Here I was, embarrassed last weekto admit that I bounced a check last year, and come to find out onein seven of you don't turn your 5300 Call Reports in on time.

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And last quarter wasn't just a case of CFPB mortgage reg prep ortime-consuming budgeting season, either. The letter to federallyinsured credit unions from NCUA Chairman Debbie Matz said a largepercentage of late filers last quarter were chronically late,repeatedly filing after deadline.

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To someone in the news business, where we live and die bydeadlines, that sounds pretty staggering to me.

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And the fines the NCUA could assess are also staggering: up to$2,000 per day if a 5300 report is late, or if any information inthe report is accidentally inaccurate AND the credit union alreadyhas procedures in place to prevent inaccurate information. If noprocedures are in place, or if the report is more than just a fewdays late, that fine could increase to $20,000 per day.

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In a nod to the NCUA's increased focus on mitigating internalfraud (for which they deserve a tip of the hat), credit unions thatfile false or misleading reports knowingly, or with recklessdisregard for accuracy, could be fined up to $1 million per day or1% of total assets.

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Look, I know there are a million tasks to accomplish in a creditunion every day. It's hard to prioritize.

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I recall one planning session back in my credit union days whenour meeting facilitator had the management team make a master listof all projects we had planned for the upcoming year. The resultinglist was pretty long, as they probably are at most creditunions.

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“Okay, now let's prioritize the list,” the facilitator said. Shethen asked our CEO to tell her which projects on the list she feltwere crucial and absolutely had to be done in the next year.

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“All of them,” my CEO replied.

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“I don't think you understand what we're trying to do here,” thefacilitator replied. “We're prioritizing your tasks so you canfocus on them in order of importance, which increases thelikelihood that they get accomplished.”

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“They're all important,” my CEO said, standing her ground. “Wemust accomplish them all.”

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“That's not prioritizing,” the facilitator said. “You can't justadd more hours to the day.”

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“We can't fail, either,” my CEO said. “We do whatever we need todo to fit it all in.”

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That conversation has stuck with me throughout my career. I wasa middle manager at the time and frustrated by the long list ofitems that required my participation … and I was merely in chargeof business development, not operations or anything trulycrucial.

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Folks, that was back in the year 2000. Before September 11,before the mortgage meltdown, before the corporate implosion andbefore the CFPB. Wasn't life easy back then? It almost seemsquaint, doesn't it?

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And yet, even back then, the daily grind at your average creditunion was incomprehensible to our meeting facilitator.

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The point is, I get it. Even if your core system spits outeverything you need for your 5300 reports, those numbers still haveto be verified, cross checked, analyzed and certified.

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But to me, 5300 reports are like taxes. When the feds requireyou to send in your forms by a certain date, you do whatever youneed to do to fit it in.

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Not long after we posted our story about the fines, a readerexpressed frustration over the announcement, calling the NCUA atypical government agency in a comment left on our website.

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“Did anyone think for a minute that maybe credit unions justhave too much work? What is a small staff supposed to do?” thereader wrote.

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The reader said his or her credit union always has its callreport finished in the first few days of the new month, but inprotest of the civil penalties, would in the future transmit 5300numbers no sooner than the deadline date.

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As much as I love sticking it to The Man, this doesn't seem likethe best reaction. I'm guessing the NCUA is getting pressure fromother places, maybe the U.S. Treasury, about how quickly it canproduce quarterly industry data.

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If there are specific reasons why some credit unions simplycan't make the 5300 deadline – overburdened accounting or auditvendors, complex investment products, core processing shortfalls,etc. – I'd love to hear about them. Please email me your thoughts.

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