DCUC Calls on NCUA to Protect Credit Union Competitiveness

By DCUC Staff — October 21, 2026

WASHINGTON, D.C. — Following the OCC’s announcement of its final GENIUS Act rule, Jason Stverak, Chief Advocacy Officer of the Defense Credit Union Council (DCUC), issued the following statement:

“The OCC’s announcement makes NCUA’s next steps critical for credit unions. Credit unions need a workable path to offer responsible payment innovation, compete alongside banks, and keep serving their members. NCUA should move promptly to ensure military families can access new payment options through the credit unions they already trust.“The impact reaches credit unions that never issue a stablecoin. If stablecoin rewards draw member deposits away, credit unions could face higher funding costs and less money to lend for homes, emergencies, and veteran-owned businesses. NCUA must consider those risks to affordable credit as it develops its rules. Protecting credit unions’ ability to serve military families must remain central to that work.“NCUA must provide explicit parity between bank deposits and credit union shares in stablecoin reserve requirements. The OCC’s recognition of on-demand credit union share accounts in its liquidity requirements is a useful step. NCUA should build on it so credit unions have a fair opportunity to hold eligible reserve funds and participate in the payments market.“Participation must be practical for credit unions of different sizes. NCUA should allow jointly owned subsidiaries so credit unions can share costs, clarify how pledged reserves interact with CUSO investment limits, and preserve lawful investment opportunities across regulatory regimes. It should also address field-of-membership barriers within its authority and identify changes Congress must make. Applying a bank framework without accounting for credit unions’ cooperative structure could create unnecessary barriers to entry.“On rewards, NCUA should issue clear guidance and coordinate enforcement with other regulators to prevent evasion of the statutory interest ban. The OCC removed its proposed presumption against certain third-party rewards arrangements, but the interest prohibition remains. NCUA should scrutinize arrangements within its jurisdiction based on their economic substance, including the role of affiliates and partners. Congress should close statutory gaps that regulators cannot resolve. Calling a payment a reward should not become a workaround for prohibited interest.“Compliance costs must be proportionate to risk. NCUA should tailor capital and liquidity requirements, avoid duplicate reporting, and permit monthly issuer reporting where sufficient for supervision. The OCC retained weekly and quarterly reports; if NCUA follows that approach, it should provide comparable relief for eligible smaller issuers. Added stablecoin oversight should be funded through limited assessments on participating entities, protecting other credit unions from bearing those costs through general operating fees or the Share Insurance Fund overhead transfer.“NCUA should publish an implementation roadmap ahead of the OCC rule’s January 18, 2027 effective date, including application requirements, decision timelines, and criteria for lawful transition relief. It should clarify the treatment of custody-only services and tokenized shares, require plain-language disclosures that payment stablecoins are not federally insured share accounts, and review the rules within the first year. Credit unions need timely answers to plan investments and serve members responsibly.“DCUC wants NCUA to deliver rules that give credit unions a fair chance to compete, preserve their capacity to lend, and protect the servicemembers, veterans, and military families who depend on them.”

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Originally reported by DCUC.