ALEXANDRIA, Va. — America’s Credit Unions is calling on the National Credit Union Administration to streamline its data collection and reporting requirements, arguing that a number of current reporting obligations are duplicative, confusing and unnecessarily burdensome for credit unions.
In a comment letter submitted in response to the NCUA’s request for information on enhancing and streamlining data collection, America’s Credit Unions said it supports the agency’s efforts to modernize its reporting framework but urged regulators to make a series of changes to the Credit Union Profile, Call Report and related reporting instructions.
The trade group said the Credit Union Profile currently requires extensive contact information, including home and work addresses, multiple email addresses and multiple phone numbers for credit union officials and staff. America’s Credit Unions argued that the NCUA should limit reporting to essential contact information and distinguish requirements for operational employees from those applicable to volunteer board members.
The Recommendations
Among its recommendations, America’s Credit Unions urged the NCUA to calculate and report a standardized efficiency ratio using data already collected through the Call Report and Financial Performance Report. The organization said credit unions currently calculate efficiency ratios independently, often using different methodologies, resulting in inconsistent reporting and additional work.
The group also recommended reducing manual data entry by introducing materiality thresholds that would allow minor discrepancies in Call Report fields without triggering system errors. According to the letter, even small rounding differences can require time-consuming revisions. America’s Credit Unions further suggested automatically populating summary totals from detailed schedules and allowing Call Report data to be reported in thousands rather than exact dollar amounts.
Reporting Challenges ID’d
The organization identified numerous areas where members have encountered reporting challenges, including inconsistencies involving Emergency Capital Investment Program reporting, Community Development Financial Institutions Fund grant reporting and Call Report requirements for lines of credit and credit cards. The letter further seeks clarification on the treatment of ECIP subordinated debt, pledged assets securing borrowing capacity, beneficiary and trust account reporting, and uninsured deposit calculations.
Call Report Revisions
America’s Credit Unions said several Call Report forms should be revised to improve clarity and eliminate redundancy. The organization questioned the usefulness of certain reporting requirements, including detailed reporting of realized investment gains and losses already captured elsewhere in financial statements and reporting of certificates of deposit exceeding $100,000.
It also asked the NCUA to update references to in-house electronic data processing to reflect widespread use of cloud-computing services.
Indirect Lending Clarifications
The trade group further requested clarification on definitions related to indirect lending, member business loans and commercial lending. It said confusion remains over whether credit unions should classify certain loans as indirect loans and whether institutions must look through purchased participations to determine how originating lenders classified those loans.
Critical of Loan Reporting Instructions
America’s Credit Unions also criticized a 2022 change to loan reporting instructions that requires increases in credit lines to be reported as new loans. The organization said the policy can result in the same outstanding balance being counted multiple times during a year and urged the agency to revise the requirement to avoid duplicate reporting.
Challenges Around CUSOs
The letter highlighted additional challenges involving CUSOs, including uncertainty over how warehouse lines of credit and other CUSO-related balances should be reported. America’s Credit Unions said clearer guidance would help institutions coordinate reporting and reduce interpretive challenges.
Clarity Around Delinquency Calculations
The organization also asked the NCUA to provide greater clarity regarding delinquency calculations, treatment of unfunded commitments, reporting of negative loan balances and the impact of varying month lengths on delinquency statistics.
Call Reports & GAAP
In addition, America’s Credit Unions urged the NCUA to better align Call Report requirements with U.S. generally accepted accounting principles, arguing that current reporting requirements for hedge accounting and derivatives create inconsistencies with accounting standards and add unnecessary operational burdens.
Clarification Around Schedule A
Finally, the trade group requested clarification regarding Schedule A’s requirement to report the most common interest rate offered, saying credit unions remain uncertain whether the figure should reflect all loans outstanding at the reporting date or only rates offered during the most recent quarter. The organization said clearer instructions would promote consistent reporting across the credit union system.
