While CUNA supports NCUA’s commitment to examination modernization, it cautioned the agency against a one-size-fits all approach in a letter sent Thursday. CUNA’s letter was in response to NCUA’s request for information (RFI) on electronic data collection modernization.
“CUNA recommends that any data collection proposal reconsider the impact that additional technology reporting and compliance would have on small credit unions’ ability to serve their members, keeping in mind the lack of negotiable power wielded toward vendors, the additional record-keeping and compliance costs involved, overall automation and manual file-keeping transfer requirements unique to smaller institutions, as well as limited personnel and staffing resources,” the letter reads. “Any mandatory one-size data collection effort, as outlined in the RFI, would be nearly insurmountable for the majority of America’s smallest credit unions.”
CUNA also noted that, given both the manually-intensive data migration efforts, and extensive information technology enhancements any new electronic data collection requirements would necessitate, a sufficient implementation timeframe is critical, and that any new requirements should apply prospectively, without retroactive application.