The NCUA proposes adding several questions regarding third-party vendors to the Credit Union Profile (Form 4501A) that are unnecessary. America’s Credit Unions wrote to the NCUA Tuesday outlining concerns with their inclusion. Federally insured credit unions must submit a profile to the NCUA within 10 days of a senior official or within 30 days of any change of information in the profile.
“We disagree with including questions seeking specific information on credit unions’ third-party vendors. While this information may be obtained through the examination process, we disagree with including it in the Profile,” America’s Credit Unions Regulatory Advocacy Senior Counsel Luke Martone wrote, noting the disagreement with questions that seek specific vendor information.
“We ask the NCUA to provide specific data on how a lack of information regarding the specific vendors a credit union utilizes for its AML system, payment system services, digital banking services, and Managed Security Service Provider services increases risk to the NCUSIF,” Martone wrote.
The revised profile includes nearly 90 changes, and America’s Credit Unions has no issues with the “vast majority” of changes.
The letter reiterates America’s Credit Unions’ concern with the process used earlier this year to make changes to the call report and urges the agency to “utilize the notice and comment process under the Administrative Procedures Act.”
