Submission to the National Credit Union Administration

GENIUS Act Comment Letter — PPSI Licensing

Regulator
National Credit Union Administration (NCUA)
Date filed
Filed by
Auditchain Labs AG
Federal Register citation
91 FR 6531
Docket ID
NCUA-2025-1335
RIN
3133-AF69
Responding to
Investments in and Licensing of Permitted Payment Stablecoins Issuers

Summary

Responding to the NCUA's proposed rule on PPSI investment and licensing, this focused comment made two principal recommendations: that applicants under proposed § 706.105 disclose BNP activities as part of the application's description of related activities, and that the NCUA adopt XBRL-based structured data for application submissions in coordination with the FDIC, OCC, and Federal Reserve. It supported the joint-application structure, urged a cross-agency mutual recognition framework for PPSI licenses to avoid disadvantaging credit unions, and addressed the selective application of Part 712 CUSO requirements. The letter noted that, unlike the banking agencies, the NCUA does not yet operate XBRL reporting infrastructure making this rulemaking its first opportunity to adopt the standard and harmonize with the Financial Data Transparency Act.

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