FR 2025-06965

The National Credit Union Administration (NCUA) has released a notice inviting public comments on a proposed information collection. This initiative involves gathering data pertinent to capital planning and stress testing for large federally insured credit unions. The underlying purpose of this collection is to ensure that these credit unions possess adequate capital resources as per regulatory guidelines. This process falls under the purview of the Paperwork Reduction Act of 1995, emphasizing the necessity of public involvement. The public is encouraged to submit their comments by June 23, 2025. All responses will be considered and detailed in a subsequent request for approval by the Office of Management and Budget.

Significant Issues and Concerns

There are a few notable concerns associated with this document:

1. Lack of Financial Details: While the document mentions an estimated total annual burden of 3,740 hours, it does not clarify the financial implications. The absence of specific dollar amounts could lead to confusion or speculation among stakeholders about the actual costs or savings associated with this data collection process.

2. Calculation Transparency: The methodology used to calculate the 3,740 burden hours is not detailed. Without understanding how these numbers were derived, stakeholders may question the validity of this estimate, potentially undermining confidence in the proposed process.

3. Purpose and Benefits: Although the document states the objective of the information collection, it lacks specifics about how the outcomes will benefit the public or the NCUA itself. This omission may lead to ambiguity regarding the broader impact and the practical utility of the data collected.

4. Guidance on Automated Techniques: The encouragement to use automated collection techniques is applauded; however, the document fails to offer concrete examples or guidance on adopting such tools. This lack of detail could leave organizations uncertain about how best to reduce their participation burden.

Impact on the Public

The information collection could have various implications for the public:

• Public Assurance: If executed effectively, ensuring that credit unions have adequate capital resources may enhance the public's confidence in these financial institutions. This stability can foster greater trust and participation in credit unions.

• Informed Feedback: By soliciting public comments, the NCUA promotes transparency and inclusivity. This empowers stakeholders, including credit union members and the general public, to voice their opinions and potentially shape the process to better serve communal interests.

Impact on Specific Stakeholders

Different stakeholders may experience distinct impacts based on this notice:

• Credit Unions: Large credit unions are directly affected, as they are required to comply with the data collection mandate. The lack of clarity on financial burdens and procedural methodologies could pose challenges, potentially requiring additional resources to navigate this process.

• Policy Makers and Regulators: For regulators, this initiative supports a structured approach to ensuring financial stability within the credit union sector. Comments from the public can provide valuable insights, helping refine and enhance regulatory frameworks.

In summary, while the NCUA's notice aims to enhance capital adequacy within credit unions, it does present several areas needing clarification and improvement. Addressing these concerns could facilitate a smoother implementation and greater stakeholder alignment, ultimately achieving the desired regulatory objectives.

The document in question from the National Credit Union Administration (NCUA) contains financial references related to the regulation of federally insured credit unions with substantial assets. The key financial term highlighted in the document is $10 billion or more in assets, which is pertinent to the credit unions subject to the "Capital Planning and Stress Testing" requirements under the NCUA's supervision. This regulation aims to ensure that these large credit unions adequately assess their capital adequacy and have sufficient capital resources.

However, the document does lack specificity in certain areas that affect financial understanding:

1. Estimated Total Annual Burden Hours: The document mentions that the estimated total annual burden is 3,740 hours. This reflects the time spent by credit unions in complying with the NCUA's information collection requirements. However, the document does not translate these hours into a monetary value, leaving the financial implications somewhat vague. By not specifying a dollar amount, it becomes challenging for stakeholders to fully grasp the economic impact of these hours on credit unions, particularly in terms of labor costs and resource allocation.

2. Methodology and Assumptions: There is an absence of clarity regarding the methodology used to determine the 3,740 hours. An explanation of how these hours were calculated, including any financial assumptions or models, would provide better insight into the fiscal reasonableness and validity of this estimate. Without this detail, there may be skepticism or questions surrounding the financial and operational burdens perceived by these credit unions.

3. Benefits and Practical Utility: While the purpose of collecting information is stated as ensuring capital adequacy, the document does not explicitly connect these efforts to potential financial benefits for the public or the agency. Laying out these advantages could justify the financial costs and burdens imposed on credit unions, helping stakeholders see the broader picture of how ensuring such financial stability could benefit the overall economy or provide increased security to credit union members.

4. Automated Collection Techniques: While the document endorses the use of automated processes to reduce collection burden, it does not elaborate on how such technology might lessen financial strain. Providing examples or guidance on available technologies could help credit unions efficiently allocate their financial resources, potentially converting these estimated burden hours into cost savings.

In summary, while the document outlines a framework for financial oversight of large credit unions, further elucidation on how the financial burdens were calculated, and how they relate to expected benefits, would enhance transparency and understanding for all parties involved.