WASHINGTON—The American Bankers Association is urging NCUA to hit pause on its proposed rule implementing part of the GENIUS Act for payment stablecoins, arguing the agency should not finalize an application process for permitted payment stablecoin issuers before it has also proposed the far more substantive prudential standards that would govern capital, liquidity, risk management and supervision.
In a comment letter dated April 13, ABA said NCUA’s current proposal is too incomplete to move forward on its own.
In the five-page letter, ABA said NCUA’s proposal—like an earlier FDIC proposal—largely operationalizes how applications would be handled, but leaves key requirements to a future “Subpart B” rulemaking. The trade group said that approach could create confusion under the GENIUS Act’s “complex and novel” framework and urged NCUA to wait until the full rule package and other related federal rulemakings are available so stakeholders can evaluate the regime “holistically.”
ABA also pressed NCUA to coordinate closely with the FDIC, Federal Reserve and OCC, arguing the statute itself contemplates joint or coordinated rulemaking among the primary federal payment stablecoin regulators. The banking group said NCUA should seek “equivalent regulatory requirements and supervisory expectations” across agencies to preserve financial stability and avoid creating competitive advantages that could predetermine “winners and losers” in the emerging stablecoin market.
Beyond that, ABA asked NCUA to build in a formal public notice-and-comment process for applications submitted under the rule, saying outside input could surface relevant information about an applicant’s management, ownership, compliance history or other safety-and-soundness concerns—particularly for newer institutions with limited supervisory track records. It also urged NCUA to adopt clear, transparent standards for granting the GENIUS Act’s temporary waiver authority for pending applications, including guardrails to prevent regulatory arbitrage, unfair competitive advantages or risks to the broader financial system.
Finally, ABA warned that NCUA and the other regulators need to coordinate the timing of final rules so a single agency’s action does not inadvertently trigger the GENIUS Act’s effective date before the full framework is in place. The group said the agencies should issue final rules concurrently and reiterated in its conclusion that NCUA should not finalize the proposal until Subpart B and other key GENIUS Act rules are available, with a coordinated interagency framework that ensures a level playing field among banks, credit unions and their subsidiaries.