CUNA told the NCUA in a comment letter on Friday that theagency's proposed diversity standards would place a burden oncredit unions.

The extended comment period for the standards for the NCUA andseveral other agencies ended Friday.

READ NAFCU's comment on the proposedstandards.

“Congress provided only very narrow authority to the agenciesunder the Dodd-Frank Act regarding diversity issues at financialinstitutions. To impose new requirements or seek to enforce newstandards under the Act would be contrary to the directives ofCongress,” wrote Mary Dunn, CUNA deputy general counsel, in theletter to Gerard Poliquin, secretary of the board at the NCUA.

Dunn cited a portion of the law that said subsection342(b)(2)(C) “may be construed to mandate any requirement on orotherwise affect the lending policies and practices of anyregulated entity, or to require any specific action based on thefindings of the assessment.”

Based on that part of the law, Dunn said an “overall approachthat does not result in new regulations, additional enforcementpowers for the agencies, or provide further support for privatecauses of action against covered entities is the only approachconsistent with the intent and language of the Dodd-Frank Act.”

The Dodd-Frank Act, signed by President Obama in 2010, requiredthe NCUA, the Fed, the OCC, the FDIC, the CFPB and the SECto establish anOffice of Minority and Women Inclusion which would developstandards for assessing the diversity policies and practices withinthe entities they regulate.

Dunn said the diversity standards would place manual reportingrequirements on credit unions.

“It would likely mean that a number of credit unions would berequired to gather employee-related diversity data manually. For credit unions, this would likely require significant resourceexpenditures when many are already struggling to comply with theonslaught of recent and forthcoming regulations, including thoseunder the Dodd-Frank Act,” Dunn wrote.

As a result, Dunn said CUNA urges the NCUA and the otherregulators to “limit the applicability of the standards underSection 342 to EEOC-reporting institutions.”