Call report revisions can reduce reg. burden, CUNA says

August 12, 2016

Revising call reports and Credit Union Profile can both enhance the NCUA’s supervisory ability and reduce regulatory burden on credit unions, CUNA wrote to the agency Friday.

As part of its examination and supervision modernization efforts, the NCUA requested input on the necessity and accuracy of the information collected, as well as ways to enhance the quality, utility and clarity of the collected information.

Friday’s letter follows CUNA’s letter sent earlier this month suggesting short- and long-term exam improvements.

CUNA conducted extensive outreach to its members to assist the NCUA in its reform efforts. CUNA’s call report requirements survey uncovered several concerns with the 5300 Call Report and the 4501A Profile Report.

Those include:

  • Limited Resources. 79% of respondents agree that filing requirements are a “big deal” and 44% agree that the reporting requirements are “very burdensome;”
  • Inadequate Support. Survey respondents often find the reporting process and systems difficult to understand and see significant gaps in support resources; and
  • Need for improvements. Credit unions see substantial room for improvement in call reports as well as in the reporting process. For example, 70% of survey respondents indicate that they believe that call reporting requirements should be changed to better reflect credit union size and complexity. And 64% agree that well-capitalized credit unions should be able to file abbreviated quarterly reports. Similarly, 52% agree that well-capitalized credit unions should be able to file reports less frequently.

CUNA suggests the following guiding principles for the NCUA to use when revising the call report and profile:

  • Revise the forms to make them intuitive and easy to use;
  • Only collect data that is accurate, relevant, and usable;
  • Collect data that more accurately reflects safety and soundness concerns;
  • Remove data that has little or no supervisory value or value to the industry for peer-to-peer comparison;
  • Remove data where the effort of collection outweighs the supervisory value;
  • Only collect new or additional data through the call reports if it results in an overall reduction in regulatory burden or an improved/more efficient exam;
  • Improve the clarity and descriptive quality of the instructions to the call report and profile documents; and
  • Eliminate odd-quarter reporting for any credit union below the $50 million asset thresholds that report a net worth ratio above 10%.