In a letter to the House Financial Services Subcommittee on Digital Assets, Financial Technology, and Artificial Intelligence (yes, that’s a mouthful), DCUC laid out exactly what credit unions need to actually compete in the emerging digital asset space. And it’s not a small ask, because it’s not a small problem.
Why This Matters More Than You Think
DCUC represents over 200 credit unions serving more than 40 million members — including active-duty servicemembers, veterans, National Guard and Reserve members, DoD civilians, and military families. Nationwide, credit unions serve about 145.8 million members total. That’s a lot of people who could get left behind if the rules only work for big banks and tech giants.
“The future of finance cannot be reserved for the largest banks and technology platforms,” said Anthony Hernandez, DCUC President and CEO. “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.”
Translation: Your credit union should be able to offer you the same digital asset services as Chase or PayPal, assuming those services are legal and properly regulated. A credit union charter shouldn’t become a disadvantage just because Congress wrote rules with only big banks in mind.
What Credit Unions Are Actually Asking For
The letter supports provisions already in the Senate version of the bill that would let federal credit unions use digital assets and blockchain technology to deliver services they’re already allowed to provide. We’re talking about things like digital asset custody, staking services, crypto-backed loans, payments, running blockchain nodes, offering wallet software, and brokerage services.
But as Jason Stverak, DCUC Chief Advocacy Officer, put it: “Permission on paper must become access in practice.” In other words, it’s great if the law technically allows credit unions to do this stuff, but if the actual implementation makes it impossible or prohibitively expensive, what’s the point?
Credit unions aren’t asking for special treatment. They’re asking for genuine regulatory parity — the same playing field everyone else gets.
The Seven-Point Playbook
DCUC’s letter includes seven specific recommendations for Congress. Here’s the breakdown:
1. Keep Credit Union Authority Future-Proof
The law should be technology-neutral so credit unions don’t get locked out of future innovations just because Congress didn’t specifically name a particular protocol in 2025. Finance moves fast — the rules need to keep up.
2. Give the NCUA a Proper Seat at the Table
The National Credit Union Administration should be explicitly named as the primary federal regulator for credit unions in this space. They should be included in consultations, joint rulemakings, supervisory coordination, and advisory bodies. Otherwise, credit unions become an afterthought.
3. Include Credit Union Service Organizations
CUSOs are how credit unions pool resources and share services. They should be expressly permitted to support custody, wallets, settlement, compliance, brokerage, and other digital-asset services under appropriate oversight. Credit unions can’t all build this infrastructure alone.
4. Set Workable Custody and Consumer Protection Standards
Digital assets held in custody should be segregated, bankruptcy-remote, and protected by strong security controls. Consumers should get clear disclosures that their crypto isn’t insured like their savings account. But these standards need to be realistic for institutions of all sizes, not just megabanks.
5. Make Compliance Risk-Based, Not One-Size-Fits-All
Requirements should reflect an institution’s actual size, complexity, and risk profile. And Congress should give credit unions at least 18 to 24 months after final rules drop to implement everything, with model policies, examiner training, technical assistance, and safe harbors for good-faith efforts.
6. Guarantee Equal Infrastructure Access
Credit unions should get access to tokenized-settlement and digital-payment systems on the same terms as banks. No second-class treatment. They should also be able to participate in regulatory sandboxes and innovation programs — those aren’t just for fintech startups.
7. Get Stablecoin Rules Right
Payment stablecoins should work like payment instruments, not deposit substitutes that pay yield. The final legislation should prevent stablecoins from functioning as high-yield checking accounts while still allowing transaction-based rewards and ensuring credit unions can participate under NCUA oversight.
Why Military Families Are Watching Closely
This isn’t just abstract policy stuff. For military and veteran communities, digital financial services are genuinely practical. Servicemembers and their families move constantly, deploy overseas, and often live far from physical branches. Secure digital payments and settlement services can dramatically improve access to financial services.
“Financial readiness is inseparable from mission readiness,” Hernandez said. “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.”
The point is simple: innovation should work for everyone, not just people who bank with institutions that have massive compliance budgets and D.C. lobbying teams.
What Happens Next
DCUC will keep working with Congress, the NCUA, state regulators, and other federal financial agencies to hammer out technical language that protects consumers, enables responsible innovation, and lets every type of financial institution compete under clear, equivalent standards.
The letter was submitted ahead of a July 17 field hearing in New York called “Building the Future of Finance: How the CLARITY Act Unlocks Innovation,” and DCUC requested inclusion in the hearing record. Whether lawmakers listen remains to be seen, but credit unions just made it very clear: they’re not sitting this one out.