Comment from Timothy, Anderson

Public Comment – NCUA Standards Proposal (Payment Stablecoins) Submitted via Regulations.gov Docket: NCUA-2026-1024 | RIN: 3133-AG41 Re: Implementing the GENIUS Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the NCUA – Supplemental Proposed Rule (Standards Proposal) To the NCUA Board: I am submitting this comment as an individual. I work in the credit union industry in Georgia, with a focus on BSA/AML and digital-asset compliance. The views below are entirely my own and do not represent the position of any employer or organization. I appreciate the Board’s careful work to meet the GENIUS Act deadline, and I want to comment on the one area of the proposal that is most distinctly a credit-union issue: the treatment of funds in the Share Accounts at federally insured credit unions relative to deposits at banks. 1.The final rule should explicitly treat Share Accounts at FICU’s on par with bank deposits (Questions 5 and 15). The proposal correctly observes that the GENIUS Act relies on banking-specific terminology and that an overall reading of the Act supports treating “deposits” at banks and funds in “Share Accounts” at credit unions interchangeably. I encourage the Board to make that parity explicit rather than leaving it to interpretation – for example, by adopting a defined term “Deposit” that expressly includes both deposits as defined by the FDI Act and accounts (Share Accounts) as defined by the FCU Act. Leaving the parenthetical limited to the FDI Act definition invites needless interpretive and competitive risk, and could disadvantage credit unions and their members for no policy reason. Explicit parity in the definitions of “Monetary Value” and “Payment Stablecoin” would give credit unions and their members the same footing Congress plainly intended. 2.I support permitting NCUA-Licensed PPSIs to hold reserve assets in Share Accounts at FICUs (§706.202(c) / “Eligible Financial Institution”). Allowing reserves to be held as insured shares at credit unions keeps reserve-related liquidity within the cooperative system, supports smaller institutions, and is consistent with the Act’s parallel treatment of insured shares and demand deposits as permissible reserve backing. I encourage the Board to retain this in the final rule. 3.Preserve proportionality so smaller credit unions can participate through shared issuers. The consortium/joint-application structure is the realistic path for most credit unions of modest size. I encourage the Board to ensure that capital, backstop, and reserve-concentration requirements attach to the licensed issuer as a whole – satisfiable on a pooled basis – rather than in a way that effectively forecloses smaller credit unions from participating in an otherwise well-capitalized shared issuer. Thank you for the opportunity to comment. Respectfully, Timothy Anderson Warner Robins, Georgia