ALEXANDRIA, VA (November 19, 2013) -- Data provided by the National Credit Union Administration in Federal Register notices on Aug. 5 and Sept. 26 estimating credit unions’ continued compliance with the Truth in Savings Act were incorrect.
To correct the error, NCUA submitted a revision to OMB on Nov. 7. NCUA is also submitting a technical correction to the Federal Register for publication. The revised notice is available here.
The estimated number of annual periodic statements sent to members should be 380.1 million. The 380.1 million is the number of credit union members (95 million) multiplied by four statements per year. The error occurred when the 380.1 million was inadvertently multiplied by the total number of credit unions at the time (6,859). Thus, the estimated hours required for compliance, which is based on the corrected number of estimated periodic statements, should be 6.3 million hours for this line item.
With the correction, the total estimated hours for continued compliance under the Truth in Savings Act comes to 9.9 million. This estimate incorporates the 6.3 million hours for periodic statements, 803,654 hours for other continuing annual compliance requirements, and 2.8 million hours for one-time compliance requirements.
The Federal Register entry was a report of NCUA’s estimate of the time necessary for continued compliance. It did not involve any additional regulation or any change to the existing regulation.
Through the Truth in Savings Act, credit unions and banks are required to make certain information available to their members and customers, respectively. Congress requires NCUA to have rules (Part 707) to implement the Truth in Savings Act. Congress also requires NCUA to issue periodic estimates of compliance with these rules under the Paperwork Reduction Act.