Calls Go Out to Examine Call Reports
Melissa Green, controller for $153 million West Community Credit Union in O’Fallon, Mo., said she spends as much as 25% of her time completing NCUA 5300 Call Reports.
Given the depth and breadth of the 25-page quarterly report and its 104 pages of instructions, Green said she has to gather more information than she believes the regulator needs or, perhaps, knows what to do with. And it costs the credit union an estimated $20,000 annually in staff time and resources, Green said.
“I’m not really sure why they need this information,” said the 15-year credit union veteran who has been responsible for call report completion for the past six years.
Bill Kennedy, CFO for $150 million Interior Federal Credit Union in Washington, had the same concerns about time spent gathering and reporting what he considered to some degree superfluous data to the regulator.
“I really have no idea how long it takes me,” said Kennedy, who's been filing call reports for 25 years. “I do it piecemeal because I’d have to do a lot of it anyway.”
He also said he didn't understand the reason for much of the data reported and rarely does his examiner bring up the call report during exams.
“What do they need this information for?” Kennedy asked. “They want to know how many loans have been given to board members and staff. What does that have to do with anything?”
Kennedy estimated he spends about 30 hours per quarter at a cost of about $50 per hour, or $1,500 per report. But that's not the only price he pays, especially given potential penalties for inaccuracies and late submissions.
“How do you put a price on headaches and stress?” Kennedy asked.
NCUA spokesman John Fairbanks said the reports are integral to helping the agency monitor financial trends in credit unions in light of larger market trends.
The NCUA also uses the information to improve transparency into credit union operations, streamline examination processes, and gather data to satisfy requests from Congress, other agencies, the public and the media.
“NCUA continues to modernize the call report filing system and promote greater efficiency by building data and analytical reporting tools to assist us in surveillance of risks, conducting exams, developing insurance models and other activities essential to the agency's statutory responsibilities to monitor and mitigate risk in the credit union system,” Fairbanks said, “which in turn helps protect the deposits of more than 97 million credit union members.”
Meanwhile, major efforts have been made in regulatory reform in recent years, and lobbying for more is key at CUNA and NAFCU.
But call report reform specifically has not yet surfaced as a major area of emphasis among either trade group's lobbying efforts. However, as a reflection of the regulations and guidelines in place, call report content does come under scrutiny, according to Mike Coleman, NAFCU's director of regulatory affairs.
“Call reports are a concern that we raise with the agency if there are potential issues,” Coleman said. “We believe they should be kept manageable and reasonable.”
CUNA's position is much the same, said CUNA EVP Mary Dunn. “We’ve urged the NCUA to streamline the 5300 Call Report,” she said. “We’ve been very concerned about the issue of timely filing. We don't want the call report to be more onerous than it already is.”
However, a formal call report reform effort has not yet figured heavily on either CUNA's or NAFCU's regulatory reform agenda. It is usually seen as an adjunct to other regulatory reform efforts, but not its own initiative.
“I don't recall us ever asking NCUA about call report reform,” said Curt Long, NAFCU's senior economist.
Credit unions, it seems, don't necessarily expect call reports to be a major topic, either.
“I think CUNA and NAFCU have bigger fish to fry than wondering if one person is spending an extra 10 hours per quarter doing something they shouldn't have to do,” Kennedy said. “This would not be one of the top needs from my trade association. I’m not sure that's even their battle.”
The Independent Community Bankers of America believed otherwise. Call report simplification is considered critical to easing banks’ regulatory burden, one all too familiar to Terry Jorde, ICBA's senior EVP and chief of staff.
“In 1986, the call report for independent community banks was 18 pages long,” Jorde said. “By 2003 the report had grown to 29 pages and today is up to 80 pages with 570 pages of instructions.”
An ICBA survey in May got responses from nearly 700 respondents, who said that total hours dedicated to preparing the call report had increased for 73% banks in that time.
Jorde noted that a change to the call report process is within the purview of the regulatory bodies and does not require an act of Congress. “The survey results are loud and clear that banks are looking for relief. We already have been hearing from regulators and they’re eager to talk to us about this,” she said.
Could such a survey bear similar results for credit unions? CUNA aims to find out when it distributes its own recently drafted survey about the call report burdens facing credit unions.
Developed by Mike Schenk, CUNA's acting chief economist, the brief survey was designed to measure the impact of both NCUA's 5300 call reports and its credit union profile report, or Form 4501A. CUNA was encouraged to pursue this avenue based on NCUA comments made earlier this summer regarding a series of regulatory relief initiatives, according to Schenk.
“The survey will help us quantify those aspects of the report and reporting process that seem especially problematic. Most agree there is some low-hanging fruit here,” Schenk said.
Respondents were asked to grade 21 statements that relate to the ease and usefulness of completing call reports and whether well-capitalized credit unions should be allowed to complete short-form call reports.
The survey also asked what single, realistic change to quarterly reporting requirements would best reduce burdens associated with quarterly report for credit unions.
“We will make the results public in some form and also share our conclusions and recommendations with the agency,” Schenk said.
CFOs and CEOs in smaller credit unions would likely be asked to participate in the survey. State leagues also would be asked to participate, although their exact roles had not yet been defined, according to Schenk.
CUNA's survey would likely be distributed this month, according to Schenk.