WASHINGTON–CUNA has sent a comment letter to NCUA in response to its request for comment regarding the Electronic Data Collection Modernization effort.
While CUNA said it supports the agency’s commitment to examination modernization, it stated in the letter, “The discussion subject to the Request for Information (RFI) on data collection, however, appears to apply a one-size-fits-all model to data collection that may be inappropriate for smaller credit unions, given the volume, quantity, and specialization of products and services offered, as well as technology resources and infrastructure constraints. CUNA recommends that any data collection proposal reconsider the impact that additional technology reporting and compliance would have on small credit unions’ ability to serve their members, keeping in mind the lack of negotiable power wielded toward vendors, the additional record-keeping and compliance costs involved, overall automation and manual file-keeping transfer requirements unique to smaller institutions, as well as limited personnel and staffing resources.
“Any mandatory one-size data collection effort, as outlined in the RFI, would be nearly insurmountable for the majority of America’s smallest credit unions,” CUNA added.
CUNA further stated it would “support a data collection system utilizing a Turbo Tax-style (or ‘Choose Your Own Adventure’ cataloging system) whereby a credit union could input data based on their specific needs. To the extent fields could be entirely categorized as non-applicable at the outset would also be useful.”
The full copy of the letter can be found here.