DCUC Urges Congress to Guarantee Credit Union Access and Parity in Final CLARITY Act

Letter calls for explicit NCUA authority, CUSO inclusion, workable custody standards, proportional compliance, and equal access to digital-payment infrastructure.

WASHINGTON, DC– The Defense Credit Union Council (DCUC) today sent a letter to Chairman Bryan Steil and Ranking Member Stephen F. Lynch of the House Financial Services Subcommittee on Digital Assets, Financial Technology, and Artificial Intelligence. The letter was submitted ahead of the Subcommittee’s July 17 field hearing in New York, “Building the Future of Finance: How the CLARITY Act Unlocks Innovation,” and requests inclusion in the hearing record.

​DCUC urged Congress to ensure that the final Digital Asset Market Clarity Act establishes a safe, workable, and competitively neutral pathway for credit unions to offer lawful digital-asset products and services. DCUC represents more than 200 defense-affiliated credit unions serving over 40 million members worldwide, including active-duty servicemembers, members of the National Guard and Reserve, veterans, Department of Defense civilians, and military families.

Nationwide, federally insured credit unions serve approximately 145.8 million members. DCUC emphasized that those consumers should be able to access responsible digital-asset services through the same trusted, member-owned institutions where they save, borrow, make payments, and receive financial guidance.

“Congress has an opportunity to establish rules that protect consumers while preserving competition, choice, and responsible innovation,” said Anthony Hernandez, DCUC President and CEO. “The future of finance cannot be reserved for the largest banks and technology platforms. Credit union members including servicemembers, veterans, and military families should be able to access lawful digital-asset services through the trusted, member-owned institutions that already understand their financial needs. A financial institution’s charter should never become an artificial barrier to serving its members.”

The letter supports preserving and strengthening credit union provisions of the Senate reported version of H.R. 3633. That provision would expressly permit federal credit unions to use digital assets and distributed-ledger systems to deliver activities, products, and services they are otherwise authorized to provide. It also establishes parallel treatment for federally insured, state-chartered credit unions, subject to applicable state law.

These provisions identify a range of permissible activities, including digital-asset custody and safekeeping, staking-related services, digital-asset lending facilitation, loans collateralized by digital assets, payments, distributed-ledger node operation, self-custodial wallet software, brokerage and execution services, and customer-directed secondary-market transactions.

“Permission on paper must become access in practice,” said Jason Stverak, DCUC Chief Advocacy Officer. “The final legislation should explicitly name the NCUA, include credit union service organizations, provide workable custody and accounting rules, calibrate compliance obligations to actual risk, and guarantee equal access to digital-payment and settlement rails. Credit unions are not asking for preferential treatment. We are asking Congress to ensure genuine regulatory parity.”

DCUC’s letter recommends that Congress:

• Preserve and future-proof credit-union authority. Section 401 should remain technology-neutral so that future services functionally equivalent to otherwise permissible credit-union activities are not prohibited merely because Congress did not identify a particular protocol or delivery mechanism.
• Explicitly recognize the NCUA and state credit-union supervisors. The final bill should name the National Credit Union Administration as the primary federal prudential regulator whenever federally insured credit unions are implicated and include the NCUA in relevant consultations, joint rulemakings, supervisory coordination processes, and advisory bodies.
• Include CUSOs and shared-service models. Credit Union Service Organizations and other collaborative arrangements should be expressly permitted to support custody, wallet, settlement, compliance, brokerage, and other authorized digital-asset services under appropriate federal and state oversight.
• Establish workable custody and consumer-protection standards. Digital assets held in custody should be segregated, bankruptcy-remote, and subject to strong reconciliation, cybersecurity, key-management, recovery-planning, and third-party risk-management controls. Consumers should receive clear disclosures that digital assets are not credit-union shares and are not insured by the National Credit Union Share Insurance Fund.
• Adopt risk-based compliance and a realistic implementation period. Requirements should reflect an institution’s size, complexity, transaction volume, delivery model, and actual risk exposure. Congress should provide at least 18 to 24 months after final rules for implementation, supported by model policies, examiner training, technical assistance, pilot programs, and appropriate good-faith safe harbors.
• Guarantee infrastructure and innovation access. Similarly situated credit unions should receive access to lawful tokenized-settlement and digital-payment rails on terms no less favorable than banks. Credit unions and CUSOs should also have a meaningful opportunity to participate in federal regulatory sandboxes and innovation programs.
• Preserve stablecoin safeguards while allowing credit-union participation. Payment stablecoins should function as payment instruments rather than synthetic deposit substitutes. The final legislation should prevent direct and indirect yield paid solely for holding stablecoins while allowing bona fide transaction-based rewards and ensuring that eligible credit unions and CUSOs can participate under NCUA oversight.

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The letter also highlights the practical importance of digital financial services for military and veteran communities. Servicemembers and their families are frequently mobile, deployed, or located far from a physical branch. Secure, well-regulated digital payments and settlement services can improve access while allowing defense credit unions to pair technological innovation with financial education, fraud monitoring, member support, and prudential oversight.

“Financial readiness is inseparable from mission readiness,” Hernandez added. “As financial services evolve, military and veteran families deserve access to modern tools delivered with strong safeguards, clear disclosures, and the personal support credit unions are known for. Congress should ensure that innovation strengthens the cooperative financial model rather than leaving millions of credit union members behind.”
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DCUC will continue working with members of Congress, the NCUA, state credit-union supervisors, and other federal financial regulators to develop technical language that protects consumers, promotes responsible innovation, and allows every financial charter to compete under clear and equivalent standards.