NAFCU told the NCUA in a comment letter on Friday that more specific language is needed in the agency’s proposed diversity standards statement.
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 required the NCUA, the Fed, the OCC, the FDIC, the CFPB and the SEC to each establish an Office of Minority and Women Inclusion to develop standards for assessing the diversity policies and practices of the entities its agency regulates.
According to the proposed diversity policy statement, “the Agencies will not use the examination and supervision process in connection with these proposed standards.”
NAFCU asked the NCUA to clearly state that the proposed standards are not regulations or regulatory requirements subject to examinations.
“While this language can be construed broadly, NAFCU would urge NCUA to provide more targeted language either in the final policy statement or in guidance to follow that explicitly states credit unions will not be held responsible for having this as part of their examinations,” said Michael Coleman, director of regulatory affairs at NAFCU, in the letter to Gerard Poliquin, secretary of the board at the NCUA.
“This includes an assurance that credit unions will not be required to keep documentation for examiners and that this is not added to the examiner’s checklist,” Coleman added.
NAFCU also pointed out that credit unions work extensively with third party vendors to serve their members effectively.
The NCUA has addressed third-party relationships in Supervisory Letter 07-01, which outlines ways for credit unions to understand risk and balance their safety with their members’ best interests.
Coleman said the “Procurement and Business Practices – Supplier Diversity” section of the proposed diversity standards does not take into consideration where this guidance may be inconsistent with that supervisory letter.
“NAFCU urges the NCUA and the participating agencies to clarify how these policies and previous guidance can more clearly be implemented in concert,” Coleman wrote.
The extended comment period on the standards ended Friday.