Credit Unions Face Deadline for Q1 Reports, New Overdraft Fee Reporting Requirement

Credit unions must submit their first-quarter 2024 financial reports by today, April 30. The call reports include a new requirement for credit unions with over $1 billion in assets to disclose income earned from overdraft and non-sufficient fund (NSF) fees.

The NCUA mentioned the change in February during an interview instead of an official public announcement. Since formal rulemaking was not needed, the change was implemented through the Paperwork Reduction Act.

Credit unions are concerned by both the tight implementation window and that disclosing this data without additional context could lead to inaccurate or misleading reports and potential reputational damage. Area credit unions and the Association have directly voiced these concerns to the NCUA. The aggregate data is expected to be publicly available as early as late May. The Association will be reviewing the data with credit unions as it is released.

CFPB: Significant Decline in Overdraft & NSF
This new reporting requirement aligns with the Biden Administration's focus on reducing or eliminating so-called "junk fees," including overdraft and NSF charges. The CFPB reports significant declines in these fees since 2019. This decrease of over $6.1 billion represents a drop of more than 50% from pre-pandemic levels and a 24% decrease from 2022 to 2023. It's important to note that the data do not include credit unions which have not been required to report overdraft and NSF fees, until now. Banks with more than $1 billion in assets have been required to report their overdraft and NSF fees since 2015.

The CFPB proposed a rule in February to limit overdraft fees to $3-$14 for banks and credit unions with over $10 billion in assets.