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.

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 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.

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.

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.

ALM First, a firm advising credit unions on balance sheet strategy and risk management, supports the NCUA's proposed framework for stablecoin issuance. They argue that the rule's effectiveness depends on integrating stablecoin activities into existing governance, liquidity, and capital planning processes rather than creating isolated regulatory silos.

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.