CUNA Comment Letter

Data Collection Pilot Program

February 28, 2006

Mr. Neil McNamara
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314-3428

Dear Mr. McNamara:

This letter represents the views of the Credit Union National Association regarding the National Credit Union Administration Board’s request for comments on the data collection pilot program involving 481 federal credit unions. The purpose of the pilot is to provide information about the types of services federal credit unions provide and the economic status and financial needs of the members receiving those services.

Some credit union representatives have raised the concern that the data collection is tantamount to Community Reinvestment Act requirements for credit unions. Such statements do not reflect an accurate understanding of CRA. CUNA does not support any efforts to impose federal CRA standards on credit unions, which would be unwarranted, unnecessary and inappropriate.

Under the Paperwork Reduction Act of 1995 (PRA), the Office of Management and Budget (OMB) was given specific responsibilities that include ensuring that:

  1. effective and efficient information resource management practices are implemented across the government;
  2. the paperwork burden imposed by the Federal government on the public is minimized; and
  3. the greatest possible public benefit comes from the data collection.

In light of these provisions, and the requests for information from the House Ways and Means Committee and the Government Accountability Office, in CUNA’s view these objectives will be met if the following concerns are addressed.

We urge the agency to emphasize to credit unions and its examiners that the pilot credit unions must be allowed to provide additional information to supplement the data NCUA is seeking, which will help ensure the most complete picture possible is obtained of the credit unions’ service.

It is our understanding that only aggregate data will be published and that no individual compensation or credit union service information will be reported outside of the agency. In that connection, CUNA also urges the agency to determine and clarify to credit unions how it plans to safeguard the information it receives from the 481 federal credit unions.

We further urge the agency to recognize and reflect in its report the differences among charter types and how those differences impact the ability of a credit union to serve various income groups.

CUNA questions the agency’s estimate of the time it will take credit unions to produce the loan files examiners will need for their analysis. We believe more time will be needed by the credit unions just to provide the files, and the estimate does not take into account that problems may occur that the credit unions would have to address.

Thank you for the opportunity to file our comments on the data collection pilot. Please do not hesitate to contact me if you have any questions about our letter.

Sincerely,

Mary Mitchell Dunn
Senior Vice President and CUNA Deputy General Counsel