FINAL_0004_SS_MBL-Changes_010316

Paperwork Reduction Act Collection Justification
Revisions to National Credit Union Administration (NCUA) Call Report and Profile
OMB No. 3133-0004
PART 1

REQUEST FOR OMB REVIEW AND APPROVAL, 3133-0004
SUMMARY OF PROPOSED CHANGES TO NCUA CALL REPORT AND PROFILE
DATA COLLECTION
PROPOSED CYCLE DATE: March 31, 2017
REPORT(S) IMPACTED: NCUA Call Report Form, NCUA Profile Form
OMB FORM #: 3133-0004 (Expires 12/31/2019)
CALL REPORT PAGE(S) IMPACTED:
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Statement of Financial Condition – Page 2
Loans – New page – Page 6
Miscellaneous Information – Page 7
Additional Delinquency Information – Page 9
Loan Charge Offs and Recoveries – Page 10
Liquidity, Commitments and Sources – Page 11
Schedule A – Specialized Lending – Page 15
Schedule A – Business Lending – Page 16
Schedule A – Troubled Debt Restructured Loans – Page 17

Other pages are adjusted for numbering and updated terminology resulting from revisions to Part
723 of NCUA Rules and Regulations.
PROFILE PAGE(S) IMPACTED:
•

Credit Union Programs and Member Services – Page 8

SUPPORTING ATTACHMENTS: Draft March 2017 Call Report Form (Enclosure 4) and
September 2016 Profile Form (Enclosure 5).
Call Report and Profile Form Changes
NCUA is requesting modifications in the 5300 Call Report and 4501A Profile to align collection
items with changes in Part 723 of NCUA’s Rules and Regulations
(https://www.ncua.gov/regulation-supervision/Documents/Regulations/FIR2016218memberbusiness-loans.pdf). Changes in Part 723, Member Business Loans; Commercial Lending,
become effective January 1, 2017.
Proposed changes to the quarterly 5300 Call Report and 4501A Profile will assist the National
Credit Union Administration (NCUA) in monitoring credit union compliance with Part 723 of
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NCUA’s Rules and Regulations, thereby, protecting the integrity of the National Credit Union
Share Insurance Fund (NCUSIF). The following summarizes proposed changes.
Description of Call Report Form Changes:
Page 2 – Statement of Financial Condition (on New and Existing Call Report Form): Replace
loan breakout with single line for total loans. [Loan breakout is now reported on a
separate page.] Move additional miscellaneous loan collection items to newly created
loan-detail page (page 6). These changes reduce the number of collection items on this
page by 38.
Page 6 – New Loan Page: Move above-referenced items from page 2 (Statement of Financial
Condition) to new loan-detail page and update real-estate collection items to reflect
changes to Part 723 of NCUA Rules and Regulations. Also, capture government
guaranteed non-commercial loans. These changes increase the number of collection
items on this page by 52.
Page 7 – Revised the wording of additional share and deposit insurance to clarify the collection
intent. This update does not change the number of collection items on this page.

Page 9 – Additional Delinquency Information (Page 8 of Existing Call Report Form): Update
delinquency terminology for 18 lines of collection items to reflect the changes in Part 723
of NCUA Rules and Regulations (e.g., change “Member Business Loans” to
“Commercial Loans”). This update does not change the number of collection items on
this page.
Page 10 – Loan Charge Offs and Recoveries (Page 9 of Existing Call Report Form): Update
loan-loss terminology in nine lines of collection items to reflect changes in Part 723 of
NCUA Rules and Regulations (e.g., change “Member Business Loans” to “Commercial
Loans”). This update does not change the number of collection items on this page.
Page 11 – Liquidity, Commitments and Sources (Page 10 of Existing Call Report Form):
Remove four lines of collection items for unfunded commitments on various categories
of business loans. Update one line of collection items to reflect changes in Part 723 of
NCUA Rules and Regulations (e.g., change “Business Loans” to “Commercial Loans” in
line asking for total unfunded commitments of this type). These changes reduce the
number of collection items on this page (net) by 12.
Page 15 – Schedule A, Specialized Lending (Page 14 of Existing Call Report Form): Remove
one line of collection items for non-member business loans. Update terminology for one
collection item under Miscellaneous Real-Estate Loan/Lines of Credit Information to
reflect changes in Part 723 of NCUA Rules and Regulations (e.g., “Business” to
“Commercial”). Under Participation Loans Outstanding by Type, drop one line of
collection items and update terminology on another line of collection items (e.g.
“Business” to “Commercial”). These changes reduce the number of collection items on
this page (net) by 4.

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Page 16 – Schedule A, Specialized Lending (Page 15 of Existing Call Report Form): Remove all
Member Business Loan collection information except Total Member Business Loans
(subtracts 89 collection items). Add commercial-loan collection information to reflect
changes in Part 723 of NCUA’s Rules and Regulations (90 collection items). Remove
seven lines of collection information under Miscellaneous Business Loan Information
(subtracts 13 collection items) and replace with eight lines of similar information on
commercial loans (adds 14 collection items). Add a question on the amount of member
business loan balance of 1-4 family residential properties (adds 1 item). These changes
increase the number of collection items on this page (net) by 3.
Page 17 – Schedule A, Specialized Lending (Page 16 of Existing Call Report Form): Update
terminology in four lines of collection items to reflect changes in Part 723 of NCUA
Rules and Regulations (e.g. “Business” to “Commercial”). This update does not change
the number of collection items on this page.
Taken together, the net change in the number of collection items across all affected pages of the
Call Report is one.
Description of the Profile Form Changes:
Page 8 – Credit Union Programs and Member Services - Member Service and Product Offerings
– Credit: Added the word “Commercial” to Business/Commercial Loans and Indirect Business
Loans to reflect changes in Part 723 of NCUA Rules and Regulations.

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National Credit Union Administration
Supporting Statement
NCUA Call Report (NCUA Form 5300) and Profile (NCUA Form 4501A)
OMB No. 3133-0004
PART 2

1.

Explain the circumstances that make the collection of information necessary.
Sections 106 and 202 of the Federal Credit Union Act require federally insured credit
unions to make financial reports to the NCUA.
Section 741.6 of the NCUA Rules and Regulations requires all federally insured credit
unions to submit a Call Report (NCUA Form 5300) quarterly. Section 741.6 also
requires insured credit unions to submit a Credit Union Profile (NCUA Form 4501A) and
update the Profile within 10 days of election or appointment of senior management or
volunteer officials or 30 days of other changes in Profile information. NCUA's website
further directs credit unions to review and certify their Profiles every Call Report cycle.
Financial and statistical information collected through the Call Report and Profile is
essential to NCUA supervision of federal credit unions. This information also facilitates
NCUA monitoring of other credit unions with share accounts insured by the National
Credit Union Share Insurance Fund (NCUSIF).

2.

Purpose and use of information.
NCUA uses information collected through Call Reports to supervise federally insured
credit unions and safeguard the NCUSIF. The Federal Reserve also uses the information
to conduct monetary policy, protect the payments system, and preserve competition
among depository institutions. Congress and the state legislatures use the information to
formulate policy on credit unions, other depository institutions, and the financial system.
Finally, the U.S. Department of Commerce uses the information to produce national
income accounting data and statistics.
Changes made to Profile/Call Report forms for March 2017 will help NCUA assess
credit-union safety and soundness without increasing the burden on reporting institutions.
NCUA also uses Call Report data to create a Financial Performance Report (FPR) for
each reporting credit union, the industry as a whole, and various industry cohorts. These
reports are available to the general public and distributed to all federal credit unions,
federally insured state-chartered credit unions, and those non-federally insured credit
unions required to submit Call Report data by their State Supervisory Authority (SSA).
NCUA examiners and SSAs also receive FPRs to assist in examination/supervision. Call
Report changes ensure FPRs provide all recipients with accurate pictures of credit-union
risk and profitability – at the individual institution and aggregate levels.

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3.

Describe any considerations of the use of improved information technology.
Individual credit unions are the sole source of information about their financial condition
and operations. Effective January 1, 2014, all federally insured credit unions must use
the NCUA web-based data collection system (CU Online) to submit their Call Reports
and update their Profiles. NCUA computer systems perform a series of sophisticated
edits and calculations to minimize the amount of information required and reduce the
burden to reporting credit unions.
Credit Union Profile
NCUA collects information for the Credit Union Profile via a web-based system – CU
Online. The Profile captures information about the credit union that changes
infrequently. After initial Profile data are entered, a credit union need only update these
data to reflect additions, deletions, and other changes. Under NCUA Rule and
Regulations Section 741.6(a)(1), credit unions must update Profile information within ten
days of election or appointment of officials or thirty days of any other change. Credit
unions can enter Profile data any time through CU Online. Requiring input only when
Profile information changes and allowing such changes to made 24/7/365 through an
online interface reduces reporting burden. NCUA also collected quarterly Call Report
data through CU Online.

4.

Describe efforts to identify duplication.
Aside from Call Report data-gathering cycles, NCUA engages in no other comprehensive
collection of credit-union data. NCUA alone collects, processes, and releases Call Report
data, so there is no duplication of effort at the federal level. At the state level, NCUA
works closely with the National Association of State Credit Union Supervisors
(NASCUS, which represents all SSAs) to improve the Call Report as a federal and state
tool for collecting material information about credit union condition and practices while
minimizing the burden on reporting institutions.

5.

Reducing burden on small entities.
All credit unions must submit Call Report and Profile information as prescribed by
regulations. NCUA minimizes the burden on small credit unions with CU Online, which
performs calculations needed to derive various balance-sheet and income-state items,
generate risk/performance metrics, and compare risk/performance with peer institutions.

6.

Describe the consequence to the federal program or policy activities if the collection
were conducted less frequently.
Collection items from the 5300 Call Report and 4501A Profile provide critical
information for supervision of safety-and-soundness and monitoring of regulatory
compliance. In particular, NCUA uses collection items for off-site monitoring, which
greatly reduces the burden of on-site examinations. NCUA must react quickly to
emerging risks to protect the share accounts of the nation’s credit union members (over
102 million people) and the integrity of the NCUSIF – hence the need for quarterly
reporting.

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The consequences of non-collection are severe. Absent quarterly Call Report
submissions and Profile updates, SSAs and NCUA would have to rely on more frequent
on-site visits to supervise credit-union risks and monitor regulatory compliance.
Moreover, there would be no FPR – thereby depriving federal and state authorities as
well as the credit-union industry of a valuable tool for policymaking and financial
management.
7.

Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with the guidelines of 5 CFR 1320.5(d)(2).
NCUA conducts collection entirely within the guidelines outlined in 5 CFR 1320.5(d)(2).

8.

Consultations with persons outside of the Agency.
NCUA has an ongoing commitment to communicate and interact with SSAs, NASCUS,
and credit-union trade associations. Typically, NCUA receives comments and
suggestions from SSAs and trade associations throughout the year. NCUA considers
these comments when revising the Call Report and Profile forms as well as other aspects
of data collection.
A 60-day notice was published September 19, 2016, at 81 FR 64205 in the Federal
Register soliciting comments from the public. No comments were received in response
to this notice.

9.

Payment of gifts.
NCUA will not provide any payment or gift to respondents.

10.

Describe any assurance of confidentiality.
Most Call Report data are public information subject to release under the Freedom of
Information Act. NCUA provides this information to the general public on the agency
website (www.ncua.gov). Some Call Report and Profile information as well as
information obtained through the supervisory process are confidential and, therefore,
exempt from release under the Freedom of Information Act.

11.

Questions of a sensitive nature.
Data collection fields are critical for adequate off-site monitoring and on-site examination
of federally insured credit unions. The Profile asks for critical non-financial data such as
contact information for credit union officials and mandatory-role individuals.

12.

Provide estimates of burden of the collection of information.
NCUA estimates credit unions will, on average, need six hours to complete the forms.
To obtain industrywide costs, this average is applied to 5,954 credit unions, thereby
yielding:

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Credit Union Staff Time – Six hours per reporting institution per reporting cycle (four
cycles per year):
No. Respondents

No. Responses
Per Respondent

No. Annual
Responses

Hours Per
Response

Total Annual
Burden Hours

5,954

4

23,816

6

142,896

TOTAL ANNUAL BURDEN HOURS ...................................................142,896
TOTAL ANNUAL RESPONDENTS LABOR COST .......................$5,001,360
The dollar-cost estimate uses an average hourly wage for credit-union staff. This wage –
$35 – is based on Call Report data. The source of information for most Call
Report/Profile questions is monthly financial statements and reports prepared by all credit
unions in their normal course of business. NCUA provides advance notification of all
changes in reporting, thereby allowing credit unions to modify automated and manual
record-keeping systems before data collection begins.
13.

Capital start-up costs and operations and maintenance costs.
There are no capital start-up, operation, or maintenance costs associated with this
information collection.

14.

Annualized cost to the Federal government.
Staff
Central Office:
Analyst staff - 2 full-time persons
Technical data processing support staff

$250,000
$1,001,880

Regional Offices:
Regional office staff – 320 hours @ $55/hr.
Examiner field staff – 33,408 hours @ $38/hr.
TOTAL ANNUAL FEDERAL GOVERNMENT COST:

$17,600
$1,269,504
$2,538,984

The estimate of annual costs to the Federal Government includes all costs associated with
collection, processing, and distribution of information. It is important to note, however,
these costs are offset through the NCUA Risk Focused Examination program. Moreover,
NCUA monitoring of credit-union financial trends reduces expected losses to the
NCUSIF as well as economic costs arising from disruptions of the payments system and
local economies when credit unions fail.
15.

Explain reasons for changes in burden.
Modifications necessary to support changes in part 723 of NCUA Rules and Regulations
(“Member Business Loans; Commercial Lending”) will not alter the amount of hours
necessary to complete the forms. The amount of data elements removed compared to
those being added have negated any differences in burden. . Moreover, none of the
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changes – even those involving new account codes – represents a significantly new
collection (e.g., the vast majority involve asking for data on “commercial” loans rather
than “member business” loans). The specific program changes are detailed in Part I of
this supporting statement.
This submission reflects adjustment due to the decline in the number of federally insured
credit unions due to industry consolidation from mergers and liquidations, which has
averaged approximately one percent per quarter. Specifically, the number of federally
insured credit unions completing the Call Report and Profile dropped from 6,021 to 5,954
(67).
16.

Collections of information planned to be published for statistical use.
The projected Financial and Statistical Report/Call Report collection schedule for 2017 is
provided below. The schedule is tentative because NCUA is reviewing procedures for
processing Call Report data.
March 31 Collection
April 30
April 30 - May 10
May 10 - May 24
May 10 - June 5

Forms Due
Forms Processed
Reports Prepared
Data Finalized and Distributed

June 30 Collection
July 30
July 30 - August 10
August 10 - August 24
August 10 -September 5

Forms Due
Forms Processed
Reports Prepared
Data Finalized and Distributed

September 30 Collection
October 29
October 29 - November 10
November 10 - November 24
November 10 - December 6

Forms Due
Forms Processed
Reports Prepared
Data Finalized and Distributed

December 31 Collection
January 28, 2018
January 28 - February 10, 2018
February 10 - February 24, 2018
February 10 - March 9

Forms Due
Forms Processed
Reports Prepared
Data Finalized and Distributed

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17.

Display of OMB expiration date.
The display of an expiration date may cause confusion among respondents when
providing information by a prescribed date because 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.
There are no exceptions to the certification statement.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not involve statistical methods.

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