NCUA Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data

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

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Hello, this is Samantha Shares. This episode covers NCUA Board Member Tanya Otsuka 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. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.

And now the STATEMENT

N C U A Board Member Tanya Otsuka 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

If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening.

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