CUNA Comment Letter
Proposed Revisions to Call Report (Form 5300)
October 27, 2000
Mr. James L. Baylen
National Credit Union Administration
1775 Duke Street
Alexandria, Virginia 22314-3428
RE: Proposed Revisions to Call Report (Form 5300)
Dear Mr. Baylen:
The Credit Union National Association (CUNA) appreciates the opportunity to comment on the proposed revisions to the Call Report, which are scheduled to be effective in time for the 2000 year-end reports. CUNA represents more than 90% of our nation's 10,500 state and federal credit unions.
We recognize that most of the proposed revisions are necessary in order for NCUA to obtain the information necessary to administer the prompt corrective action rules that were issued earlier this year. However, we have reviewed the revisions and offer the following suggestions.
- Page 8 of the revised Call Report contains account code 712, described as the "total amount of all real estate loans outstanding that will contractually refinance, reprice or mature within 5 years." We believe that the instructions for account code 712 should be clarified so that credit unions know that the dollar amount reported here should not include member business loans. If possible, we also suggest that the form itself should contain the phrase "do not include member business loans" immediately following the description for account code 712.
- Page 3 contains new equity accounts to be reported under account codes 658 (Other Reserves), 996 (Miscellaneous Equity), and 945B (Other Comprehensive Income). We suggest that NCUA provide more detailed definitions and examples for these new accounts. Specific guidance on the treatment of merger-related equity in this context would also be helpful. Also, because definition for the account code 658 has changed, it may minimize confusion if the account code number changed as well.
- Line 8 of page 6 asks "if you have a transactional world wide website, how many members use it?" We believe there needs to be more guidance on how this number should be measured, over what time period the measurement should be taken, and how the term "use" should be interpreted. For example, does "use" mean merely that the member entered into the site or does the member need to utilize a service on the website in order for it to be considered a "use?" Without more guidance, credit unions may interpret this question differently and this will reduce the value of the information.
- We believe the account codes 889, 889A, and 889B on line 11 of page 6 should be removed. In general, we understand the need for revisions to the Call Report but we believe that the additional reporting burden should be kept to a minimum. Here, account codes 889, 889A, and 889B require additional information regarding future websites that credit unions may add in the future. This is in addition to several other questions about websites that already appear in this section of the Call Report. Although NCUA may find some value in this information, we believe the additional reporting burden posed by these additional website questions exceeds the possible value to NCUA.
- Beginning on page 1 of the Call Report, we note that the "Asset" section of the Statement of Financial Condition appears on more than one page. It may helpful to insert the phrase "continued on the following page" at the bottom of page 1.
Thank you for the opportunity to comment on the proposed revisions to the Call Report. If Board members or agency staff have questions about our comments, please give me a call at 202-218-7795.
Assistant General Counsel