Comment from America's Credit Unions

Summary: America's Credit Unions supports the NCUA's proposed rule but urges the agency to ensure that regulations are tailored to the specific capital structures and operational realities of credit unions rather than being directly imported from bank-centric frameworks. They advocate for specific clarifications regarding share account parity, the ability to issue multiple branded stablecoins, and the treatment of "cash on deposit" to ensure competitive neutrality and operational viability for credit union-licensed stablecoin issuers.