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NCUA should prioritize reducing credit unions' regulatory burden in its planned call report modernization efforts, NAFCU Senior Regulatory Affairs Counsel Michael Emancipator told the agency Friday.

Writing in response to NCUA's request for information on modernizing its data collection, Emancipator noted NAFCU's support of NCUA's overall enterprise solution modernization program and, in particular, its planned revision of the call report and the Form 4501A Profile. He also noted NAFCU's appreciation for the agency's commitment to transparency and industry participation.

"NAFCU is optimistic for the opportunities that an updated Call Report could present," Emancipator wrote. "For example, an updated Call Report could provide NCUA with a more accurate picture of individual credit union health.

"This would enable NCUA examiners to conduct more thorough pre-exam reviews, and thus decrease the amount of time spent on-site, or at least decrease the amount of examiner-requested documentation," he continued.

Emancipator noted that the number of call report items has more than doubled since 2008, and he urged NCUA to eliminate call report data fields that are unrelated to safety and soundness concerns and to streamline data entry and submission. He also noted NAFCU's concerns about NCUA potentially collecting additional non-financial information about credit unions. NAFCU believes this information collection is not statutorily mandated or related to the industry's safety and soundness.

Emancipator attached an appendix with more recommendations from NAFCU members about call report modernization, including deleting obsolete line and exploring how call reports could be integrated with other data credit unions already produce, such as Home Mortgage Disclosure Act data.

Emancipator also particularly emphasized the importance of improving call report instructions, which one-quarter of NAFCU members surveyed called "poor" or "very poor." He urged NCUA to establish a call-in number for credit unions to use to speak to someone with technical expertise regarding call reports, which not all examiners are able to offer.