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ALEXANDRIA, Va.-While CUNA and NAFCU expressed their support for the flexible examination schedule in conjunction with quarterly 5300 reporting, both wrote in official comment letters that smaller credit unions need additional flexibility. The trade associations pointed out that the new exam schedule would have benefits not only for credit unions, but also for the agency. “NAFCU believes both the risk based examination schedule and the risk focused examination approach will greatly reduce the burden of examinations on both credit unions and the agency, while allowing NCUA to focus examination efforts on credit unions that need additional attention,” NAFCU President and CEO Fred Becker wrote in the group’s official comment letter. CUNA Associate General Counsel Mary Dunn agreed, writing, “By extending the examination schedule for healthy federal credit unions, NCUA will be able to focus resources on problem areas and should be able to achieve reductions in the agency’s budget.” CUNA has been working to help develop a 5300 EZ form for smaller credit unions, which would whittle down unnecessary work for less complex credit unions. “A number of [small credit unions] have expressed to us their apprehension about the additional burden they would shoulder if reporting requirements are expanded from two to four each year,” Dunn wrote. Additionally, CUNA suggested that NCUA color-code the form so credit unions would be directed to exactly what they need to answer or facilitate electronic filing of 5300 reports. The letter also noted that CUNA President and CEO Dan Mica has urged NASCUS to ensure healthy state chartered credit unions have flexible examination schedules available to them as well. NAFCU recommended that NCUA allow credit unions under $50 million in assets to continue to have the option of filing semiannually with the understanding they would have to submit to yearly on-site exams. According to Becker’s letter, some federal credit unions with assets under $50 million told NAFCU that the average time to complete a call report is 11.38 hours, though some said it could take up to three days. “For a credit union with limited staff and/or reporting expertise, this can be a tremendous burden,” he wrote. Also included in the proposal, which would allow healthy credit unions to be examined every 18 months rather than every year, is a change to the Prompt Corrective Action (PCA) rule that would no longer require credit unions to provide written notice of a state supervisory authority of a net worth change under PCA. [email protected]

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