NEWS: The League submitted a comment letter yesterday on an NCUA “advanced notice of proposed rulemaking” (ANPR), which sought “comments on ways the agency can improve and update its records preservation program regulation and accompanying guidelines.”
The ANPR said: “The [NCUA] Board is particularly interested in obtaining stakeholder input on the content of the regulation, which has not been updated in 15 years and may be outdated or at odds with current best practices. The Board is also interested in feedback on the structure of the part which may be confusing as it currently contains a combination of regulatory requirements and guidance.”
With feedback The League received from several Wisconsin credit unions, we were able to share a variety of responses to a list of 20 questions the NCUA posed in its ANPR. For example, our member credit unions summarized the costs they incur for record retention, they discussed pros and cons of physical vs. electronic storage methods, they explained their views on NCUA requirements to keep certain records permanently, and they offered insights into the use of third-party vendors to assist with record retention.
In our letter, we also explained that record retention can be a confusing topic, for which there are few reliable resources. For example, Wisconsin’s regulations for state-chartered credit unions no longer list record retention requirements, instead telling each credit union to keep records “in a manner consistent with prudent business practices.” In addition, for many years, The League recommended that credit unions consult the Financial Managers Society’s comprehensive “Financial Institutions Record Retention Manual.” However, the manual’s 6th edition was published in 2009, and no new edition is available.
“This leaves a void in authoritative information on record retention best practices, which the NCUA’s guidance only partially fills,” we wrote. “For that reason, we urge the NCUA to do all it can to update and modernize its record retention guidance, giving credit unions explicit (and reasonable) timelines for retaining specific types of business records.”
We want to thank all the credit unions that shared their thoughts on record retention with The League in response to our May 17 Comment Call. Our comments to regulators are always more persuasive when we can share insights and facts from credit unions.
The League will alert you when the NCUA announces further action on its record retention guidelines.
League shares CUs’ comments on NCUA’s record retention guidelines
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