Joint Letter to the NCUA on Implementing the GENIUS Act Rulemaking

To Whom it May Concern:

The undersigned trade associations (the "Associations") appreciate the opportunity to comment on the notice of proposed rulemaking issued by the National Credit Union Administration regarding the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act.

We also appreciate the NCUA’s careful consideration of the regulations that it is required to issue under the GENIUS Act, particularly given the numerous significant policy questions that implementation of the GENIUS Act raises. The proposal addresses a broad range of prudential and risk management requirements for permitted payment stablecoin issuers ("PPSIs") within the NCUA's remit, including governance, reserve management, operational resilience, compliance risk management, and Bank Secrecy Act/anti-money laundering and sanctions compliance. The way in which the GENIUS Act is implemented, and the prudential and compliance requirements that will apply to payment stablecoin issuers, could have significant effects on financial stability, credit creation, consumer protection, illicit finance risk, and the broader economy. Changes and clarifications to the proposed rule are important to help to ensure the GENIUS Act is implemented in a manner that, as Congress envisioned, appropriately balances the benefits and innovative potential of payment stablecoins with the broader economic, consumer protection, and illicit finance risks that these instruments may pose.

To that end, the Associations urge the NCUA to coordinate closely with the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation to ensure that requirements for PPSIs are substantially similar and appropriately rigorous across the primary Federal payment stablecoin regulators.

Download the joint comment letter to read the full text.