GAC Coverage: NCUA Announces Call Report Data on OD/NSF Income Will be Confidential

WASHINGTON–NCUA has announced that Call Report Data related to overdraft income collected by credit unions will now be confidential.

There has been considerable scrutiny of credit union OD/NSF income and its collection since NCUA announced it would begin doing so last year for credit unions of more than $1 billion in assets.

In January of this year, under then Chairman Todd Harper, the agency released a Research Note that provided an analysis of statistics for overdraft and non-sufficient funds fees, and observations on the relationship between overdraft and non-sufficient funds fees and other revenues.

Under the previous data collection policy, the NCUA required federally insured credit unions with more than $1 billion in assets to disclose, separately, income from overdraft and non-sufficient funds fees. The data was available to the public on an individual basis and in the aggregate. Under the new policy, which goes into effect with the March 31, 2025, Call Report cycle, NCUA said it will collect overdraft and NSF fee data as part of the examination process and we will continue to publish overdraft and NSF fee income data in the aggregate once updates to its examination system are complete.

“Our regulatory framework should protect consumers from predatory practices without depriving them of the financial tools they need to navigate their lives,” Hauptman said in a statement . “The appropriateness of overdrafts and NSF fees charged is a matter between a credit union and its member-owners who ultimately determine how their credit union is run.”

The change in policy was announced by Hauptman during America’s Credit Unions GAC. 

(A week after the announcement, the two other members of the NCUA board issued statements objecting to the change.)

‘Unintended Consequences’

“There is a well-intentioned movement aimed at protecting consumers from excessive fees, which is something we all support,” Hauptman said. “However, we must also consider the unintended consequences of such policies. In this instance, the previous data collection policy incentivized credit unions to avoid serving the needs of low-income and underserved communities. These fees can be the best option in a bad situation, saving money and protecting individuals’ credit scores. Overdraft also protects people from much higher costs imposed by their local governments.

“Our regulatory framework should protect consumers from predatory practices without depriving them of the financial tools they need to navigate their lives,” Hauptman continued. “The appropriateness of overdrafts and NSF fees charged is a matter between a credit union and its member-owners who ultimately determine how their credit union is run.”

Trade Group Objects

America’s Credit Unions had previously raised what it called “concerns” about reporting and publicly publishing data from overdraft and non-sufficient fund fees since the NCUA made the requirement last year. The trade group further called on the agency to use a “more transparent process” for changes to call reports to ensure credit unions “have reasonable time to review, provide feedback, and implement the changes.”

‘Consequential Misunderstandings’

“Credit unions offer overdraft programs in safe, clearly disclosed terms to members who may need help to make ends meet, but having this data publicly accessible could lead to consequential misunderstandings. America’s Credit Unions thanks Chairman Hauptman for hearing the concerns of credit unions and moving to protect institutions from reputational harm,” said ACU President/CEO Jim Nussle in a statement. “We look forward to continued collaboration on issues that ensure credit unions remain consumers’ best option for financial partners.”

What NCUA Found

Beginning with the first quarter of 2024 Call Report, the largest federally insured credit unions with more than $1 billion in assets were required to submit their year-to-date revenues from overdraft and NSF fees. 

The Research Note highlights two findings, according to NCUA:

  • Credit unions with higher combined overdraft and NSF fees per member do not seem to have lower fees per member for other services.
  • Credit unions with higher combined overdraft and NSF fee revenues do not seem to be using those fees to “subsidize” better interest rates.

The full NCUA findings can be found here:://ncua.gov/newsroom/press-release/2025/ncua-releases-research-note-overdraft-nsf-fees-credit-unions

Issue of Inclusion

Separately, Hauptman discussed with GAC attendees what he called “true financial inclusion,” which means removing barriers to de novo credit unions and removing the ‘pain points’ that have led to fewer small credit unions.

​“The NCUA must ensure our regulatory burden is not a factor in a credit union’s decision to merge away,” he said in a statement. “Once those credit unions are gone, rarely does anyone come to fill their place. Relieving the regulatory burden on credit unions, especially the small and newly formed ones posing relatively low risk to the Share Insurance Fund, is vital to keeping these credit unions thriving now and in the future.”

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