DCUC Writes to NCUA for Clear Digital-Asset Roadmap Following CLARITY Act Vote

By DCUC Staff — September 22, 2026

WASHINGTON, DC – The Defense Credit Union Council (DCUC) has written to National Credit Union Administration (NCUA) Chairman John Crews following the Senate’s September 15 vote that did not invoke cloture on the motion to proceed to the CLARITY Act, urging the agency to provide credit unions with greater clarity on digital-asset activities under existing law.

“Credit unions need a clear understanding of what they can do today, what conditions apply, and where additional authority is needed,” says Anthony Hernandez, DCUC President/CEO, Ret. U.S. Air Force Colonel. “NCUA has already established important building blocks through its digital-asset guidance and implementation of the GENIUS Act. We believe the next step is bringing those pieces together into a practical framework credit unions can use.” In its letter, DCUC respectfully requested the NCUA develop a consolidated digital-asset roadmap addressing several questions: Can we offer the service directly? Must it be conducted through a permitted subsidiary, CUSO, or independent provider? Is prior approval required?Which risks must the board address? What will examiners expect? DCUC noted that NCUA’s existing guidance provides a foundation, with its 2021 guidance addressing qualifying relationships with third-party digital-asset providers, and its 2022 distributed-ledger guidance confirming that the technology is not prohibited when used for otherwise permissible activities and in compliance with applicable law. DCUC encouraged NCUA to build on that foundation with clearer, activity-specific guidance covering third-party services, payment and settlement activities, payment stablecoins, tokenized shares, custody-related functions and other emerging uses of distributed-ledger technology. DCUC also urged NCUA to complete its GENIUS Act implementation with clear and proportionate standards that account for cooperative structures and provide credit unions a meaningful opportunity to participate alongside similarly situated regulated institutions. DCUC also wrote that boards and examiners should have consistent expectations for governance, cybersecurity, third-party oversight, consumer protection, reconciliation and orderly exit, with clear distinctions between legal requirements and supervisory guidance. Coordinating for Credit Unions and Military Families Because digital-asset activities can involve multiple federal and state regulators, DCUC also encouraged NCUA to coordinate closely with Treasury, FinCEN, the SEC, CFTC, and other agencies to ensure credit unions are appropriately considered in emerging policy and regulatory frameworks. DCUC called for practical guidance addressing military addresses, remote identity verification, and deployment-related changes while maintaining applicable sanctions and anti-money-laundering requirements. DCUC has requested an in-person meeting with Chairman Crews and NCUA staff to discuss these issues and identify what can be addressed under existing authority, where additional guidance or rulemaking may be appropriate, and which questions require congressional or interagency action.

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Originally reported by DCUC.