Comment from Tokenization Systems
Tokenization SystemsSupportOther
Summary: Tokenization Systems, an independent research program, submits a supplemental comment supporting the NCUA's implementation of the GENIUS Act for stablecoins. The commenter provides eleven specific recommendations aimed at ensuring cross-agency consistency, protecting stablecoin holders, and preventing "charter arbitrage" between different regulatory bodies.
Summary of comment of Tokenization Systems on Docket No. NCUA-2026-1024 (RIN 3133-AG10), Implementing the GENIUS Act standards for NCUA-Licensed Permitted Payment Stablecoin Issuers. The full comment is attached.
Tokenization Systems is an independent research program on stablecoin and payment infrastructure regulation. This comment completes its coverage of the parallel GENIUS Act implementing rulemakings across the OCC, FDIC, Treasury, FinCEN, the banking agencies, and the NCUA. Its central cross-docket point is that the agencies should reconcile avoidable differences before final rules take effect, because divergent reserve, capital, redemption, insurance, reporting, or stress-testing standards would invite charter arbitrage.
The comment makes eleven recommendations. It asks the NCUA to make core reserve-diversification standards mandatory, require public reserve reports to identify reserve institutions and insured versus uninsured balances, preserve the technology-neutral part 745 amendment, pair any no-pass-through insurance posture with plain holder disclosures, classify indirect claims on Share Accounts as payment stablecoins rather than tokenized shares, require redemption for any holder who clears screening and onboarding, cap stress-state redemption fees at documented cost, add an objective issuance-scaled capital floor, adopt insolvency and resolution rules with reserve traceability, coordinate reporting and primary-regulator designation with sibling agencies, and require size-scaled stress testing using the March 2023 reserve-concentration depeg channel.
The comment also supports the proposed twelve-month operational backstop because it matches the FDIC's parallel calibration. The recommendations are designed to protect stablecoin holders, preserve credit-union safety and soundness, and avoid cross-charter divergence while staying within the proposed rule's structure and the GENIUS Act.
Respectfully submitted,
Zach Zukowski,
Independent Researcher,
www.Tokenization.Systems