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Standards for Assessing Credit Unions' Diversity Policies & Practices

As reported previously, National Credit Union Administration (NCUA), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Fed, Office of the Comptroller of the Currency (OCC), and Securities Exchange Commission (SEC) have proposed joint standards for assessing the diversity policies and practices of the entities they regulate. Credit Union National Association (CUNA) encourages credit unions to take a look at the CUNA Regulatory Advocacy Call to Action and provide feedback on the proposed standards by early December. CUNA wants to make sure they are aware of issues and concerns well ahead of the December 24 comment deadline so they can be addressed in the letter. The Missouri Credit Union Association (MCUA) requests that you send a copy of your feedback to them via email.

Under the Dodd-Frank Act, the director of each agencies’ Office of Minority and Women Inclusion (OMWI) is required to develop standards for “assessing the diversity policies and practices of entities regulated by the agency.” The Act explicitly states that such standards may not “be construed to mandate any requirement on or otherwise affect the lending policies and practices of any regulated entity, or to require any specific action based on the findings of the assessment.”

The agencies believe that the term “assessment” encompasses many different types of assessments including self-assessment and provides an opportunity for the agencies and the public to understand the diversity policies and practices of regulated entities. The assessment envisioned by the agencies is not one of a traditional examination or other supervisory assessment. Thus, the agencies should not be able to use the examination or supervision process to enforce the proposed standards. That is an issue CUNA will certainly be commenting on in their letter.