By Ray Birch
WASHINGTON —NCUA’s proposed stablecoin rule may look like a straightforward implementation of the GENIUS Act, but industry observers say the real story lies in how much discretion the agency is building into the framework — and in the strategic crossroads it creates for credit union boards.
Brandy Bruyere, a partner at Honigman, LLP, said the proposal makes clear the rule itself will serve as a high-level framework, with much of the substantive detail living in separate licensing and issuer manuals.
“The proposal contemplates a separate licensing manual, and issuer manual, which indicates the rule will be a framework and particulars will live in those guidance documents which will be easier to amend from time to time compared to changing a regulation,” Bruyere said, adding that this structure would allow NCUA to adjust as the framework is implemented, regulators’ perspectives shift, or leadership changes.
She noted the approach “somewhat reminds me of the commercial lending rule about 10 years ago,” when the agency made the regulation less prescriptive and relied heavily on its Examiner’s Manual to communicate substantive requirements.
Bruyere added that stakeholders should watch what the FDIC publishes in its own guidance and manuals, as there will likely be consistency in approach.
Brandy Bruyere
Resources Will Be Needed
“The NCUA has to license issuers, which aligns with the statute, but this will take resources especially as interested credit unions apply simultaneously as this process is finalized,” Bruyere said. “The proposal does not contemplate a filing fee but does indicate fees could end up being necessary based on the number of applications and resources required to do this work.”
The proposal, Bruyere noted, encourages scheduling “prefiling” meetings to obtain feedback on business plans.
“Presumably, so feedback can be proactively incorporated by the applicant before submitting a final license application,” she explained. “Issuers will need to meet capital requirements based on the volume and type of transactions anticipated in the business plan.”
Bruyere believes there will be consistency with the FDIC approach.
“So, watching how that rulemaking process goes is very likely to inform the NCUA path as well,” she said. “The agency is asking a lot of substantive questions, so, the more feedback the industry provides, the better. The number of comments may be an indicator of the industry’s interest in or potential future level of participation as well.”
Important Policy Signal
Kian Sarreshteh, CEO of InvestiFi, said the proposal sends an important policy signal, but warned that issuance should not become a reflexive move.
Kian Sarreshteh
“The NCUA’s proposed rule allowing federally insured credit unions to apply to become ‘permitted payment stablecoin issuers’ is a meaningful signal that regulators recognize stablecoins are becoming part of the modern financial system,” Sarreshteh said. “From a policy perspective, it provides clarity and a defined pathway for credit unions that want to participate more directly in digital payments infrastructure.”
However, before credit unions go down the path of issuing stablecoins themselves, they need to clearly understand the why behind the investment, Sarreshteh emphasized.
“Spinning up a compliant stablecoin program is not trivial. It requires significant operational buildout, risk management frameworks, liquidity planning, cybersecurity controls, compliance oversight, and likely new staffing,” he said. “Credit unions already face intense competing priorities—core modernization, member experience, lending growth, cybersecurity, and regulatory burden. Stablecoin issuance should not become a ‘shiny object’ initiative without a defined member use case and ROI.”
The questions every credit union board should ask, Sarreshteh said, is: “What specific member problem are we solving?”
“Is issuance the right strategy, or is enablement sufficient?” he said. “Can we achieve the same member value more efficiently through partnerships to free up internal resources? In many cases, credit unions don’t necessarily need to issue a stablecoin to participate in the digital asset ecosystem. There are alternative models that allow them to offer crypto access, stablecoin payments, and digital asset functionality without assuming full issuance risk or infrastructure costs.
“For example, through InvestiFi’s multi-custodial approach to crypto and stablecoins, we can integrate digital asset capabilities directly into a credit union’s existing digital banking experience,” continued Sarreshteh. “Members can access crypto and stablecoin functionality, while the credit union avoids the cost, regulatory exposure, and operational lift of becoming an issuer itself. The member value can be nearly identical—at a fraction of the cost and complexity.”
Sarreshteh asserted the proposed rule will likely accelerate strategic conversations in boardrooms.
“Some larger or innovation-forward credit unions may explore issuance as a competitive differentiator,” he noted. “However, for many institutions, partnership-based models will likely prove to be the more capital-efficient and risk-aligned path.”