After a years-long regulatory approval process, the National Credit Union Administration (NCUA) is implementing an updated, streamlined Call Report for the March 2022 cycle filing due April 30, 2022. The NCUA issued a new Call Report form on January 25, 2022, and credit unions are expected to use it moving forward. This form represents a significant adjustment from prior Call Reports, with changes to nearly every page and section. Read on for an overview of what’s changing, what’s staying the same and more details about the new reporting process.
Why is the Call Report changing?
Originally, the NCUA intended these Call Report changes to coincide with 2015’s risk-based capital changes. Together, these reforms are intended to reduce the reporting burden on credit unions, enhance supervision capabilities and improve the organization and clarity of the Call Report form. The below chart from NCUA shows the decrease in the number of fillable accounts:
Source: NCUA
What has changed on the Call Report form?
A lot. Overall schedules have moved, new schedules were added and many account codes have been retired. Here are some examples:
- Maturity distribution schedules are relocated from the face of the financial statements to various schedules within the report.
- The Other Than Temporary Impairment is relocated from the Statement of Income and Expenses to Schedule B.
- Many account codes for Troubled Debt Restructure (TDR) have been eliminated, now only requiring the reporting of the total number and dollar amount of outstanding TDRs.
- Schedule C has added off-balance sheet exposures to inform Risk-Based Capital.
- Changes to loans, delinquency and charge offs, specifically Schedule A.
- Schedules F, G, H and I are new to the Call Report.
What are Schedules H and I?
Schedule H is for Complex Credit Union Leverage Ratio (CCULR). All credit unions with total assets over $500 million must complete question 1 (Account LR0001) which asks if your credit union has a CCULR framework election. If a credit union meets or exceeds the $500 million threshold but does not elect or qualify for CCULR, then it must complete Schedule I for the risk-based capital calculation. Credit unions under $500 million in total assets are not required to complete these schedules.
What stays the same on the new Call Report form?
At first blush, not much. Some items will stay the same, just in a different spot within the report. For example:
- OTTI reporting is now located on Schedule B.
- Borrowing maturity distribution schedule moved from the Statement of Financial Condition to Schedule B.
- Other items previously on the Statement of Financial Condition, such as share maturity, distribution, additional share information and the NCUA insured savings computation, also moved to Schedule D.
Prepare now for call report changes
These Call Report changes impact all credit unions of every size. Now is the time for credit unions to evaluate the impact on their reporting processes. While intended to reduce reporting complexity, these significant changes may cause confusion during the first few Call Report cycles.
The NCUA has stated that it will be flexible with credit unions as they navigate these changes and allow credit unions to correct Call Reports errors after filing. The NCUA also indicated that examiners will work with credit unions that cannot meet the submission deadline to develop an estimated Call Report.
RKL can be a resource to help credit unions adopt Call Report changes and get positioned for ongoing reporting success. Contact us today using the form at the bottom of this page to get started. Learn more about the many ways we serve the compliance, regulatory and advisory needs of financial institutions throughout the Mid-Atlantic.
