Comment from Better Markets

Summary: Better Markets, a non-profit organization, opposes the NCUA's proposed rule for stablecoin issuance, arguing that it lacks robust capital and liquidity standards, fails to coordinate with other federal regulators, and creates systemic risks through cooperative ownership models. They specifically highlight concerns regarding "step-in" risk for credit unions, circular reserve dependencies, and the NCUA's current lack of supervisory capacity to manage the framework.