Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

Samantha: Hello, this is Samantha Shares.

This episode covers N C U A Board
Member Tanya OAtska Statement on the

Decision to Remove Total Overdraft
and Non-sufficient Fund Fee Data

The following is an audio
version of that STATEMENT.

This podcast is educational
and is not legal advice.

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And now the STATEMENT

N C U A Board Member Tanya OAtska
Statement on the Decision to Remove Total

Overdraft and Non-sufficient Fund Fee Data

N C U A Board Member Tanya F.

Otsuka issued the following statement
about the agency’s decision to remove

total overdraft and non-sufficient
fund (NSF) fee data for federally

insured credit unions with more than
$1 billion in assets from Call Reports

beginning with the first quarter of 2025.

Member empowerment is a cornerstone
of the cooperative credit movement.

For credit unions, which are built
on the philosophy of “people helping

people,” increasing transparency is a
simple way to demonstrate the credit

union difference, enable consumers
to make informed financial decisions,

and help maintain trust and confidence
in our cooperative system of credit.

In that spirit, the N C U A began
collecting and publishing quarterly

Call Report data on revenues credit
unions with over $1 billion in assets

made from overdraft and non-sufficient
funds (NSF) fees last year.

Unfortunately, the fourth quarter
2024 data published today will be

the last to include information
on overdraft and NSF fee income.

On March 3, 2025, Chairman Hauptman
unilaterally announced changes

to the way the N C U A collects
overdraft and NSF fee information.1

Specifically, starting on March 31,
2025, the agency would “no longer publish

overdraft and non-sufficient fund fee
income for individual credit unions”

and this information would ostensibly be
collected during supervisory examinations.

This is a step in the wrong direction.

There is no data to suggest credit
unions limited the services they provide

low-income or underserved consumers last
year simply to avoid having to report

fee income on the N C U A’s Call Reports.

Credit unions with higher overdraft
and NSF fees also do not appear to

offer lower fees to members for other
services, nor better interest rates.2

Overdraft and NSF fees put a strain
on members who are likely already

struggling and may further trap them
in a cycle of financial hardship

that can be difficult to escape.

That is why providing the public
information about fees through the N

C U A’s Call Reports enabled consumers
across the country to more readily compare

between credit unions and choose the
institution that best fit their needs.3

Credit unions are already required
to disclose to their members

the fees that they charge.

Instead of providing overdraft and fee
income in a transparent, consistent, and

standardized way, collecting overdraft
and NSF fee data through the exam process

will erode the quality of the data and
hamstring our ability to monitor trends.

The decision to collect this data
through the supervisory process

rather than through the quarterly
Call Report must not be used as an

excuse to withhold it from credit
union members or the broader public.

Transparency is vital for promoting fair
competition within the financial system.

Limiting access to individual credit union
data does not help consumers, encourage

the chartering of de novo institutions,
or reduce regulatory burden on small

cooperatives, which were exempt from
the requirement to report these data.

It just enables larger institutions
that rely heavily on fee income to

operate in the shadows, resulting in
less competition and less choice for

consumers, and places institutions
that stay true to the principles of the

credit union movement at a disadvantage.

At the end of the day, members, as owners
of their credit union, have a right to

know how their institution operates, just
like any investor would if they purchased

stock in a publicly traded company.

We shouldn’t keep credit
union members in the dark.

I urge the N C U A Chair to prioritize
transparency and to continue the practice

of quarterly reporting and public
disclosure of overdraft and NSF fee

income for individual credit unions.

I look forward to continuing to work
with the entire N C U A Board to protect

consumers and the credit union system.

This concludes the STATEMENT

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This is Samantha Shares and
we Thank you for listening.