WASHINGTON , DC (July 17, 2026) |
The Defense Credit Union Council today filed a comment letter with the National Credit Union Administration in response to the agency’s proposed rule implementing portions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act, commonly known as the GENIUS Act.
The proposed rule supplements the NCUA’s previous licensing proposal and would establish a regulatory framework for NCUA-licensed Permitted Payment Stablecoin Issuers, or PPSIs, and federally insured credit unions participating in the emerging payment stablecoin market.
DCUC expressed general support for the proposal and for the establishment of a supervisory framework that advances safety and soundness while allowing responsible innovation. DCUC also offered recommendations intended to improve the final rule’s clarity, flexibility and operational efficiency.
“Responsible innovation and strong supervision are not competing priorities,” said Anthony Hernandez, DCUC President and CEO. “A well-calibrated framework can protect the financial system while ensuring credit unions have the same opportunity as other federally regulated financial institutions to participate in the evolving payments market. That opportunity is especially important for credit unions serving servicemembers, veterans and military families who depend on secure, efficient and resilient financial services.”
In its letter, DCUC urged the NCUA to:
- Maintain consistency with the federal banking agencies whenever possible;
- Adopt principles-based requirements throughout the regulation;
- Avoid unnecessary operational, timing and reporting mandates;
- Preserve regulatory flexibility as PPSIs and their business models develop;
- Clarify applicable consumer-protection requirements and examination standards; and
- Review the regulatory framework following implementation and refine it as necessary.
DCUC also provided detailed recommendations concerning reserve assets, redemptions, supervision, reporting, capital requirements and regulatory assessments. Among other recommendations, DCUC supported the NCUA’s proposed principles-based approach to reserve-asset diversification, encouraged a redemption period of at least three business days and recommended monthly rather than weekly supervisory reporting.
“The NCUA’s proposal is a constructive starting point for implementing this new statutory framework,” said Jason Stverak, DCUC chief advocacy officer. “The final regulation will be most effective if it remains principles-based, aligned with the other federal banking agencies and proportionate to demonstrable supervisory risks. Reasonable redemption timelines, appropriately calibrated reporting requirements and clear examination expectations would improve operational efficiency without compromising safety and soundness.”
DCUC further recommended that any assessments imposed to cover the NCUA’s additional stablecoin-related oversight costs be limited to institutions participating in those activities. Those costs should not be paid through the general federal credit union operating fee or the National Credit Union Share Insurance Fund overhead transfer.
Because the GENIUS Act establishes an entirely new regulatory regime, DCUC emphasized that continued engagement between the NCUA and industry stakeholders will be essential during implementation. DCUC encouraged the agency to review its final requirements within the first year after implementation and periodically thereafter to ensure the framework continues to support responsible innovation while maintaining safety and soundness.
DCUC will continue examining how the NCUA’s regulatory requirements affect credit unions and the broader financial-services industry and will provide additional feedback to the agency throughout the year.