WASHINGTON—CUNA has filed a comment letter with NCUA over its efforts to streamline the examination and supervisory process and identified areas it would like to see addressed.
CUNA sent a letter to the agency in response to NCUA’s request for information on call report/profile content modernization.
CUNA’s congratulated NCUA for convening working groups to address call report improvements, which allowed for significant outreach and feedback, resulting in a proposed rule that requires little significant alteration prior to adoption, which it believes is an effective method to model for future rulemakings.
Other highlights of the letter include:
- CUNA said it welcomes the retirement of impertinent account codes and deletion of irrelevant data metrics, such as interest rate reporting.
- CIMA said it would also would like to see more fields pre-populated, such as the prototype Schedule FC-R, PCA Net Worth Calculation Worksheet
- CUNA suggested a one-year timeline to permit for information technology updates, along with an additional two quarters whereby late filings or non-material reporting errors would not be subject to penalty, particularly for smaller credit unions
- The trade group said detailed instructions on new reporting obligations, such as the Risk-Based Capital Worksheet, Schedule FC-T, would be useful. In addition, 5300 instructions should be consistent with those found on the online portal
- CUNA said credit unions have reported that it would be helpful if the agency would conduct periodic training sessions, including related to new compliance requirements, such as for Current Expected Credit Losses and Risk-Based Capital