DCUC Urges Senate To Protect Overseas Military Access And Credit Union Parity In CLARITY Act
By CU Today Staff —
WASHINGTON—The Defense Credit Union Council is urging the Senate to address gaps in proposed CLARITY Act language that create uncertainty for military families stationed overseas and leave credit unions without the same clear treatment as banks in several important areas.
In a letter addressed to Senate Banking Committee Chairman Tim Scott and Ranking Member Elizabeth Warren, Chief Advocacy Officer Jason Stverak called for explicit protections ensuring that official overseas assignments do not become barriers to otherwise lawful financial services.
“Military service should never be the reason a family loses access to its trusted credit union,” said Anthony Hernandez, DCUC president/CEO, ret. U.S. Air Force colonel. “As Congress develops the rules for digital financial services, it must account for the Americans our country sends overseas and the credit unions authorized to serve them. We can protect their access without weakening the safeguards that protect their money.”
The letter identifies a residence-based definition in Section 10404 of the proposed Senate substitute to H.R. 3633, the Digital Asset Market Clarity Act. That definition governs specific payment-stablecoin compensation restrictions and related protections. DCUC emphasized that it is not, by itself, a blanket prohibition on overseas access, but creates uncertainty Congress should resolve before the legislation becomes law.
“An overseas assignment should change a family’s location, not its access to lawful financial services or its credit union’s ability to provide them,” Stverak wrote.
DCUC asked lawmakers to expressly include servicemembers, including National Guard and Reserve personnel serving on orders, their accompanying spouses and dependents, and federal civilian employees and families on official overseas assignments within the relevant U.S.-person treatment. DCUC reminded that protection should not require maintaining a current physical residence in the United States.
DCUC also requested a broader military-service continuity provision, noting that otherwise eligible members should not lose access to accounts, payment services, qualified digital-asset safekeeping, or payment-stablecoin redemption solely because official orders place them abroad.
The requested protection extends to the institutions serving those households. U.S. federally and state-chartered credit unions, authorized overseas branches, qualifying subsidiaries, credit union service organizations (CUSOs), and lawful service-provider arrangements should not lose eligibility or be treated as foreign providers solely because they serve covered military families overseas.
DCUC also urged federal financial regulators to work with the Department of War and state supervisors on practical implementation, including military mailing addresses, official duty documentation, remote identity verification, and location-based access controls. A domestic street address should not be the only acceptable way to establish a military household’s eligibility.
“The requested changes would preserve sanctions, anti-money-laundering requirements, consumer protections, membership and charter requirements, and safety-and-soundness supervision. They would not override applicable host-country laws or international agreements or require institutions to provide unsafe services,” said Stverak.
Closing The Remaining Bank-Credit Union Gaps
DCUC recognized meaningful progress in the draft, including clearer treatment of credit union accounts and digital-asset activities, while asking Congress to make related provisions consistent.
“Our request is not special treatment or protection from competition. It is a fair opportunity to provide lawful services safely, with the same clarity Congress provides to banking institutions,” Stverak wrote.
Among the changes requested, DCUC urged the Senate to provide comparable authority and registration treatment; make safekeeping rules consistent; include NCUA in key decisions; and protect member savings and affordable credit.
“The GENIUS Act already provides an approval framework for qualifying credit union subsidiaries to issue payment stablecoins,” said Stverak. “The proposed account corrections improve legal certainty. They do not create credit unions’ first opportunity to participate. A payment stablecoin does not become federally insured merely because a credit union is involved.”
Pursuing Progress Beyond One Legislative Package
DCUC urged lawmakers to pursue targeted statutory corrections and other appropriate legislative opportunities if broader CLARITY negotiations require more time. The trade group expressed support of regulatory action where existing law permits, while recognizing that agencies cannot substitute for Congress when a statutory change is necessary.
“We should not make military families or their credit unions wait indefinitely for Congress to get these details right,” Hernandez stressed. “If the broader bill takes longer, lawmakers should pursue targeted corrections that protect access and provide certainty. Our focus should remain on practical results for the people these institutions serve.”
“The Americans ordered overseas to defend our country should not be left outside the financial future Congress is creating. Their credit unions should be able to serve them wherever their duty takes them,” Stverak added.
Originally reported by CU Today.