ARLINGTON, Va. – Both CUNA and NAFCU sent generally supportive letters in response to NCUA's proposal to streamline the 5300 forms and to make the filing requirements more uniform across credit unions regardless of asset size. Both raised concerns that the move effectively increases the reporting requirements for smaller credit unions, and both urged that the agency allow smaller credit unions more time to get used to collecting the new data. "NAFCU, however, is concerned that small credit unions currently permitted to file a short form twice yearly will bear additional reporting burdens due to the longer Form 5300 and the increased amount of data required to complete it," the association said. "NAFCU supports the proposed revisions to the financial and statistical reporting form, but urges NCUA to provide small credit unions with ample time to prepare for the revised requirements and to be flexible during the rule implementation process. NAFCU would support the proposed implementation date of September 2006, if the revised form is approved and made available before the end of 2005. However, if the form is not available until 2006, NAFCU would support an implementation in the first quarter of 2007 or later. NAFCU also encourages the agency to continue to identify means for streamlining the reporting process." CUNA offered similar sentiments. "Small credit unions will need time to prepare the additional data and all credit unions, regardless of assets, should be given sufficient time before use of the new Form 5300 is required. If the new form is not approved by the end of this year, then the use of the new Form 5300 should not be required prior to the first quarter of 2007," the association said.

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