CUNA is concerned with the approach NCUA has taken toward impending Call Report changes and calls on the agency to extend the comment period on the proposed changes until at least mid-January. CUNA responded to an NCUA request for comments regarding the collection of information through NCUA Call Reports.

The letter also notes CUNA’s general support of NCUA efforts to streamline and update the Call Report.

“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 reads.

“[B]ased on our research and review of 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,” it adds.

It is CUNA’s understanding that NCUA may intend to have the Call Report changes implemented by the first quarter of 2022, a timeframe CUNA calls “extremely problematic.”

“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 reads. “This would allow sufficient time for the core processors to implement the changes and for credit unions to conduct testing and training.”