As the NCUA moves forward with its effort to modernize the quarterly Call Report (Form 5300), America’s Credit Unions pressed the agency to prioritize ease-of-use and minimal disruption, particularly for smaller and non-complex credit unions.
In a comment letter submitted Monday, Tyler Maron, regulatory affairs counsel at America’s Credit Unions, outlined a series of recommendations to guide the modernization effort. Any revisions, he wrote, should reflect three core goals: Improved data quality and comparability, reduced reporting burden, and transparent implementation with clear timelines and instructions.
Specific suggestions included eliminating ambiguity on the report’s certification page by identifying expected signers and explicitly treating e-signatures as “official,” automatically transferring data added to schedules into the main financial statements and providing example scenarios for complex situations. Maron also emphasized that definitions must be maintained across time and aligned, when possible, with bank call report terminology.
To avoid disrupting operations, America’s Credit Unions urged the NCUA to provide credit unions with at least two quarters of lead time, public side-by-side comparisons between old and new instructions, change logs with effective dates and agency-led training with office hours.
“The NCUA should seek to minimize disruption to the greatest extent possible in implementing these changes,” Maron wrote. He further recommended the agency pilot-test revisions with a diverse set of credit unions and vendors and coordinate deadlines to avoid “core system blackout periods.”
NCUA officials have said the Call Report modernization is aimed at better aligning supervisory data with evolving risks and operational structures across the credit union system.
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