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CUNA Regulatory Comment Call

September 23, 2005

EXECUTIVE SUMMARY

• The NCUA Board has issued a proposal to reflect upcoming changes in the Financial and Statistical Report with NCUA, also known as the Call Reports or 5300 Reports. The new changes will require all federally insured credit unions to file the same quarterly Call Report. The abbreviated report that is currently filed in the first and third quarters by credit unions with assets less than ten million dollars will be eliminated.
• NCUA believes the abbreviated report is no longer needed because the revised report will simplify the reporting process for all credit unions, while also providing many benefits to NCUA.
• Comments are due by November 21, 2005. Please submit your comments to CUNA by November 14, 2005.

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Associate General Counsel Mary Dunn at mdunn@cuna.coop and to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.coop; or mail them to Mary and Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext. 6732, if you would like a copy of the proposed rule, or you may access it here.

BACKGROUND

NCUA proposes to revise the rules governing the filing of the Call Reports. Before they were revised in 2002, federally insured credit unions with assets over $50 million were required to file a quarterly report with NCUA. Smaller credit unions were permitted to file these reports semiannually. The 2002 revisions require that all federally insured credit unions file a quarterly Call Report, although credit unions with less than ten million dollars in assets have the option of filing a short form in the first and third quarters.

BRIEF DESCRIPTION OF THE PROPOSED RULE

The proposed rule will require all federally insured credit unions to file the same quarterly Call Report form, which has now been revised. The revised Form 5300 consolidates information, reduces the number of schedules, and is designed to be easier to read and used. NCUA plans to begin using the new form in September 2006. Because of these revisions, NCUA believes the current short form is no longer needed.

NCUA believes this new form will provide the following benefits for credit unions:

• It will have a consistent appearance for each cycle, which will eliminate confusion for smaller credit unions.
• The new form is shorter. It is 16 pages, as compared to the current 19-page form.
• It is designed so small credit unions will generally not have to complete the supporting schedules. Only the first ten pages require input by all credit unions. Although this is longer than the current eight page short form, NCUA believes the simplified format of the new form will reduce the burden of the slightly longer form.
• The number of schedules will be reduced from seven to three. The remaining three schedules will be Specialized Lending, Investments, and CUSO Information.

NCUA believes the new format will provide benefits to the agency. By eliminating the short form, NCUA only has to maintain one 5300 Form, which will improve efficiencies and reduce the likelihood of errors. NCUA also believes that the distribution of the form will reduce printing and mailing costs.

For a copy of the new Form 5300, click here.

• Do you agree that the new Form 5300 will provide the benefits to credit unions, as listed above, and is preferable to the current system in which smaller credit unions are able to file a short form in the first and third quarters?
  
  

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• Do you have any suggestions on how the proposed 5300 Form can be changed to further reduce burdens for credit unions, while providing NCUA with the information it needs?
  
  

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• Other comments?
  
  

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