Analysis of NCUA diversity policies, practices letter available
June 29, 2015 -- We have posted our analysis (members only) of NCUA’s letter to credit unions on diversity policies and practices, which was released by the agency late last week.
The letter (LTCU 15-CU-05) is intended to inform credit unions of an interagency policy statement establishing standards for assessing the diversity policies and practices of federally insured credit unions. NCUA includes a voluntary self-assessment template with its guidance. Other federal banking agencies issued similar guidance to their regulated entities. The policy statement was required by the Dodd-Frank Wall Street Reform and Consumer Protection Act.
Some key points in NCUA's guidance:
- The policy statement is not a new rule or regulation; it does not create any legal compliance obligations;
Implementation or use of the diversity standards by credit unions is completely voluntary;
- The agency won’t incorporate review of credit union diversity policies and practices in its examination and supervision program;
- The agency will announce annual submission dates for credit unions willing to conduct the self-assessment, and submit their data to the agency;
Data voluntarily submitted by credit unions to the agency will be aggregated and anonymized, and submitted to Congress as part of an annual report.
Examples of NCUA’s aggregated disclosures are found in past OMWI Congressional Reports.
While the policy statement is “applicable” to any federally insured credit union, NCUA encourages credit unions with at least 100 employees, in particular, to review the policy statement. NCUA reminds credit unions that “diversity best practices are also good business practices.
See the full NASCUS analysis of the letter here (members only).