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

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.

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 Defense Credit Union Council (DCUC) supports the NCUA's proposed rule to implement the GENIUS Act, advocating for a supervisory framework that promotes safety, soundness, and innovation for credit unions in the stablecoin market. They recommend maintaining consistency with federal banking agencies, adopting principles-based requirements, and reducing unnecessary operational and reporting burdens.

The Cooperative Credit Union Association, Inc. supports the proposed rule but urges specific clarifications to ensure a level playing field for state-chartered credit unions and to reduce regulatory burdens. They advocate for principles-based reserve asset diversification, parity with bank capital requirements, and the inclusion of federal preemption provisions.

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.

TruStage, a provider of financial products and services to credit unions, supports the NCUA's proposed rules for implementing the GENIUS Act. They advocate for a risk-based, principles-based approach to supervision that focuses on effective outcomes—such as redemption capability, governance, and operational resilience—rather than prescriptive, uniform requirements.

VeloxVFX LLC, a company developing interoperability architecture, supports the NCUA's implementation of the GENIUS Act by advocating for a "lifecycle-separated" relationship-state classification. They argue that the framework should clearly distinguish between different types of relationships (e.g., credit union members vs. stablecoin issuer customers) to preserve institutional boundaries, improve supervisory readability, and ensure audit-oriented traceability.