WASHINGTON (10/27/15)--Data collection on credit union service organizations (CUSOs) would be better if collected during examinations or supervisory visits rather than through additional credit union reporting.
That’s what CUNA told the National Credit Union Administration and Office of Management and Budget (OMB) in response to a request for comments on revisions to OMB information collection.
Under the revisions, federally insured credit unions with an investment in, or loan to, a CUSO must obtain a written agreement with the CUSO addressing accounting, financial statements, audits, reporting and legal opinions.
According to the Federal Register notice, collection of this data would require roughly 4,116 respondents to respond, leading to an estimated 11,558 hours of burden at a total annual cost of $76,177.20.
“A better alternative for the agency would be to collect this information during an examination or supervisory visit and not require additional reporting by a credit union,” CUNA’s letter reads. “We believe this is a much less burdensome alternative that reduces the reporting burden on the public.”
The data collection falls under the OMB’s review and under the Paperwork Reduction Act of 1995. CUNA notes that this act is designed to ensure that the public, as well as the regulated entity, is not overburdened by data collection.
“In this instance where the purpose for the collection is questionable, at a minimum the act would demand the agency collect the information in the least burdensome manner possible,” CUNA’s letter reads.
Currently, all CUSOs are required to annually provide basic profile information to NCUA and the appropriate state supervisory authority. CUSOs engaging in certain complex or high-risk activities are also required to report more detailed information, including audited financial statements and customer information.