Letter to the NCUA on the Proposed Rule regarding Investments in and Licensing of Permitted Payment Stablecoins Issuers

Dear Ms. Conyers-Ausbrooks:

The American Bankers Association (ABA) appreciates the opportunity to respond to the National Credit Union Administration's (NCUA) Proposed Rule regarding Investments in and Licensing of Permitted Payment Stablecoins Issuers ("Proposed Rule"). We are providing the banking industry's views on the NCUA’s Proposed Rule as it works to implement requirements of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), codified at 12 USC 5901 et seq.

Relevant Background

Importantly, the Federal Deposit Insurance Corporation (FDIC) issued a notice of proposed rulemaking on December 19, 2025 that would establish procedures to be followed by an insured State nonmember bank or State savings association (each, an FDIC-supervised institution) that seeks to obtain FDIC approval to issue payment stablecoins through a subsidiary pursuant to the GENIUS Act. ABA and other trade associations noted that the FDIC's proposal did not include provisions to "implement the capital, liquidity, risk management, and other prudential requirements, as required by section four of the GENIUS Act, that would apply to PPSIs that are subsidiaries of FDIC-supervised institutions." [Note: On April 10, 2026 (as this letter was being finalized), the FDIC published a proposed rule would implement requirements in these areas. Comments are due June 9, 2026.]

Furthermore, questions remain on how the proposal would interact with the GENIUS Act’s complex and novel regulatory framework for payment stablecoins, as "Congress' policy goals [can be effectively achieved] only if affected parties are given the opportunity to thoughtfully consider all required rulemakings applicable to payment stablecoins holistically." The FDIC extended the comment deadline for the December 19 proposal from February 17, 2026 until May 18, 2025.

Download the comment letter to read the full text.