# PUBLIC COMMENT ON PROPOSED REGULATIONS: Investments in and Licensing of Permitted Payment Stablecoins Issuers

**Submitted by the Center for Federal Accountability (CFA)**  
**Document Number:** 2026-02868

## Executive Summary

The Center for Federal Accountability submits this draft comment to support timely public record participation while full model-backed legal analysis is queued. This draft identifies baseline accountability concerns and preserves key issues for agency consideration before the close of comments.

## Table of Authorities (to be finalized)

- Administrative Procedure Act (5 U.S.C. 551 et seq.)
- Agency enabling statute and implementing regulations (rule-specific citations to be finalized)

## Key Concerns

- The agency should clearly identify statutory authority for each material requirement in the proposal.
- The agency should provide transparent cost, burden, and implementation assumptions with reproducible methodology.
- The agency should address foreseeable operational risks and unintended consequences for regulated parties and the public.

## Preliminary Analysis

This preliminary draft is generated from the available Federal Register text excerpt below and is intended to preserve issues for the rulemaking record. A full model-backed CFA legal analysis can be substituted in a subsequent revision.

> Federal Register, Volume 91 Issue 29 (Thursday, February 12, 2026) [Federal Register Volume 91, Number 29 (Thursday, February 12, 2026)] [Proposed Rules] [Pages 6531-6552] From the Federal Register Online via the Government Publishing Office [ www.gpo.gov ] [FR Doc No: 2026-02868] ======================================================================== Proposed Rules Federal Register ________________________________________________________________________ This section of the FEDERAL REGISTER contains notices to the public of the proposed issuance of rules and regulations. The purpose of these notices is to give interested persons an opportunity to participate in the rule making prior to the adoption of the final rules. ======================================================================== Federal Register / Vol. 91, No. 29 / Thursday, February 12, 2026 / Proposed Rules [[Page 6531]] NATIONAL CREDIT UNION ADMINISTRATION 12 CFR Part 706 RIN 3133-AF69 Investments in and Licensing of Permitted Payment Stablecoins Issuers AGENCY: National Credit Union Administration (NCUA). ACTION: Proposed rule. ----------------------------------------------------------------------- SUMMARY: The NCUA Board (Board) is seeking comment on proposed regulations to implement portions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The GENIUS Act charges the NCUA with licensing, regulating, and supervising payment stablecoin issuers that are subsidiaries of federally insured credit unions (FICU subsidiaries). The GENIUS Act also requires the NCUA to issue implementing regulations by July 18th, 2026. This proposed rule proposes regulations to implement the statutorily required process for approval and licensure of permitted payment stablecoin issuers (PPSIs) subject to the NCUA's jurisdiction. It also proposes regulations limiting FICUs to investing in NCUA-licensed PPSIs. A forthcoming proposal will propose regulations to implement the standards and restrictions imposed by the GENIUS Act on PPSIs. DATES: Comments must be received by April 13, 2026. ADDRESSES: Comments may be submitted in one of the following ways. (Please send comments by one…

## CFA Recommendations

1. Publish a clear crosswalk from each proposed requirement to its statutory basis.
2. Expand and disclose the quantitative assumptions used in cost-benefit analysis.
3. Provide implementation alternatives and phase-in options to reduce compliance risk.
4. Extend or reopen comment if substantial updates are made after publication.

## CFA Contact

Center for Federal Accountability (CFA)  
8401 Mayland Dr # 7387  
Richmond, VA 23294  
policy@federalaccountability.com | https://www.federalaccountability.com/

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_Generated via cursor provider fallback at 2026-03-23T21:00:35.729694+00:00._