Compliance Blog

On September 27, 2021, NCUA published a notice in the Federal Register regarding the Call Report. The notice is only about a page long, and is seeking comments on changes that include:

• Restructuring to streamline the report;
• Retire obsolete account codes; and
• Accommodate the Risk-Based Capital (RBC) ratio calculation schedule, including adding schedules for off-balance sheet exposures and the RBC ratio calculation.

NCUA is seeking comments on several things, such as whether these changes are necessary, if the information “will have practical utility,” and “ways to minimize the burden” of the collection. There are scant details though about the details of the changes that would help credit unions analyze and provide feedback. So, what is this all about?

NCUA first introduced plans to modernize its data collection processes during its May 2016 Board meeting. Later that year, NCUA issued a request for information to gather public input on the various data collected through the Call Report. This led to a modernization effort in 2018, although not much information has been published about the changes recently. This document summarizes some of the changes, and NCUA has more information on this webpage. NAFCU submitted comments in 2018, noting support for removing obsolete data points and the reorganization of the sections.

The various changes are summarized in a nearly 200-page document. Here are some examples of some codes that are labeled as new, and some that are labeled as being retired.

• New –  Total cash, cash equivalents, and other deposits;  information about deposits the credit union has with other financial institutions; other services provided by money service businesses; loan loss information by different product type such as charge offs and year to date recoveries; payday alternative loans; non-federally guaranteed student loans; new and used vehicle loans; loan delinquencies by collateral type and dollar amount of delinquencies; number of indirect loans; interest income year to date by various loan type; information about the credit union’s borrowing relationships; and more.
• Retired – various specific data points related to troubled debt restructurings (TDRs); transfer to regular reserves; interest rates on various loans; dividend rates on various categories of share accounts; various data points related to loan participations; the number of foreclosed and repossessed assets; and more.

Many other data points will be relocated to accommodate the restructuring of the Call Report. Many retired data points will still be reviewed during a credit union’s exam under this proposal.

The plan is for these changes to be effective for the March 2022 Call Report. NAFCU is seeking feedback from members on the timing of these changes, and there are more details that can be found in our Compliance, Risk and BSA Network (member-only).