A year ago, in July 2025, President Trump signed the GENIUS Act into law to create a federal regulatory system for stablecoins. Since then, various federal agencies have issued Notices of Proposed Rulemaking (NPRMs) to hammer out the details of GENIUS Act implementation.

On July 16, Solari submitted comments to the National Credit Union Administration (NCUA), in response to the NCUA’s supplemental NPRM (“Standards Proposal”) implementing the standards and restrictions imposed by the GENIUS Act on permitted payment stablecoin issuers (PPSIs). The NCUA, created in 1970, is “an independent federal agency that insures deposits at federally insured credit unions, protects the members who own credit unions, and charters and regulates federal credit unions.”

Previously (in May-June 2026), Solari submitted comments responding to NPRMs issued by three Treasury Department agencies: an NPRM issued by the Office of the Comptroller of the Currency (OCC) and an NPRM jointly issued by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC).

The July comments to the NCUA address:

• Consumer-protection compliance standards related to preservation of cash and non-programmable payment options; guaranteed access to a non-programmable alternative; and prohibition on discrimination, viewpoint-based denial, and social-credit scoring
• Financial privacy and data protection
• Smart contracts, programmable restrictions, and due process
• Redemption integrity and delay notice
• Surveillance risk in supervisory reporting
• Protection of community credit union and bank deposit funding
• Clear disclosure of the absence of share insurance

In the letter’s conclusions, Solari reminds the NCUA that:

“A payments system that surveils, restricts, scores, and controls the financial behavior of individuals, however efficiently, is not a payments system that serves a free people. The NCUA has both the authority and the responsibility to ensure that the framework it establishes reflects this truth.”

You can read Solari’s comments to the NCUA here.

To stay informed about Solari’s legislative and regulator efforts to protect financial freedom, sign up to receive Financial Transaction Freedom email updates from Solari here and consider attending Solari’s monthly Financial Transaction Freedom briefings.