DCUC Supports Proposed Stablecoin CIP Framework, Urges Regulatory Clarity for Credit Unions

WASHINGTON, D.C. — The Defense Credit Union Council (DCUC) has provided official comments on the joint agency proposed rulemaking issued by the Financial Crimes Enforcement Network (FinCEN), the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation, and the National Credit Union Administration (NCUA) (hereinafter, “the agencies”) to implement certain provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).  ​

“This rulemaking implements the GENIUS Act's directives to treat permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act (BSA) and to require issuers to maintain an effective customer identification program (CIP),” DCUC’s letter stated. 
 
“DCUC supports the agencies’ proposed framework for establishing CIP requirements applicable to PPSIs. The GENIUS Act appropriately requires PPSIs to be treated as financial institutions for purposes of BSA and to maintain effective CIP procedures. Robust and appropriately tailored requirements are important to protecting the financial system from money laundering, terrorist financing, fraud, and other illicit financial activity. At the same time, DCUC urges the agencies to ensure that the final rule remains risk-based, operationally workable, and appropriately tailored to avoid unnecessary duplication for financial institutions that are already subject to comprehensive federal or state regulatory and BSA and anti-money laundering (AML) requirements.” 
 
Within its comments, DCUC recommended the agencies: 
 

• Explicitly include credit unions in the financial-institution exclusion: DCUC supports excluding regulated financial institutions from the PPSI CIP definition of “customer,” but asks the agencies to expressly state that this includes both federally chartered credit unions regulated by NCUA and state-chartered credit unions supervised by state authorities. DCUC voiced that credit unions already face comprehensive BSA/AML, CIP, and CDD requirements, making duplicative PPSI procedures unnecessary. 

• Support flexible, risk-based CIP standards: DCUC supports requiring PPSIs to maintain written CIPs tailored to their size, complexity, products, services, customer base, and risk profile rather than imposing a one-size-fits-all approach. 

• Allow enterprise-wide compliance programs: DCUC encourages the agencies to confirm that affiliated entities can satisfy CIP obligations through a coordinated or unified enterprise-wide CIP where appropriate, reducing unnecessary duplication while maintaining effective compliance. 

• Preserve flexibility in identity verification: DCUC strongly supports allowing PPSIs to use risk-based approaches and determine when documentary, non-documentary, or combined verification methods are appropriate. 

• Retain the “reasonable period of time” standard: Rather than imposing a fixed deadline for identity verification, DCUC recommends maintaining flexibility so PPSIs can account for differences in verification methods, available information, and individual circumstances. 

 
“DCUC appreciates the agencies’ efforts to establish a strong and appropriately tailored CIP framework for PPSIs and looks forward to continued engagement as the regulatory framework develops further,” wrote Jason Stverak, DCUC Chief Advocacy Officer, on behalf of DCUC.