mastercard networks. While this may increase competition among card payment networks and give merchants opportunities to lower payment acceptance costs, it would not directly improve affordability for everyday Americans. Over time, it would reduce interchange income for all credit card issuers—regardless of size—which could ultimately impact cardholder benefits, rewards, and both access to and the cost of credit for the consumers who rely on credit cards the most.
Ongoing efforts to further legislate payments, along with a pending court approval of a 20-year class action lawsuit between merchants, Visa, and Mastercard, could have collective and unintended consequences for everyday Americans—impacting access to and the cost of credit for those who rely on these payment tools the most.
Leading through chaos
Managing through chaos requires true leadership—whether at the industry level through grassroots advocacy, by preparing for strategic pivots as you assess potential outcomes, or by leading teams in a way that keeps them focused on current strategy and goals until a pivot is truly needed.
And while digital assets and payments legislation are just two issues that will be top of mind as we head to Washington D.C. for the Governmental Affairs Conference (GAC), we all should think about the unpredictable behavior seen so far and focus our efforts on the legislative topics and issues that matter the most to our industry, our credit unions, and the members and communities we serve.
