FINAL_0114_Supporting_Statement_080116

SUPPORTING STATEMENT
National Credit Union Administration
Payments on Shares by Public Units and Nonmembers
OMB No. 3133-0114
A.

JUSTIFICATION

1.

Circumstances Necessitating the Collection of Information
Section 107(6) of the Federal Credit Union Act (Act) and §701.32 of the NCUA Rules
and Regulations (12 CFR 701) may receive from public units and political subdivisions
(as defined in §754.1) and nonmember credit unions, payments on shares. Limitations on
nonmember and public unit deposits in federally insured credit unions is 20 percent of
their shares or $3 million, whichever is greater. This collection of information is
necessary to protect the National Credit Union Share Insurance Fund (“Fund”). The
NCUA Board has determined that deposits in excess of 20 percent of shares or $3 million
can cause an undue risk to the Fund and a loss of confidence in the credit union system.
The NCUA must be made aware of and be able to monitor those credit unions seeking an
exemption from the requirement.

2.

Purpose and Use of the Information Collection
The information collection requirements is for those credit unions seeking an exemption
from the nonmember deposit limit must (1) adopt a specific written plan concerning the
intended use of those shares and submit along with their (2) lending and investment
policies, (3) a copy of their latest financial statement, and (4) identify the new maximum
level of public unit and nonmember shares in a request to the NCUA Regional Director.
NCUA uses this information to determine whether or not a particular credit union will be
granted an exemption to the limit on nonmember and public unit deposits. Deposits in
excess of this amount have caused direct losses to the Fund and indirect losses to all
federally insured credit unions since they capitalize and maintain the Fund. This
collection of information is necessary to protect the National Credit Union Share
Insurance Fund (“Fund”).

3.

Consideration Given to information technology.
Written requests and related documents may be provided to NCUA electronically, using
email.

4.

Duplication.
There is no duplication. Credit unions do not otherwise report this information. The data
collection only requires credit unions seeking an exemption to provide an explanation
documenting their need for an exemption.

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5.

Reducing burden on small entities.
The information requested by this collection is required to be supplied only once by each
credit union seeking an exemption. This is a minimal burden.

6.

Consequences of Not Conducting Collection
Deposits in excess of this amount have caused direct losses to the Fund and indirect
losses to all federally insured credit unions since they capitalize and maintain the Fund.
This collection of information is necessary to ensure the safety and soundness for
federally insured credit unions.

7.

Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2).
None – the collection is conducted within the Guidelines.

8.

Consultations Outside the Agency.
A 60-day notice was published in the Federal Register on June 6, 2016, at 81 FR 36353
soliciting comments from the public. NCUA received no comments on this collection of
information.

9.

Payment or gift.
NCUA will not provide any payment or gift to respondents.

10.

Confidentiality
There are no assurances of confidentiality other than those provided by law.

11.

Questions of a sensitive nature.
There are no questions of a sensitive nature. No personally identifiable information (PII)
is collected.

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12.

Burden of information collection
12 CFR

# Responses Per
Respondent

20

1

20

2

40

$1,400.00

20

1

20

2

40

$1,400.00

2

1

2

1

2

$70.00

82

$2,870.00

701.32(b)(2)
Adopt written plan
701.32(b)(3)
Submit Request
701.32(b)(5)
Appeals
TOTALS

Annual
Responses

20

Hours per
Response

42

Total Annual
Burden

Cost per
Respondent (hr.
labor rate $35.00)

#
Respondents

It has been the recent experience of the NCUA and it is projected that 20 credit unions
will submit an exemption request, on a one-time basis, annually. The time estimated for
each credit union fulfilling this requirement is 2 hours. Credit unions submitting such
requests must adopt a written plan covering the intended use of these shares. The
Regional Director will make a determination within 30 calendars after receipt of the
request. If denied, appeals would be directed to the NCUA Board, through the Regional
Director.
13.

Capital start-up costs and operation and maintenance costs.
There are no capital start-up or operation and maintenance costs associated with this
information collection.

14.

Cost to the Federal government.
NCUA estimates it spends 3 hours reviewing each credit union submission. We estimate
a $40 average hourly cost for NCUA’s time. Therefore, the annual estimated cost to the
Federal government is $2,400.

15.

Reason for Change.
An increase of 42 hours is an adjustment to the total burden to included information
collection requirements prescribed by §§701.32(b)(2) and (b)(5) that were omitted from
the previous submission.

16.
.

Information Collection Planned for Statistical Purposes
There are no plans for publication of results.

17.

Display of OMB Expiration date.
There are no traditional collection instruments associated with this collection of
information, e.g. forms. The OMB control number and expiration date associated with

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this PRA submission will be displayed on the Federal government’s electronic PRA
docket at www.reginfo.gov.
18.

Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to the certification statement.

A.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not involve statistical methods.

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