May 10, 2013
Tracy Crews
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314
RE: NCUA-2013-0018; NCUA Information Collection Activities
Dear Ms. Crews:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I am writing you regarding the National Credit Union Administration’s (NCUA) request for comment on its submission to the Office of Management and Budget (OMB) for review and clearance of certain changes to the Credit Union Profile and the 5300 Call Report. See 78 Fed. Reg. 15382 (March 11, 2013).
Changes to Profile
NCUA is seeking to make a number of changes to existing questions in the Credit Union Profile, as well as add new questions.
At the outset, NAFCU notes that the Credit Union Profile form has gradually expanded to require credit unions to provide a significant amount of information, and the increased data collection has long reached unjustifiable levels. Thus, we urge the NCUA to review the profile form carefully and remove unnecessary components.
For the June 2013 version, the NCUA proposes to make a number of amendments to existing portions while also adding several new questions. We would like to address two specific items.
First, the NCUA proposes to require credit unions to report the name of the audit firm or auditor the credit union uses for its financial statement audit. The agency, however, does not provide any justifications for requiring this disclosure. Unless the NCUA provides such justification, we would urge that this line item is removed from the June 2013 Call Report.
The NCUA also seeks to make changes to recently-added questions on credit unions’ diversity policies and EEO-1 Survey Report. NAFCU recognizes that the NCUA is seeking such information to fulfill its obligations under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) to assess “the diversity policies and practices of entities [the NCUA regulates]”. See Dodd-Frank Act § 342(b)(2). However, we continue to believe that the NCUA can fulfill this Dodd-Frank Act objective without adding to credit unions’ already steep burden related to data collection. If the NCUA insists on taking the approach of collecting data, the NCUA should at the very least make technical changes to ensure the proposed question 13 and its sub-sections do not create unnecessary confusion. Specifically, the criteria to which the question refers should be directly following the question, rather than after the two subsections.
Changes to Call Report
The NCUA also proposes to make a number of changes to the 5300 Call Report. While we do not object to any particular proposed change (in fact, some changes should make reporting of the particular item in question easier), we strongly urge the agency to ensure that the corresponding instructions are clear and precise so as to leave no doubt about what the line item entails.
NAFCU appreciates the opportunity to share our comments. Should you have any questions or require additional information please call me at (703) 842-2268.
Sincerely,
Tessema Tefferi
Senior Regulatory Affairs Counsel
cc: OMB, Desk Officer for the NCUA