Providing detailed feedback on NCUA’s GENIUS Act proposal
As NCUA works to implement the GENIUS Act, America’s Credit Unions submitted comments on the proposal Friday. NCUA’s proposal contains core operational requirements for agency-licensed permitted payment stablecoin issuers (PPSIs).
“We commend the NCUA for seeking to align proposed regulations with the statutory text of the GENIUS Act and for favoring individualized, risk-based assessments over rigid quantitative mandates in areas where the statute directs tailoring, such as capital adequacy,” the letter reads. While acknowledging an overarching objective of regulatory coordination, the letter urged "the NCUA to remain attentive to the structural differences [of] credit unions.”
America’s Credit Unions provided detailed recommendations to improve a final rule, including requests for the NCUA to:
Improve definitional clarity, and codify parity between bank deposits and credit union share accounts;
- Ensure the prohibition on offering interest on stablecoins applies uniformly across all PPSIs, while avoiding an attempt to enumerate every application of the prohibition, and instead commit to issuing periodic interpretive letters as regulatory interpretations evolve;
- Provide an exception to the two-business-day funds availability standard for redemptions when a PPSI or federally insured credit union has a reasonable suspicion of fraud, modeled on Regulation CC; and
- Clarify the disclosures, policies, call report treatment, and redemption mechanics that will distinguish tokenized shares from payment stablecoins, including whether a stablecoin redemption may settle into a tokenized share account.