The largest maximum civil money penalty a credit union couldreceive for filing its call report late this past quarter is$106,000, the NCUA said Monday.

Each of the 84 credit unions the NCUA determined did not have alegitimate reason for filing a late 5300 report received a letterwith a consent form that contained two figures.

The first dollar amount was the CMP that would have to be paidif the credit union signs a consent form. The second figure – alarger penalty – was the CMP due if the credit union does not signthe consent form and decides to argue its case in court before anadministrative law judge.

According to NCUA Director of Examination and Insurance Larry Fazio, the 84 credit unions were also given a third option:“Request reconsideration of the CMP due to an extenuatingcircumstance.”

The NCUA said the proposed CMP dollar amounts in each letterwere based on each credit union's asset size and number of days itscall report was late.

NCUA Board Chairman Debbie Matz said the proposed CMP would becut in half if the credit union signed the consentform.

“The civil money penalties ultimately could be onerous, but ifthe credit union decides to sign a consent decree, it's really whatI consider a minimum amount. Some credit unions are charged acouple hundred dollars,” she said at the NCUA's Chicago ListeningSession on Thursday. “We don't get the money. The money goes toTreasury. We're doing it because we need to do our job,” sheadded.

The largest maximum CMP included in the letters was $106,000 andthe smallest minimum CMP was $150, according toFazio.

“In between, there is a wide variety of dollar amounts dependingon each individual credit union's circumstances,” he said.

A credit union executive asked Matz at the Listening Session ifthe agency could implement a call report filing grace period forsmaller credit unions.

“We don't just automatically access civil money penalties,” Matzsaid. “First we go to the regions and have them find out if therewas an extenuating circumstance.”

Matz said an example of an extenuating circumstance would be aflood or electrical problem.

“So, even though we started with 104 credit unions that filedlate, we are actually down to 84 because there were 20 that hadreasonable reasons why they couldn't get it in on time,” Matzsaid.

“As far as the others respective of their size, we need to getthe data because if we don't get the data on time, we can't produceour reports on time. And when we can't produce our reports on time,we hear from the other regulators, and we hear from members ofCongress. They don't care how big the credit union is. They don'tcare what our issues are. They want the call reports on time,” sheadded.

Matz said penalties were a last resort for the agency. Sheadded that the FDIC typically has zero late filers.

“It just seems like we have been too lenient about it and we'retaking the flack for it so this seems to be the only way to get ourmessage through,” she said. “I'm sorry, it does seem harsh, butit's not something we wanted to do. We couldn't figure out anyother way to get our point across.”