Request for Information: Enhancing and Streamlining Data Collection from Credit Unions

Eastern Corporate Federal Credit Union (EasCorp) supports the NCUA's initiative to enhance and streamline data collection but urges a risk-focused approach to reduce redundant reporting burdens. They specifically advocate for consolidating duplicative data points, simplifying derivative reporting, and providing phased-in compliance timelines for any new changes.

Kinecta Federal Credit Union supports the NCUA's efforts to streamline data collection and provides specific recommendations to reduce manual reporting burdens. They suggest eliminating top-side entries for loan participation purchases and enabling secure API-based connectivity to allow for direct data submission from internal systems.

GoWest Credit Union Association, a regional trade association, supports the NCUA's initiative to streamline data collection but urges the agency to prioritize "safety and soundness" as the primary standard for data requirements. They advocate for minimizing form revisions, providing longer lead times for changes, and removing specific reporting requirements that do not contribute to supervisory goals, particularly for smaller credit unions.

America’s Credit Unions supports the NCUA's efforts to modernize and streamline data collection and provides specific recommendations to reduce regulatory burdens. They advocate for simplifying the Credit Union Profile, standardizing efficiency ratios, implementing materiality thresholds, and clarifying various reporting requirements in the Call Report to ensure consistency and accuracy.

GECU Federal Credit Union supports the NCUA's effort to streamline and enhance data collection, provided the focus remains on reducing manual reporting burdens and improving system functionality. The organization argues for clearer instructions, better automation, and a risk-based approach that tailors reporting requirements to the size and complexity of the credit union.

SchoolsFirst Federal Credit Union supports the NCUA's effort to streamline data collection and provides specific recommendations to improve efficiency. They suggest aligning reporting requirements with existing internal practices, such as using weighted average rates, and propose removing obsolete reporting sections to reduce the regulatory burden.

Corning Federal Credit Union supports the NCUA's efforts to streamline and improve regulatory reporting but argues that the current proposal still contains several burdensome and complex requirements. The credit union requests specific simplifications, such as eliminating the reclassification of small commercial loans as consumer loans and removing certain granular loan and share maturity reporting requirements.

The commenter, representing a credit union, provides specific feedback on streamlining data collection by identifying redundant questions in the Profile and suggesting ways to simplify loan classifications. They advocate for reduced reporting burdens, more accurate burden estimates based on asset size, and the creation of a centralized FAQ to improve clarity.

The Defense Credit Union Council (DCUC) supports the NCUA's initiative to streamline data collection but emphasizes the need for ongoing dialogue and comprehensive stakeholder engagement. They specifically recommend reviewing data points for necessity, eliminating duplicative reporting, improving instructions, and adopting a model that only requires reporting changes rather than repeated certifications.

A credit union employee argues that the current Call Report is overly complex and redundant, particularly regarding loan classifications and thresholds. They advocate for streamlining the data collection process to reduce the administrative burden on staff while maintaining the ability to assess the institution's stability.