CUNA has written NCUA's Office of Minority and Women Inclusionto urge the agency implement one of the requirements of theDodd-Frank Act with as little additional reporting requirements aspossible.

Section 342(b)(2)(c) of the Dodd-Frank Act requires Federalfinancial regulators, including the NCUA, to set up offices ofminority and women inclusion and staff the offices with directors.The offices are responsible first for monitoring the diversity andinclusion practices of the agencies themselves as well as“assessing the diversity policies and practices of entitiesregulated by the agency.”

It's this last requirement that led CUNA, with credit unionexecutives, to meet with the office's director Tawana James onFebruary 29 and to have written her a letter on March 26 expressingconcern about a possible requirement to assess the diversitypractices of credit union contractors and suppliers.

“Nevertheless, there is not an express requirement in thelanguage of Section 342(b)(2)(c) requiring OMWI to develop anystandards relating to assessing diversity practices or policiesspecifically relating to credit unions' contractor and supplierrelationships< the association wrote. “Since it is not requiredunder the statute, and because it would be unduly difficult – andperhaps impossible – for our members to collect such information,CUNA recommends that OMWI exclude data relating to contractor andsupplier relationships from any assessments it will implement underSection 342.”