What changed between these versions
v2 introduces several clarifications and adjustments to the reporting requirements for various financial institution charter and insurance applications. Key changes include adding a 'to the extent practicable' clause for reporting common reasons for denial or withdrawal, clarifying that reports should cover equivalent procedures used by agencies, and significantly modifying the specific metrics required for Federal Credit Union charter applications.
Overview
A handful of changes were made across all reporting sections of the bill. · v2 clarifies the scope of reporting requirements by acknowledging equivalent agency procedures and introducing a practicability standard for reporting common reasons, while also refining the specific metrics for Federal Credit Union applications.
The primary changes in v2 involve adding a 'to the extent practicable' qualifier to all requirements for reporting common reasons for application denial or withdrawal, and including language to ensure reports cover 'equivalent procedures' used by the respective agencies. Additionally, the reporting requirements for Federal Credit Union charter applications in Section 3 have been substantially revised, altering the specific statuses and timelines that must be reported. The core purpose of requiring annual reports on application numbers remains unchanged.
Deletions
v1 required the National Credit Union Administration Board to report on Federal credit union charter applications that were 'proofs of concept established,' 'expired,' or 'mooted.'
The deletion of these specific statuses means that the National Credit Union Administration is no longer explicitly required to track and report on these particular stages or outcomes for Federal credit union charter applications. This narrows the scope of reported application statuses.
v1 required the National Credit Union Administration Board to report the 'mean and median times to establish proof of concept' for Federal credit union charter applications.
The removal of this reporting requirement means that the time taken for Federal credit union applications to reach a 'proof of concept' stage will no longer be publicly reported. This reduces the granularity of performance metrics available for the early stages of credit union chartering.
Modifications
This modification clarifies that agencies should report on their application processes even if they use terminology or procedures that differ from the specific terms listed in the bill, ensuring comprehensive reporting regardless of internal agency nomenclature. This broadens the applicability of the reporting requirements.
Before
Each section began with a directive for the respective agency to 'publish an annual report that includes--' specific items.
After
Each section now directs the agency to 'publish an annual report that includes the following, or with respect to any equivalent procedure used by the [Agency] includes the following:'.
The addition of 'To the extent practicable' introduces a degree of flexibility for the agencies in reporting common reasons for application outcomes. This acknowledges potential limitations in data collection or the ability to definitively categorize all reasons, potentially reducing the burden on agencies while still aiming for transparency.
Before
These paragraphs required reporting 'common reasons leading to denial, withdrawal, or expiration' (or similar phrasing) of applications.
After
These paragraphs now require reporting 'To the extent practicable, common reasons leading to the denial, withdrawal, or expiration' (or similar phrasing) of applications.
This is a minor technical correction, ensuring the directive is addressed to the correct entity within the National Credit Union Administration, without changing the operative effect of the reporting requirement.
Before
v1 directed 'The National Credit Union Administration Board' to publish the annual report.
After
v2 directs 'The National Credit Union Administration' to publish the annual report.
This change updates the specific statuses for Federal credit union applications that the National Credit Union Administration must report. It removes 'proofs of concept established,' 'expired,' and 'mooted' statuses, while adding 'inactive' and 'returned pending resubmission.' This provides a different set of metrics for tracking the lifecycle and outcomes of credit union charter applications, potentially reflecting current agency processes more accurately.
Before
v1 required reporting on Federal credit union charter applications that were 'received, proofs of concept established, approved on a final basis, denied, withdrawn, expired, mooted, or returned'.
After
v2 requires reporting on Federal credit union charter applications that were 'received, approved on a final basis, denied, withdrawn, inactive, or returned pending resubmission'.
This modification aligns the reported reasons for application outcomes with the updated list of application statuses in Section 3(1). It removes the focus on 'expiration of establishment of proof of concept' and instead requires reporting on reasons for 'inactivity' or applications being 'returned for resubmission.' The addition of 'To the extent practicable' also provides flexibility in this reporting, similar to other sections.
Before
v1 required reporting 'common reasons leading to denial, withdrawal, or expiration of establishment of proof of concept of such applications'.
After
v2 requires reporting 'To the extent practicable, common reasons leading to application denial, withdrawal, inactivity, or to applications being returned for resubmission'.
Scope
Minor adjustment within existing scope — Changes are scattered throughout the bill, affecting the introductory language of each reporting section and specific reporting requirements within them. — v2 represents a refinement of the existing policy direction, aiming to improve the practicality and accuracy of reporting without altering the fundamental requirement for transparency regarding application processes. — The changes primarily affect the specific details of the reporting requirements within each section, rather than interacting with or modifying other substantive provisions of the bill.
Impact analysis
Federal regulatory agencies (Comptroller of the Currency, National Credit Union Administration, Federal Reserve System, Federal Deposit Insurance Corporation)
Procedural flexibility; potentially reduces reporting burden for 'common reasons' where data is difficult to categorize definitively.
Agencies are now explicitly allowed to report on 'equivalent procedures' if their internal processes differ from the bill's specific terminology. They also have a 'to the extent practicable' qualifier for reporting common reasons for application outcomes.
Stakeholders monitoring Federal Credit Union charter application data
Information change; different insights into the credit union chartering process will be available, potentially aligning better with current NCUA processes but removing some previously required data points.
The specific metrics and statuses reported for Federal Credit Union charter applications have changed. Data on 'proofs of concept established,' 'expired,' and 'mooted' applications will no longer be reported, while data on 'inactive' and 'returned pending resubmission' applications will be included.