Call Report Changes and RBC, CCULR
Hello compliance land, this is my first “official” compliance blog since joining NAFCU’s compliance team last week. For the past few years, I have worked on the Regulatory Affairs side and have previously blogged on NAFCU’s advocacy work, but I am very excited to join this team! NAFCU previously blogged on the proposed changes to the Call Report. The Office of Management and Budget approved changes to Call Report Form 5300 back in January which become effective during the March 2022 reporting cycle. NCUA has been seeking to modernize its data collection processes since 2016 with its “Call Report Modernization” project. The changes to the Call Report increased the number of schedules from five to eight.
Overall, the changes:
- Improve the organization of the Call Report to better align the reporting of related information;
- Revise the Call Report instructions;
- Add Risk-Based Capital (RBC) and Complex Credit Union Leverage Ratio (CCULR) schedules and associated fields to inform the RBC and CCULR schedules; and
- Reduce the quantity of data fields in the Call Report by as much as 18 percent.
Let’s take a closer look at the new Call Report schedules for CCULR and RBC.
Schedule H
Schedule H is a completely new schedule used to calculate CCULR. As a reminder, CCULR was finalized in December 2021 and became effective January 1, 2022. Is it just me, or when you read “CCULR” do you yell the lyrics from that Outkast song, “what’s cooler than being cool?” Another friendly reminder, CCULR is a voluntary, alternative measure of RBC for complex credit unions that meet certain minimum net worth requirements. Complex credit unions that are eligible do not have to adopt a CCULR framework and can opt in or out of CCULR at the end of each quarter. The CCULR final rule notes that complex credit unions do not need to provide advance notice of opting in or out of the CCULR framework; however, the NCUA flagged that “a credit union that frequently switched between CCULR and risk-based capital may raise supervisory concerns.” So, your credit union may not be completing Schedule H if you do not meet the eligibility requirements or choose not to use this alternative measure. In either of those cases, your credit union would need to complete Schedule I.
Regardless, all credit unions over $500 million in assets must answer question 1 in Schedule H, which asks if the credit union has an existing CCULR framework in effect as of the quarter-end report date. If you are a credit union with over $500 million in assets and do not have a CCULR framework, then you should mark “no” and fill out Schedule I.
Schedule I
Schedule I is a new schedule to calculate RBC, accounting for regulatory changes finalized. NCUA’s final RBC rule took effect on January 1, 2022. Credit unions with over $500 million in assets must complete Schedule I if they are not electing CCULR or do not qualify to use CCULR. Complex credit unions no longer need to formulate the previous Risk Based Net Worth (RBNW) calculation, as the final RBC rule superseded the RBNW calculation. As a reminder, capital adequacy and RBC implementation is a 2022 NCUA Supervisory Priority and the NCUA Letter to Credit Unions 22-CU-02 highlights that “NCUA examiners will review the accuracy of complex credit unions’ reporting for the new data elements required in the risk-based capital schedule of the Call Report.”
Other notable items:
- Schedule A now includes delinquency and charge-offs; the schedule separates commercial and consumer real estate loans; removes most troubled debt restructuring (TDR) codes and requires the total amount outstanding.
- No changes were made to the profile, or Form 4501A.
NCUA recognizes that it may take some time for credit unions to implement the changes in the Call Report or receive updated information from vendors. During the pandemic, NCUA temporarily paused any civil money penalties for late Call Report filings and has indicated in recent trainings that this pause would continue for the March 2022 reporting cycle. If you cannot meet the deadline on April 30th, you should notify NCUA as they will work with credit unions experiencing difficulties on a case-by-case basis.
Additional resources to assist with Call Report changes are located on NCUA’s website, including updated Form 5300 instructions and an on-demand webinar. NCUA’s Capital Markets division also has an on-demand webinar covering both RBC and CCULR. Check out our Compliance Blog on how CCULR affects member business loans.
If you have any questions, please reach out to me at kschafer@nafcu.org.