NACUSO Comments to New CUSO Rule Information Collection Request

We have provided a link below to a copy of NACUSO’s comment letter addressing the CUSO Rule Information Collection Activities Request filed in the Federal Register on July 6, 2015 by the NCUA, requesting comment by September 4, 2015.  We have been engaged in open dialogue with the NCUA during the development of the new NCUA system for gathering CUSO information, that will begin as of 12-31-2015. We believe NCUA is taking the right approach by utilizing a beta test group of CUSOs to work through the data collection process and ensure it works smoothly and efficiently.  However, as you will see in our comment letter, we also felt that this was an opportune time for NACUSO to encourage NCUA to ensure data submitted, especially by CUSOs which are deemed to be “complex” CUSOs and therefore submitting more detailed information, is kept absolutely confidential.  We also emphasized that every effort should be made to ensure that the reporting regimen minimizes unnecessary burden and that most data should be submitted electronically for less paperwork.  You can expect to hear more about this process later this fall, prior to the year-end reporting deadline in the CUSO Rule that NCUA adopted in November 2013.

While this has not been a high profile comment request, NACUSO wanted to make sure the voice of the CUSO community was heard again on the implementation of the CUSO rule and the approach to reporting that the NCUA is going to employ.