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The NCUA has issued a proposed rule implementing the GENIUS Act, establishing a federal licensing framework for payment stablecoin issuers.

For the first time, credit union subsidiaries could apply to become Permitted Payment Stablecoin Issuers (PPSIs) — but only under strict supervisory standards.

In this episode, Mark breaks down:

• Why credit unions cannot issue stablecoins directly
• How the subsidiary licensing model works
• The 10% “Parent Company” threshold and joint application structure
• The 1% CUSO investment cap and its impact on participation
• The 120-day statutory decision clock
• How this compares to FDIC, OCC, and Federal Reserve proposals
• Why “rewards vs. interest” could become the next regulatory battleground
• How the proposed CLARITY Act fits into the broader digital asset framework

This proposal represents one of the most significant expansions of NCUA supervisory authority in decades. While stablecoin issuance is optional, the regulatory guardrails are now taking shape.

Comments on the proposed rule are due 60 days after Federal Register publication.

If your credit union is considering digital asset innovation, payment modernization, or cooperative technology ventures, this episode outlines the strategic considerations.

Key Topics

• GENIUS Act stablecoin framework
• Subsidiary-only issuance requirement
• PPSI licensing process
• Capital and liquidity expectations
• CUSO structure implications
• Joint ownership models
• Regulatory cost recovery debate
• CLARITY Act market structure considerations

Why This Matters

Stablecoins are not insured shares.
 They are not backed by the full faith and credit of the United States.
 They cannot blur the line between payments and deposits.

Understanding these distinctions will be critical as the industry evaluates next steps.

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