Mahon said the “Annual Certification and Data Collection Report Form” requests duplicative information.

“For regulated CDFIs, the proposed report form requests some data already reported to other federal agencies and other data that cannot be reconciled with the detailed requirements of regulatory authorities,” Mahon's letter said. “Inconsistent data points could not only create repetitive or duplicative work but also present considerable room for error.”

Mahon disputed Treasury's three-hour time estimate for completion of the report form.

“The estimate of three hours to complete this form is not accurate and ignores the significant financial costs that would be incurred before the reporting could be undertaken at all. We estimate that the average credit union would need to invest at least 200 staff hours to prepare to complete the first annual report,” Mahon wrote.

“Subsequent reports would vary depending on the size and complexity of the credit union, but due to the complexity of the requested transaction analysis, large credit unions could easily be expected to devote more than 200 hours to the production of this report on an annual basis,” she also wrote.

Mahon said the proposed reporting requirements would cost credit unions between $10,000 and $50,000 depending on the size of the institution.

“The financial costs also would vary by credit union, but adaptations to core processing systems and associated training expenses typically range from between $10,000 for small credit unions to $50,000 or more for medium and larger credit unions,” she wrote.

Mahon, former deputy commissioner at the NYC Department of Consumer Affairs, recommended some changes the CDFI Fund could make to minimize the reporting burden and associated costs of the proposal.

Recommendations include using call report financials, as well as the operational and loan reporting categories and definitions used by federal banking and credit union regulatory agencies.

Mahon also suggested the CDIF Fund eliminate the requirement that CDFI banks and credit unions resubmit financial and operation data already sent to other federal regulatory agencies.