NCUA Proposes 26 New Stablecoin Reporting Fields for Credit Unions from March 2027

Schedule J: 26 New Data Fields for Credit Union Stablecoin Activity

The National Credit Union Administration (NCUA) moved to fold credit union stablecoin business into routine quarterly reporting on October 9, publishing a proposed revision of the Call Report (Form 5300) that every federally insured credit union files each quarter. The proposed revision adds a dedicated schedule, Schedule J, covering payment stablecoin activity through 26 individual data fields. NCUA intends to apply the revised form and its instructions starting with the report for the quarter ending March 31, 2027, and the information collection would reach all 4,224 federally insured credit unions. The fields fall into four groups: custody of reserve assets, management and control of cryptographic keys, direct exposure to stablecoin issuers, and payment stablecoins held on the institution's own balance sheet. Custody items cover reserve assets held for authorized third-party permitted payment stablecoin issuers, while key-management items address controls over the credentials used to access digital assets. The line counts are uneven. Key management carries the most items at 9, reserve asset custody follows with 8, direct exposure to issuers has 5, and an institution's own stablecoin holdings account for 4. The design separates assets custodied for others, financial exposure to issuers and the institution's own positions, so examiners can see where a credit union actually carries stablecoin-related risk. Reserves back tokens in circulation, and redemption arrangements let holders exchange them for the reference currency, which is why reserve quality and redemption speed bear directly on whether a stablecoin holds its value. NCUA is taking comments on the usefulness of the data, the accuracy of its burden estimate and ways to reduce reporting work through automation until December 8, 2026. Comments received become part of the public record and accompany the agency's approval request to the Office of Management and Budget, which must clear the revised form before any of it takes effect.

The Third Step in the Credit Union Stablecoin Rulebook

The reporting proposal is the third piece of a supervisory framework NCUA has assembled since the GENIUS Act, the federal payment stablecoin law, came into force. The agency first proposed an application framework on February 11, 2026, under which entities could seek NCUA approval to operate as permitted payment stablecoin issuers. A second proposal followed on May 15, 2026, setting operational and risk-management standards for licensed issuers, with NCUA Chairman Kyle Hauptman pointing to alignment with the parallel standards proposed for bank subsidiaries. Schedule J extends that oversight past entry: instead of reviewing only applications and licensing conditions, the agency would track post-entry activity every quarter through the Call Report, a channel built for offsite supervision where most data, apart from sensitive items, is publicly released. On the burden side, the notice estimates 47 hours per response for the complete Call Report and 794,112 hours annually across all respondents, a figure NCUA raised after an April 2026 request for information on data-collection efficiency; the agency states the stablecoin additions do not materially change the existing estimate. Parallel work is underway on the banking side. The Federal Deposit Insurance Corporation approved proposed reserve and redemption requirements for bank-affiliated issuers on April 7, including one-to-one backing with eligible assets and a general two-business-day redemption standard, and on May 22 it advanced proposals covering anti-money-laundering and sanctions compliance for issuers in its jurisdiction. Commercially, Coinbase and payments-infrastructure provider Moov agreed on September 10 to connect Coinbase's stablecoin infrastructure with Moov's platform, whose client base spans more than 1,000 community banks and credit unions and supports payments, settlement, custody and funds movement.

From Entry Rules to Quarterly Oversight

Our reading of the sequence: with Schedule J, the credit union stablecoin rulebook reaches its supervision layer. Entry rules came in February, operating standards in May, and recurring data collection would now follow, meaning a credit union approved as an issuer, or merely holding issuer exposure, would surface in quarterly filings rather than only at examination time. The weighting of the new fields, 17 of 26 tied to custody and key controls, tells credit unions that third-party service arrangements are where regulators expect the risk to sit. The December 8 comment deadline and OMB review are the remaining procedural gates; approval would put the first stablecoin data in the mid-2027 reports, making stablecoin activity a standing line item in federal supervision rather than an ad hoc disclosure.