Comment from Corporate Credit Union Alliance
Corporate Credit Union AllianceSupportTrade association
Summary: The Corporate Credit Union Alliance (CCUA) supports the NCUA's proposed framework for stablecoin issuance under the GENIUS Act, emphasizing safety, soundness, and liquidity discipline. They recommend providing flexibility for smaller or early-stage programs, such as allowing single-EFI reserve models for low-risk profiles and adopting a "Crawl. Walk. Run." phased implementation approach.
Comment is being submitted on behalf of the Corporate Credit Union Alliance.