NCUA official seal. (Source: NCUA)
In letters sent to the NCUA, both CUNA and NAFCU said they believe the agency's proposed changes to credit union Call Reports and the timeline of implementing the changes are "extremely problematic" and should be pushed back from early 2022 to later in the year, or even early 2023.
While NAFCU and CUNA support the NCUA's efforts to streamline and update the Call Report, the organizations said they believe there is not enough time for credit unions to make the proposed adjustments to the reporting process.
In a letter to the NCUA, CUNA stated, "We are concerned with the approach the agency has taken to inform the public of the impending changes to the Call Report. We believe notice through a (Paperwork Reduction Act) RFC is inappropriate and does not sufficiently alert the industry of the changes contemplated."
The letter added, "(B)ased on our research and review of (the) NCUA's Catalog of Account Code Changes, it is our understanding that the changes will be much more involved and that almost every page of the Call Report will be modified as a result of the restructuring."
In a similar letter sent to the NCUA on Friday, NAFCU's Regulatory Affairs Counsel James Akin wrote, "NAFCU urges the NCUA to provide credit unions with more time to evaluate and prepare for these significant changes to the NCUA's Call Report. NAFCU and its member credit unions support the NCUA's efforts to streamline the data collection process as well as reduce the regulatory burden and create cost-savings for credit unions."
Akin wrote that the NCUA has not provided sufficient communication to guarantee that the credit union industry will be ready to make these changes. Some of the proposed Call Report adjustments were introduced in late September.
"The most recent proposal contains completely new account codes that even the most prepared credit unions could not have expected. Credit unions should not be forced to rush to implement Call Report changes that have remained a mostly dormant subject since they were introduced four years ago," Akin stated in the letter.
While the NCUA has not officially set a date for Call Report changes, the agency has indicated that it could implement changes by March 2022.
"If correct, we believe such a timeframe would be extremely problematic. We believe a more appropriate deadline would be the third quarter of 2022," the letter from CUNA stated. "This would allow sufficient time for the core processors to implement the changes and for credit unions to conduct testing and training."
NAFCU asked the agency for even more time.
"The NCUA should postpone the effective date of the Call Report changes from March 2022 to January 2023 so that credit unions may adequately prepare for the impact to resources and staff," Akin wrote. "NAFCU urges the NCUA to continue to work to ease the burden on credit unions and their vendors while modernizing the Call Report."
In his letter, Akin suggested the NCUA update reporting requirements to include the following:
- Remove the $50,000 reporting threshold for member business loans or commercial loans to a single member.
- Remove the requirement to report first draws in a calendar year on revolving credit lines as new loans, regardless of the actual date of origination.
- Ensure that as many account codes as possible be auto-populated or auto-calculated to reduce the burden on credit unions.
The comment period for changes to the Call Report closed on Nov. 26.
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Michael Ogden
Editor-in-Chief at CU Times. To connect, email at [email protected]. As Editor-in-Chief of CU Times since 2016, Michael Ogden has led the editorial team in all aspects of content strategy and execution, including the creation of the publication’s exclusive and proprietary research database of the credit union industry’s economic landscape. Under Michael’s leadership, CU Times has successfully shifted to an all-digital editorial product with new focuses on the payments, fraud, lending and regulatory beats. Most recently, he introduced a data-focused editorial product for subscribers that breaks down credit union issues into hard data, allowing for a deeper and more factual narrative for readers. In 2024, he launched the "Shared Accounts With CU Times" podcast, which offers a fresh, inside-the-newsroom perspective through interviews with leaders from the credit union industry and the regulatory world. He dives into pressing credit union issues, while revealing the personalities working behind-the-scenes to push the credit union world forward. His background includes years as a radio and TV anchor/reporter and a public relations and digital/social media manager, where he covered the food and music industries, as well as cooperatives and credit unions. Over the years, he has launched numerous exclusive video and podcast series, including a successful series of interactive backstage interviews with musicians at music festivals, showcasing his social media and live streaming production skills.
