FINAL_SS_3133-0209 - NCUA Template - Large Credit Union Data Collection_07.2025_Final

FINAL_SS_3133-0209 - NCUA Template - Large Credit Union Data Collection_07.2025_Final.docx

NCUA Template - Large Credit Union Data Collection

OMB: 3133-0209

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National Credit Union Administration

SUPPORTING STATEMENT


NCUA Template: Large Credit Union Data Collection

OMB No. 3133-0209



  1. JUSTIFICATION


  1. Circumstances that make the collection of information necessary.


The NCUA issued a regulation under 12 CFR Part 702, Subpart C, “Capital Planning and Stress Testing” regarding capital planning and stress testing for federally insured credit unions with $10 billion or more in assets (covered credit unions).


Capital is central to a credit union’s ability to absorb unexpected losses and to continue to lend to creditworthy consumers. Capital serves as the first line of defense against losses, protecting the National Credit Union Share Insurance Fund (NCUSIF). As such, the processes of a covered credit union for managing and allocating its capital resources are critical not only to its individual health and performance, but also to the stability and effective management of the NCUSIF. NCUA’s Capital Planning and Stress Testing Rule emphasizes the importance the NCUA Board places on a credit union’s capital policy and governance, internal capital planning processes, and on the supervisory assessment of all aspects of these processes. The rule is a key element of NCUA’s supervisory program to promote safety and soundness at the largest credit unions.


The rule authorizes covered credit unions to conduct their own stress tests in accordance with the NCUA’s requirements and permits covered credit unions to incorporate stress test scenarios and results into their capital plans.


Section § 702.306 requires necessary data files for those credit unions to conduct supervisory stress test. The data collection templates were developed for credit unions to provide specific data elements to NCUA with the information needed to evaluate their internal assessments of capital adequacy and ensure capital sufficiency.


The data collection program started for six covered credit unions in the first quarter of 2017. The rapid growth of large credit unions has resulted in 16 additional credit unions being subject to the capital planning and stress test regulation and data collection program as of this application.


The NCUA uses the data collected to conduct an independent supervisory stress test (SST) and uses the internal stress testing results to assess the reasonableness of the stress test results of the covered credit unions. The NCUA’s independent stress test results are expected to support the review and ongoing improvement of the covered credit unions’ stress testing practice with the respect to its internal assessments of capital adequacy and overall capital planning.


2. Purpose and use of the information collected.


The NCUA intends to use the data collect to assess the reasonableness of the stress test results of a covered credit union and to provide forward-looking information to NCUA regarding a covered credit union’s capital adequacy. The stress test results are expected to support the review ongoing improvement in the covered credit union’s stress testing practice with respect to its internal assessments of capital adequacy and overall capital planning. The NCUA may also use the data collected to conduct other quantitative analyses to identify, measure, and monitor risks at the covered credit union. These data-driven analyses are expected to support the agency’s supervision program and ensure the safety and soundness of the credit union system.


3. Use of information technology.


The FCU Act does not prescribe specific information systems for this data collection. Therefore, credit unions may use any information technology available to reduce the burden imposed by the regulation.


The NCUA requires the information to be submitted in the form of delimited text files and be electronically transferred via a secure online portal. Credit unions may use any available information technology to satisfy the information collection requirements.


4. Duplication of information.


This collection of information is unique to each credit union and is not duplicated.


5. Efforts to reduce burden on small entities.


Not applicable. The information collection affects only large institutions that are $10 billion or greater in assets.


6. Consequences of not conducting the collection.


Conducting the collection less frequently would potentially present safety and soundness risks to those entities otherwise subject to testing.


7. Inconsistencies with guidelines in 5 CFR 1320.5(d)(2).


There are no special circumstances. This collection is consistent with the guidelines in 5 CFR 1320.5(d)(2).




8. Efforts to consult with persons outside the agency.


A 60-day notice was published in the Federal Register on April 23, 2025, at 90 FR 17085, soliciting comments from the public. No public comments were received in response to this notice.


9. Payment or gifts to respondents.


The NCUA does not provide payment or gifts for the information collected.


10. Assurance of confidentiality.


There is no assurance of confidentiality other than that provided by law.

11. Questions of a sensitive nature.


No questions of a sensitive nature are asked. Personally Identifiable Information (PII) is not collected.


12. Estimate of burden of the information collection.


In calculating the “total annual burden”, the following was considered: (1) recurring burden on the 22 existing credit unions that are currently subject to this collection to provide NCUA the prescribed quarterly information (22 respondents × quarterly reporting × 5 hours to complete each report = 440 annual burden hours); (2) we estimated approximately 15 credit unions will grow to exceed $10 billion in assets in the next three years, making them new respondents subject to the quarterly collection. Each new respondent (credit union) can anticipate spending 600 hours on average during the first 12 months in developing the templates for this information collection requirement, resulting in a total burden of 9,000 hours. Because the OMB approval is granted for up to three years, the one-time burden explained above which represents a majority of the total burden hours has been annualized over the 3-year approval period (15 new respondents × 600 one-time upfront hours / 3 years = 3,000 annual burden hours); (3) recurring burden on the 15 new credit unions to provide NCUA the prescribed quarterly information (15 respondents × quarterly reporting × 5 hours to complete each report = 300 annual burden hours)




Information Collection

No. of Current Respondents

Frequency

Total Annual Responses

Est Avg hrs. per Response

One-time burden divided (by 3) to cover the life of OMB approval

Total Annual Burden

Ongoing Quarterly Collection for Existing Respondents

22

4

88

5

 

440

One-time Burden Associated with Data Sourcing and Systems Programming of New Respondents

15

1

15

600

200

3,000

Ongoing Quarterly Collection for New Respondents

15

4

60

5

 

300

Total

37

 

163

 

 

3,740


The cost to respondents is based on the 2025 GS-11 RUS salary table with an hourly labor rate of $39 per hour. The total annual cost to respondents is estimated to be $145,860.


13. Capital start-up or on-going operation and maintenance costs.


There are no capital start-up or operation and maintenance costs.


14. Annualized costs to the Federal government.


NCUA estimates the annualized cost the Federal government will be $283,881. This estimate is based on the time ONES data staff commit on activities such as data collection, data quality review, credit union communication to provide feedback and assistance to enhance their data quality and data management program.


15. Changes in burden.


This is an extension without change of a currently approved information collection. No changes are being made to the existing NCUA Templates.


Total annual burden increased slightly from 3,447 hours to 3,740 hours due to an estimate in the number of new credit unions expected to exceed the asset threshold over the next three years. More specifically, the one-time upfront burden for these new credit unions is substantially offset by removing burden on existing credit unions to revise templates/systems as they did in last approval cycle.




16. Information collection planned for statistical purposes.


The information is not planned for publication for statistical purposes. The information collection will be used for internal Agency purposes.


17. Request non-display the expiration date of the OMB control number.


The display of the expiration date of the OMB approval will cause confusion among entities preparing the templates. Non-display of OMB expiration date is requested.



18. Exceptions to the Certification for Paperwork Reduction Act Submission.


There are no exceptions to the certification statement.





  1. Collections of Information Employing Statistical Methods


This collection does not involve statistical methods.


OMB #3133-0209; July 2025 7

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