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.

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.

The Cornerstone Credit Union League supports the NCUA's approach to implementing the GENIUS Act but urges the agency to ensure the rules are tailored to credit union capital structures and competitive realities. They request specific clarifications on definitions, reserve asset diversification, data collection burdens, and consumer disclosures to facilitate credit union participation in the stablecoin market.

Timothy Anderson, an individual working in the credit union industry, supports the proposed rule but urges the NCUA to explicitly treat credit union Share Accounts as equivalent to bank deposits. He also advocates for allowing reserve assets to be held in Share Accounts and ensuring that requirements are structured to allow smaller credit unions to participate through shared issuers.