Call report revisions should focus on improved data quality, reduced reporting burden

August 19, 2025

Efforts to modernize the NCUA’s call report are underway, and comments filed Monday outline several recommendations for the agency’s call report modernization efforts to ease use by credit unions. America’s Credit Unions Regulatory Affairs Counsel Tyler Maron provided detailed recommendations in the letter, urging that any revisions to the call report should be guided by distinct goals.  

These include:

  1. Improved data quality and comparability;
  2. Reduced reporting burden, especially for smaller and non-complex credit unions; and
  3. Transparent implementation with sufficient lead time, clear instructions, and robust vendor coordination.

Using suggestions from members, America’s Credit Unions urged the NCUA to also:

  • Eliminate ambiguity on the certification page by identifying expected signers, stating the e-signature counts as “official,” and harmonizing the posted certification page with CUOnline (the web-based program for credit unions to submit information to NCUA);
  • Automatically place data added to the schedule into the accompanying financial statement page;
  • Provide illustrative examples for common situations that technically fit within existing Call Report categories but have quirks that can make it more difficult to determine which right line-item, timing, or measurement to use; and
  • Continued interagency coordination to ensure call report definitions remain comparable across time and, where appropriate, with analogous bank call report terms. 

“The NCUA should seek to minimize disruption to the greatest extent possible in implementing these changes. We request at least two quarters of lead time after final instructions are published, a public redline comparing old and new Instructions, a change-log with effective dates, and agency-hosted trainings with office hours,” Maron added. “The NCUA should also pilot test revisions with a diverse set of volunteer credit unions and their vendors, publish FAQs during the pilot, and coordinate filing deadlines to avoid core vendor blackout periods.”

Read the full letter here.