Title : Comments on Call Report Modernization Initiative
Comments on Call Report Modernization Initiative
On August 1, I filed a comment letter with the National Credit Union Administration (NCUA) regarding the agency's Call Report/Profile Modernization initiative.As an end user of this information, I made the following general comments:
"Federally-insured credit unions (FICUs) are growing larger and more complex. As a result, NCUA’s data-collection vehicles need to evolve with changes at FICUs. As the agency seeks to modernize its Call Report, NCUA needs to ensure that its off-site monitoring tools are sufficiently robust and granular to capture risk posed by FICUs to the National Credit Union Share Insurance Fund (NCUSIF). This is extremely important given that the agency is currently studying an extension in the time between on-site examinations for FICUs.
Furthermore, the reporting burden of a FICU is commensurate with the level of complexity associated with a FICU. For example, FICUs that do not originate or participate in business loans do not have to fill out Section 4 of Schedule A dealing with business lending. Moreover, only 44 credit unions currently fill out the Schedule D “Derivative Transaction Report” – less than one percent of the industry."
In addition, I made five specific recommendations regarding the Call Report/Profile.
"First, beginning on January 1, 2019, FICUs with more than $100 million in assets will be subject to a risk-based capital requirement. This will require these credit unions to fill out a new schedule on risk weighted assets. This schedule should be comparable to Schedule RC-R Part II filled out by banks. In addition, the agency will need a new schedule regarding the data items comprised in the numerator of the risk-based capital ratio, which would be comparable to RC-R Part I filled out by banks. However, since the risk-based capital requirement is replacing the risk-based net worth requirement, NCUA can delete line items 14a and 14b in the PCA NET WORTH CALCULATION WORKSHEET, once the risk-based capital requirement becomes effective.
Second, the Call Report should require an FICU to report on its aggregate investment in the Central Liquidity Facility as part of the Statement of Financial Condition. This data item would provide a more complete picture of sources of emergency liquidity for an FICU.
Third, NCUA should report annually the compensation of a federal credit union’s senior executives. The Government Accountability Office (GAO) in 2006 pointed out that executive compensation at federal credit unions lacks transparency; because federal credit unions are not required to file the Internal Revenue Service’s Form 990 information return. GAO in its report recommended to NCUA that the agency needs to improve transparency of credit union senior executive compensation. Furthermore, in 2008 NCUA's Outreach Task Force recommended that since federal credit unions are cooperatives, the NCUA Board should adopt an amendment to its regulations requiring federal credit unions to annually disclose the total compensation of each senior executive officer. Requiring the reporting of this information would ensure comparable treatment with other tax-exempt entities, especially state chartered credit unions. Reporting this information would enhance good corporate governance and promote greater transparency. This information could be included as part of the Profile.
Fourth, the Profile captures information on the address of credit union offices for an FICU. However, this information has limited value. To improve the quality of this information, NCUA should collect annually information on deposits by branch location for each FICU. This is equivalent to the Federal Deposit Insurance Corporation’s Summary of Deposit data. Gathering this information would permit NCUA to assess the impact of credit union mergers on credit union competition and concentration in local markets. In other words, would a credit union merger reduce individuals’ access to FICUs in a local market?
Fifth, NCUA should end the collection of interest rate information on loans and dividend rates for deposit accounts in the Statement of Financial Conditions. It has been my experience that this information adds very little value. Therefore, I recommend that NCUA should no longer gather information for the following Acct Codes: 521, 522, 522A, 595A, 523, 524, 563, 562, 565, 595, 553, 552, 532, 547, 554, 585, and 599."
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