NEWPORT BEACH, Calif.–The National Association of Credit Union Service Organizations has told NCUA that efficiency should be the watchword as the agency seeks to gather input on CUSOs.
In a comment letter to the agency, NACUSO said it supports NCUA plans to build an Internet portal that will gather information, which it said is preferable to extensive paperwork reporting and is “certainly an alternative to unnecessary site visitation to merely gather data that can be submitted in other less obtrusive means.”
Separately, NACUSO is also asking the agency to extend the comment period, noting in its letter on the agency’s Information Collection Activities Request for Comment that it does not believe most interested parties were aware NCUA is seeking such comment. “It was not mentioned at an NCUA Board Meeting and it is not on the NCUA website,” said NACUSO. “We just recently became aware of it. So our first comment is that your Request for Comment has not reached the audience that would provide you valuable feedback so an extension of the comment period and more publicity seeking comment about the Request would be appropriate.”
That said, NACUSO wrote that the information requested is contained in the existing CUSO Regulation (Part 712) and does not appear to be an extension of the scope or authority per the terms of the CUSO Regulation. “Our comments on the substance of the revisions to the CUSO Regulation have been submitted during that comment period,” NACUSO said. “However, we do have comments pertaining to the CUSO Reporting regime in its entirety.”
Among those comments:
- NACUSO called on the agency to provide education and sufficient ramp-up time for credit unions and CUSOs to understand the process. Since the process is not yet implemented, it is difficult to respond to how long CUSOs will take to comply with the annual reporting duties, NACUSO said.
- Credit union owners of CUSOs and CUSOs themselves are “very concerned with the security of the information provided to NCUA,” said NACUSO. “Some of the information such as the name of the CUSO and the services provided by the CUSO are not sensitive information; however, financial information and client lists are confidential business information with a proprietary value that would be compromised by release. CUSOs and their credit union owners need to be assured that the confidential information is (1) protected by encryption and other electronic security measures from hackers, (2) not going to be carried around in thumb drives or laptops, and (3) protected from FOIA requests as confidential business information and as information incidental to the examination of credit unions. This is a crucial area of concern for CUSOs and their credit union owners and one that NCUA must address affirmatively.”
- Saying it understands that a CUSO that provides loans is considered a complex entity that is subject to enhanced reporting requirements, NACUSO said it is crucial that NCUA recognize and appreciate that – as it is presently proposed – the enhanced reporting requirement also applies to CUSOs that do not make loans but only assist credit unions in making loans to their members. “Since the loans appear on the credit unions’ books and not the books of the CUSO as lender, we question why such a CUSO has to be subject to enhanced reporting at all,” wrote NACUSO. “They are not the lender. NACUSO feels that it is unreasonable to require a CUSO to report on loans that the credit union makes and which are reported to NCUA through the 5300 Call Report of the credit union making the loan. Requiring duplicative reports from the CUSO is unnecessary regulatory burden and the type of approach that should be avoided by NCUA in the implementing of its CUSO reporting regime.”
The NACUSO letter was signed by president and CEO Jack M. Antonini.