Coming Call Report Changes for Large CUs On Overdraft, NSF Income Reporting: What You Need to Know

We continue to field questions from credit unions about NCUA having amended the Call Report to require large credit unions (in this case meaning more than $1 billion in total assets) to report income from overdraft fees and NSF fees. That reporting requirement begins with the first quarter 2024 Call Report.

"Credit unions are strongly encouraged to review this requirement and assess the degree to which this reporting might pose a reputational risk for the institution," said League Chief Advocacy Officer JT Blau. "In recent weeks, we’ve seen this new new fee reporting requirement, a move from the CFPB to eliminate NSF fees, a proposal targeting overdraft fees charged by very large financial institutions, and CFPB’s issuance of a final rule on credit card penalty fees. Given today’s competitive environment and the national conversation surrounding banking fees, credit unions are justifiably concerned what all this means for the viability of our business model and our ability to serve our members.”  

You'll recall reporting from last October in which a few California-based credit unions were criticized for their overdraft and NSF fees and the income derived from those fees.

We encourage credit unions to reviews these resources:

• League Compliance Roundtable (Archived Webinar)
• REGular Blog: An Update on NCUA Requiring Large Credit Unions to Report Overdraft and NSF Fee Income
• NCUA Call Report Update: Focus on Overdraft & NSF Fees; Penalties Resume
• REGular Blog: Harper Signals Additional Reporting Requirement for Large CUs
• League Notes Concerns With NCUA Plan to Collect Overdraft, NSF Info From Large CUs