Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the NCUA

The National Association of State Credit Union Supervisors (NASCUS) supports the NCUA's efforts to establish a regulatory framework for stablecoins under the GENIUS Act. They advocate for a risk-focused, technology-neutral, and proportionate approach that emphasizes federal-state coordination and avoids duplicative regulations.

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.

The Illinois Credit Union League (ICUL) supports the NCUA's supplemental proposed rule to implement the GENIUS Act, praising the efforts to create a clear regulatory framework for stablecoins. They advocate for a risk-based, proportionate approach that recognizes the unique cooperative structures of credit unions while seeking specific clarifications on definitions, custody, and consumer protections.

The Main Street Foundation's Center for Regulatory Analysis and Engagement (CRAE) supports the NCUA's effort to establish a supervisory framework for payment stablecoin issuers. They argue for a risk-based, proportionate approach that maintains statutory fidelity to the GENIUS Act while ensuring that requirements are tailored to the specific economic functions and risks of stablecoins rather than traditional banking.

Circle Internet Group, Inc. supports the NCUA's proposed implementation of the GENIUS Act, advocating for a consistent federal framework for payment stablecoins. They propose specific revisions to ensure the rule maintains a clear distinction between payment stablecoins and credit union share products, emphasizes standalone "ring-fenced" issuer requirements, and ensures interagency consistency across federal regulators.

The Digital Chamber (TDC), a trade association representing over 250 members in the blockchain ecosystem, supports the NCUA's proposed regulations for the GENIUS Act. They emphasize the need for regulatory consistency across different federal agencies and provide specific recommendations on definitions, reserve assets, and capital requirements to ensure a uniform national framework.

The League of Credit Unions & Affiliates supports the NCUA's proposed rule to implement the GENIUS Act, commending the development of a clear regulatory framework for stablecoins. They advocate for specific clarifications on anti-evasion frameworks for yield, the definition of "digital asset service provider," and support a principles-based approach (Option A) for reserve and liquidity requirements.

XBRL US, a nonprofit data standards organization, supports the proposed rule but urges the NCUA to require disclosures in a structured, machine-readable (XBRL) format. They argue that using XBRL and the Legal Entity Identifier (LEI) will improve data quality, transparency, and interoperability while reducing the reporting burden for stablecoin issuers.

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.

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.