Comment from Paradigm Operations LP
Paradigm Operations LPOpposeBusiness
Summary: Paradigm Operations LP opposes several aspects of the NCUA's proposed rule, arguing that the expanded yield prohibition exceeds statutory authority and that the weekly reporting requirements are overly burdensome for early-stage issuers. The firm advocates for a narrower interpretation of the yield prohibition, the retention of multi-brand issuance, and a shift to monthly reporting to foster competition and innovation.
Please see attached document.