Removing Barriers Blog

CUNA Responds to NCUA's RFI on Electronic Data Collection Modernization
Posted December 21, 2017 by CUNA Advocacy

CUNA submitted a comment letter in response to NCUA’s Request for Information regarding Electronic Data Collection Modernization. While CUNA supports the agency’s commitment to examination modernization, CUNA cautioned against a one-size-fits-all approach that would have a disproportionately adverse impact on smaller credit unions with fewer personnel and information technology (IT) resources. Given both the manually-intensive data migration efforts, as well as extensive IT enhancements, that any new electronic data collection requirements would necessitate, CUNA noted that a sufficient implementation timeframe is critical, and that any new requirements should apply prospectively, without retroactive application.