WASHINGTON (9/3/13)--Rather than moving ahead with a proposal to require electronic filing by all credit unions, the National Credit Union Administration should instead encourage credit unions to move toward electronic filing in a reasonable time, with a new rule, the Credit Union National Association said in an Aug. 30 comment letter to the agency.
Comments are due to the agency Sept. 3.
Currently, credit unions can file reports manually or electronically. At its July open board meeting, the NCUA proposed to drop the manual reporting option.
"It seems unlikely that the manual filings of 59 small credit unions place any kind of significant burden on NCUA's resources," CUNA wrote, adding that those 59 should be given time to come into conformity appropriate to their individual situations.
As noted by CUNA's Deputy General Counsel Mary Dunn, "If a formal rule on this subject is truly necessary, however, it should be flexible enough to allow credit unions that cannot for good reason file electronic reports to continue filing manual reports for a reasonable period of time, say up to nine months."
CUNA also suggested that the agency's Office of Small Credit Union Initiatives, if it is not already doing so, work with the state credit union leagues to identify these small credit unions so that they can receive additional assistance to file reports electronically.
Dunn backed a recommendation of Self-Help CU, endorsed by the North Carolina Credit Union League, that the NCUA change the required filing date for call reports to 30 days after quarter-end.
"We think this is a very sensible idea, and such a deadline would provide more flexibility for all insured credit unions," Dunn wrote.
Use the resource link to access this and other CUNA Comment Letters.