3133-0067 Supporting Statement 2016

SUPPORTING STATEMENT
OMB 3133-0067
Corporate Credit Union Monthly Call Report and Report of Officers

A. JUSTIFICATION
1. Necessity of Information Collection
Section 202(a)(1) of the Federal Credit Union Act (Act) requires federally insured credit unions
to make reports of condition to the NCUA Board upon dates selected by it. Corporate credit
unions report this information monthly on NCUA Form 5310 also known as the corporate credit
union call report. The financial and statistical information is essential to NCUA in carrying out
its responsibility for supervising corporate credit unions.
The Federal Credit Union Act, 12 U.S.C. 1762 specifically requires federal credit unions to
report the identity of credit union officials. 12 CFR 741.6(a) requires federally-insured credit
unions to submit a Report of Officials annually to NCUA containing the annual certification of
compliance with security requirements. The branch information is requested under the authority
of Section 741.6 of the NCUA Rules and Regulations.
2. Purpose and Use of the Information Collection
The Call Report information is collected on a monthly basis and used by NCUA to monitor
financial and statistical trends in corporate credit unions and to allocate examination and
supervision resources. If this information was not collected, NCUA would not be able to
effectively fulfill its primary mission of regulating and supervising credit unions.
The Report of Officers information is collected on an annual basis and used by NCUA to
monitor the directors, officials and office locations of federally insured corporate credit unions.
3. Consideration Given to Information Technology
NCUA is modifying the instrument for collecting call report data from corporate credit unions.
This information is currently collected through a standalone application that requires manual
input of data by respondents. NCUA is updating its systems to allow this information to be
provided through an online portal in a way that allows respondents to automate the submission of
this data. This will significantly reduce the burden associated with this collection.
4. Duplication
NCUA makes no other monthly collection of financial information from the corporate credit
unions. There is no duplication at the federal level.

Through this action, the NCUA is also combining two currently approved collections – the
monthly call report (OMB Number 3133-0067) and the annual report of officials (OMB Number
3133-0053). These collections will both be submitted through the same online platform.
5. Effect on Small Entities
The collection of information affects only corporate credit unions. The asset sizes of these
institutions ranges from approximately $140 million to $4 billion. NCUA has promulgated
regulations establishing $100 million in assets as the definition of “small entity” for the purposes
of the Regulatory Flexibility Act. The collection of information will have no impact on any small
business or other small entities.
6. Consequences of Not Conducting Collection
Corporate credit unions are complex financial institutions that are systemically important. The
composition of their balance sheets can, in many cases, change on a day-to-day basis. Natural
person credit unions invest funds in corporate credit unions. To gather this information any less
frequently than monthly would not provide NCUA with the ability to monitor and promptly act
when material negative trends develop. Without the ability to review and analyze the
information provided on the Call Report, federal supervisors would not be guaranteed the
availability and timeliness of comprehensive financial information. The lack of such information
could jeopardize the regulator’s ability to proactively implement timely corrective measures in
the event of emerging negative financial trends. The potential impact could cause a crisis within
the credit union system and could imperil the National Credit Union Share Insurance Fund.
7. Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)
The composition of corporate credit union balance sheets may undergo significant changes on a
day-to-day basis. Quarterly reporting of information is insufficient to maintain an appropriate
level of supervision of these institutions that account for a significant portion of natural person
credit union investments. The collection is otherwise fully consistent with 5 CFR 1320.5(d)(2).
8. Consultations Outside the Agency
The required Federal Register notice with a 60-day comment period soliciting comments on this
collection of information was published on June 6, 2016 (81 FR 36354). No comments were
received in response to this solicitation.
In addition, all corporate credit unions and NCUA Office of National Examinations and
Supervision staff are asked, at least annually, to provide recommendations for improvements to
the 5310 Call Report and its instructions. Emphasis is placed on an effective and efficient
reporting system.
9. Payment or Gift
There is no intent by NCUA to provide payment or gifts for information collected.

10. Confidentiality
There is no guarantee of confidentiality associated with this information collection.
11. Sensitive Questions
There are no questions of a sensitive nature.
12. Burden of Information Collection
There are currently 12 corporate credit unions required to submit this information. We estimate
that the transition from the stand alone system to the integrated online system will cut reporting
time from eight hours to four for each response. The estimate of the burden associated with
annual reporting of officers and branch locations will remain the same as the currently approved
collection at one hour per response

Information
Collection
Activity
1.
2.

Annual Report
of Officers
(Form4510)
Monthly Call
Report (Form
5310)

Total (Sum)

Number of
Respondents
(A)
12

Frequency
of Response
(Annual (1),
Quarterly
(4), etc.)
(B)
1

Number
of
Responses
(C)
12

12

12

144

12

156

Burden
Hours per
Response
(D)
1.0 Hours

Annual
Hourly
Burden
(E)
12 Hours

4.0 Hours

576 Hours
588 Hours

At a labor rate of $35 per hour (the average loaded wage rate for credit union employees), this
results in a cost to credit unions of $20,580 per year.
13. Capital start-up costs and operation and maintenance costs.
All equipment needed to collect, prepare, and submit financial statements, when required, is
equipment used for the customary and usual business of the credit union. There is no special or
additional equipment.
14. Costs to Federal Government
There is no additional cost to the government.
15. Changes in Burden
The burden has been adjusted to reflect changes in the method of submission of this information
as well as a reduction in the number of corporate credit unions. The use of a system that

facilitates automation of the submission of the monthly call report information is expected to
reduce the burden by, at least, 50 percent.
16. Information Collection Planned for Statistical Purposes
Not applicable. The information collection is not used for statistical purposes.
17. Approval to Omit OMB Expiration Date
The display of the expiration date may cause confusion among respondents when providing
information by a prescribed date and minor technical changes to an electronic systems would
impose additional time and resources if no other information was to change. Non-display of the
expiration date of the OMB approval is requested.
18. Exceptions to Certification for Paperwork Reduction Act Submissions
This collection complies with the requirements in 5 CFR 1320.9.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not involve statistical methods.