WASHINGTON (2/23/11)--The National Credit Union Administration’s proposed changes to the low income credit union application process could be improved if the agency provided credit unions with a more detailed explanation of what should be covered in a credit union’s narrative and supporting materials, the Credit Union National Association (CUNA) said in a Tuesday comment letter. This explanation could be provided through a letter to credit unions, CUNA suggested. The NCUA proposal would permit federal credit unions to use "statistically valid" random samples of member income data to prove their low-income status to the agency. That member income data could be drawn from loan files or surveys. Credit unions would also include an analysis of these member data samples along with their applications. This is an alternative to the current approach, which uses the agency’s geocoding software. Current NCUA regulations require a credit union to show actual income data from a minimum of 50% of its membership, plus one additional credit union member as an alternative basis for qualifying as low-income. Under the proposal, NCUA would continue to use its geocoding software to determine a credit union’s low-income status; the software uses census data to determine the average income of a membership area. However, for credit unions that do not qualify as low-income according to the software, the proposal would provide them with the alternative option of providing sample member income data. CUNA said that it approved of the majority of the NCUA's plans, and added that including a timeframe for the NCUA to review submissions could be very useful to the review process and to the credit unions seeking NCUA’s decision. However, the timeframe should be both sufficient for NCUA to undertake a reasonable review and short enough to be responsive to the credit union, CUNA said.