Yesterday the National Credit Union Administration (NCUA) published the proposed rules for stablecoins issued under the GENIUS Act, with comments accepted until 13 April. The NCUA is responsible for the regulation and supervision of 4,499 federally insured credit unions which had $2.3 trillion in assets across the US in 2025.
It’s not the first stablecoin regulator to propose rulemaking, given the FDIC published its proposals in December 2025. While some of the rules are relatively formulaic, there are some notable nuances in the GENIUS Act which may not be ideal for credit unions. Hence, the NCUA is interpreting them appropriately.
The GENIUS Act wording states that banks cannot directly issue stablecoins, only via their subsidiaries. However, the GENIUS Act wording for credit unions is somewhat ambiguous on the subsidiary front. The main clause about permitted issuers refers to “a subsidiary of an insured depository institution”, which seems to include credit unions. However, a more detailed clause stipulating regulators appends a caveat to depository institutions of “other than an insured credit union”. The regulator clause states, “with respect to an insured credit union or a subsidiary of an insured credit union, the National Credit Union Administration”. Depending on the reading, this may imply that a credit union could issue a stablecoin directly, not necessarily via a subsidiary. However, the NCUA closed that door by only considering issuances by subsidiaries as far as we could see.
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