Exam Procedures

The NCUA reviews Call Reports and CU Profiles to identify significant changes to a credit union’s management, financial condition, and risk profile. Offsite review of Call Reports and CU Profiles supplements exams and onsite supervision contacts. The NSPM outlines exam staff responsibilities related to the Call Report, Trending Analysis, and RATE/RADAR. 

This section of the Examiner's Guide addresses:

Profile Review

Information in a Profile can help exam staff scope an exam or complete appropriate offsite monitoring. Exam staff should review Profile data to:

  • Ensure the credit union has removed all CUOnline users who are no longer employed by the credit union or no longer have an active role in updating the Profile or Call Report
  • Identify relationships among credit union management and officials in which a conflict of interest may occur (such as family members or shared credit union management)
  • Confirm that the number of credit union board and supervisory committee members complies with regulatory requirements
  • Verify audit completion for compliance with the annual audit requirement (see Audits, Recordkeeping, and Fraud > Audit Report Review in the NSPM for audit report review requirements)
  • Verify that the credit union has a back-up administrative user in the event the primary user is unable to update the Profile or upload the Call Report
  • Determine the dates of the most recent annual meeting, disaster recovery test, and BSA independent test
  • Confirm that the credit union verifies membership accounts at least once every two years
  • Confirm the credit union regularly updates profile information
  • Verify that the credit union has current employees listed as primary and secondary Patriot Act contacts

Quarterly Call Report Review

With limited exceptions, SSAs are responsible for validating FISCU Call Reports. Exam staff should adhere to agreements with state supervisory authorities when reviewing a FISCU Call Report.

Staff use CUOnline to access quarterly Call Report and Profile information. To review FCU Call Report and Profile data:

  • Review each warning and ensure any corresponding comments provide an adequate explanation for the warning

    • If necessary, contact the credit union for additional explanation.

  • Review each historical warning and any corresponding comments to ensure they provide a reasonable explanation for the historical warning

    • Credit unions are not required to comment on historical warnings. If there are no comments or you cannot understand or explain a historical warning, consider contacting the credit union or the state supervisory authority, as applicable, for additional explanation.

  • Review the Call Report and FPR for anomalies, exclusions, or potential errors

    • Accounts should be reported according to the Call Report Instructions

    • If anomalies are found, examiners should determine if the data is accurate by contacting the credit union if necessary. Occasionally, it may be prudent to request supporting documentation (such as delinquency reports, investment detail or general ledger history) to help determine accuracy of reporting. Alternatively, the examiner may know of reasonable explanations for the anomalies (such as new products)

  • Contact designated credit union staff, when warranted, to notify them of the need to make changes or corrections to the Call Report

    • Credit union staff designated as the Call Report contact are listed in the Profile, Contacts tab.

NCUA employees are responsible for adhering to administrative, technical, and physical safeguards to ensure only authorized persons have access to personally identifiable information, and for ensuring that information is used and disclosed only as authorized. See the NCUA Hi-Tech Manual for more information about protecting sensitive information.

Numerous tools are available on NCUA Central that examiners may find useful while reviewing Call Reports. Commonly used tools are described in the following table:

Tool Description
Call Report Cycle to Cycle Report Can aid users in identifying data trends and reviewing historical warnings and data errors in specific accounts. The report identifies all call report account codes over multiple cycles with the ability of filtering the account categories to narrow their search results to specific areas (for example, loans or shares). The user can choose to review the data on a quarterly, annual, or 12-month basis (for example, March to March).
Previously Validated Call reports compared to Corrected Call Reports Displays each correction made to a previously validated Call Report.
Profile Warnings Report Tracks all warning messages in the CUOnline Profile for a given credit union. The report also contains a credit union’s comments regarding warnings.
Edit Report Allows users to view warnings (front end) and historical warnings for a single credit union, district, SE group, or region. Users can obtain all warnings and historical warnings (including credit union comments) for a specific cycle in one report rather than viewing each individual Call Report.
Risk Reports: Historical Trends Report Provides a quarterly or annual history of risk report flags, and can be used to identify additional areas an examiner can review further . All risk reports can be exported to Microsoft Excel.
Profile Change Log Tracks all changes made to the Profile for a given credit union. Users can view all items that were added, modified, or deleted over a specified period of time.
RATE Presents information from the FPR, risk reports, key ratios, final risk ratings, and CAMELS codes. It can be helpful in identifying red flags in the credit union’s operations or financial position.
RADAR Establishes examination and supervision plans for specific credit union cases. This monitoring tool rates credit, liquidity, and operational risks using pre-established risk metric thresholds and examiner input.

E&I and regional offices also perform routine or periodic data scrubs to identify anomalies and trends.

Examiners should contact their supervisor for guidance if they have questions about any review steps or to discuss concerns identified during the review process.

Review Call Report During an Exam

Both SCUEP and risk-focused exams require exminers to review the Call Report and Profile.

Onsite reviews of Call Reports allow a level of detail not possible during offsite reviews. For large or more complex credit unions, examiners can coordinate a Call Report review using specialists to streamline work. For example, a specialized lending examiner or RLS can review lending schedules, or a capital markets examiner or RCMS can review investment schedules, liquidity commitments and sources.

Certain steps of the Call Report review can be completed in conjunction with other scope steps during exams. For example, while reviewing delinquency trends under credit risk, an examiner can also verify the accuracy of delinquency reported on the Call Report. Staff use CUOnline to access quarterly Call Report and Profile information.

To assess the credit union’s Call Report and Profile reporting as part of an examination, exam staff should:

  • Review the credit union’s internal controls over the Call Report and the credit union’s process for ensuring Call Report accuracy

    • Determine if the experience level of personnel involved in preparing the Call Report is appropriate to their assigned duties.

    • Evaluate the verification process to determine if the credit union has appropriate segregation of duties to help ensure accuracy. Someone other than the individual that prepares the report should review the data before submitting it. The parties involved should sign or initial the report (hard copy or electronically) to verify their role. A board or supervisory committee member may review the Call Report if necessary.

    • Review the process used to confirm where numbers originated and review documentation of that process. System-generated reports are preferred, when available. If the credit union uses custom reports or spreadsheets, review the controls over the creation of these reports and verify the data integrity.

    Credit unions should be able to support the authenticity of all data reported on a Call Report. A summary developed by a credit union is insufficient if supporting documentation is not provided. A credit union’s Call Report workpapers should include supporting documents for all reported items.

  • Test the accuracy of Call Report data; see the General Ledger section of the Examiner's Guide (PDF) for exam procedures for each account

    • Trace the statement of financial condition and income statement information to source documentation.
    • Review the credit union’s reconciliation of loans and shares totals to the share and loan download, if one is provided. If the credit union does not provide a reconciliation, the examiner should determine if loans and shares reported on the Call Report agree with the loans and shares download and any other subsidiary ledger information for off-system loans and shares.
    • Trace reported delinquency—including mortgages, credit cards and any other loans maintained by a third party data processor—to system-generated reports.
    • Review the accuracy of system-generated uninsured shares reports. These reports should use unique identifiers such as social security and employer identification numbers (not account numbers) when calculating uninsured shares.
    • Trace investments to reports received from outside parties such as brokers or corporate credit unions to ensure that reported investment numbers are accurate and appear in the appropriate type and maturity classifications based on Call Report Instructions.
    • Trace loan statistical information to system-generated reports.
    • Trace share statistical information to system-generated reports.

Exam staff can use the loan and share download to verify statistical information. This is particularly helpful if a credit union uses customized reports or non-system generated reports (for example, Microsoft Excel spreadsheets). When using the loan and share download, examiners should ensure the date matches that of the exam effective date (and Call Report cycle) and that closed and charged-off accounts, which can skew data, are excluded.

  • Test the accuracy of the Profile data and review Profile tabs to ensure all required information is provided and up to date

  • Instruct the credit union to amend the Call Report and/or Profile for any errors identified during the review

    • When possible, examiners should request a credit union make changes while onsite. If a credit union refuses to amend its Call Report, examiners should address it in the examination report and include appropriate corrective action. Additionally, exam staff should consult with their supervisor about use of administrative action, if necessary.

      As noted in the CUOnline User Guide for NCUA Users, amended Call Reports in Submitted status will be automatically validated daily at midnight. Examiners may use the report titled Previously Validated Call Reports compared to Corrected Call Reports to review the accounts corrected by the credit union.

      Once the Call Report is revalidated, update the exam with amended call report data.

  • Document deficiencies in the exam report, as necessary

  • Complete the required Profile questionnaire

  • Record the results of the review in the examination scope

Contact your supervisor for guidance if they you have questions about any review steps or to discuss concerns identified during the review process.

Common Call Report Reporting Issues

To assist with review of the Call Report, exam staff should be familiar with common reporting issues associated with the Call Report. In general, these issues do not generate a historical warning.

The following list of reporting issues is not exhaustive.

  • Misstating charge-offs, recoveries, and/or provision expenses (CUOnline automatically generates a historical warning for variances greater than $1,000)

    • This can result in the ALLL account not reconciling with reported statistical information.

  • Failure to report, or misreporting:

    • Overdrawn shares

    • ALLL on real estate loans

    • Available lines of credit

    • Share certificate maturities

    • Negotiable CDs as securities

    • Brokered CDs

    • Maturities of callable fixed-rate debt obligations and deposits (should be reported at period-remaining-to-maturity date versus next call date)

    • Fair market value of held to maturity investments

    • Capital and operating leases

    • Credit union-owned life insurance (may be misreported as an investment)

    • Fees (such as loan origination fees, which are recognized over the life of the related loan as an adjustment to yield; see ASC 310-20)

    • Uninsured shares

    • Non-member deposits

  • Failure to include overdrawn shares with unsecured loans

  • Misclassifying interchange income as fee income

  • Interchange income should be reported as ‘Other Operating Income’

  • Overstating unfunded commitments for overdraft protection programs

    • The unfunded portion should equal the limit established by policy, less outstanding courtesy pay balances (See NCUA regulation § 701.21(c)(3) for additional information on overdraft policies)

    • Misclassifying club accounts as ‘Other Shares’

      • These accounts should be classified as ‘Regular Shares’

  • Misclassifying real estate loans, particularly HELOCs, based on loan type instead of lien position

    • Real estate loans should be classified by first or subordinate lien position.

  • Misreporting total members by counting sole proprietorships as a member separate from the member who owns the business

  • Failure to report the value of forward loan commitments as non-trading derivative assets or liabilities

Last updated September 15, 2021