• Regulatory Advocacy Reports
• Comment Calls
• Comment Letters
• Final Rule Analyses
• NCUA Board Meetings
• Regulatory Advocacy Podcasts
• Additional Resources
• Regulatory Advocacy Home

CUNA Regulatory Comment Call

NCUA has recently issued a Letter to Credit Unions (99-CU-06) requesting comments regarding changes to the 1999 Call Report. The changes will not be implemented until September 1999 for credit unions with assets greater than $50 million and December 1999 for all other credit unions. Comments are due in late June but please have your comments to CUNA by June 11. Please feel free to fax your responses to CUNA at 202-371-8240; e-mail them to Jeffrey Bloch at jbloch@cuna.com; or mail them to CUNA’s Regulatory Advocacy, 805 15th Street, NW, Suite 300, Washington, DC 20005.

NCUA has indicated that most of the changes to the Call Report were mandated by Congress in the Credit Union Membership Access Act (CUMAA). Specifically, section 201 of CUMAA requires that reports filed with NCUA be consistent with generally accepted accounting principles (GAAP).

The following outlines the significant changes:

• The federal credit union and state credit union versions of the form were combined into a single form.
• The presentation of the Statement of Financial Condition and Income and Expense page was revised to comply with the GAAP reporting requirements of CUMAA.
• New data collection items were added regarding lease activities, cyber financial services, and borrowing arrangements.

The Letter to Credit Unions includes a list of 14 specific changes as well as a copy of the draft Call Report, which may be found on the NCUA website. Based on our preliminary review, the following are possible issues that we may want to comment on:

• Possible confusion that may arise between line #9 on page 1 of the draft Call Report and line #6 on page 8 because both items refer to "other investments."
• Whether moving the "NCUA Share Insurance Capitalization Deposit" item (line #25 on page 1 of the draft Call Report) from the "investments" section to the "other assets" section is required under GAAP (this is #6 on NCUA’s list of specific changes).
• The necessity of requiring information about credit union websites, which would not appear to implicate safety or soundness concerns (this is #11 on NCUA’s list of specific changes).

As you may know, we are in the process of collecting e-mail addresses from governmental affairs/regulatory affairs specialists at the leagues in order to expedite distribution of the Regulatory Comment Calls. If you have not already done so, please send your e-mail address to Brent Cantley at bcantley@cuna.com if you are interested in receiving the information electronically. Thank you.