NCUA devotes 17 of its 26 proposed stablecoin Call Report fields to custody

Multiply 4,224 federally insured credit unions by four quarterly filings and then by 47 hours, and you get 794,112, the exact annual figure in NCUA's notice ^[7][17]. The estimate counts every filer the same way, whether it has a stablecoin business or not, and the agency states that the new schedule would not materially affect it ^[8]. NCUA attributes the higher 47-hour figure to public feedback on data collection. It is asking commenters how automation or other technology could reduce the reporting work ^[8][16].

Seventeen of the 26 lines concern custody, or rather two kinds of it: eight on reserve assets safeguarded for authorized third-party issuers and nine on custody and control of cryptographic keys ^[1][2][4]. That puts about 65% of the schedule on custody ^[18]. Five lines cover financial exposure to issuers, and four cover payment stablecoins on the credit union's own balance sheet ^[3]. We think the weighting shows where NCUA expects the risk to sit: in assets a credit union holds for someone else. The schedule keeps those separate from issuer exposure and from the institution's own holdings ^[12]. The counter-reading is simpler. Custody may just take more lines to describe, and a count of fields does not measure how many credit unions will offer it.

One way in for a small credit union is through a vendor. Coinbase's Sept. 10 agreement with Moov would connect Coinbase's stablecoin infrastructure to Moov's payment platform, whose customer base runs to more than 1,000 credit unions and community banks ^[14]. The link is meant to handle custody as well as settlement, payments and funding ^[14]. The published account of the proposal does not say whether custody held through a vendor of that kind would be reported on the credit union's Schedule J.

The schedule extends NCUA's work under the GENIUS Act. On May 15 the agency proposed operational and risk management standards for licensed issuers, and Chairman Kyle Hauptman emphasized alignment with proposed standards for bank subsidiaries, according to Bitcoin.com News ^[13]. The FDIC's April 7 proposal for bank-affiliated issuers set one-to-one backing with eligible assets and a general requirement to meet redemptions within two business days ^[15]. NCUA's new fields are meant for offsite supervision, so examiners can assess the activity from submitted data ^[9].

In our view, a credit union that intends to hold reserves or keys has until March 31, 2027, the first reporting date NCUA has targeted, to get those records complete ^[5]. We would be wrong if few credit unions take on custody at all, so that the custody lines sit at zero across the sector. We would also be wrong if custody held through vendors keeps the records off credit unions' books.