Dear Board of Directors and Chief Executive Officer:
Federally insured credit unions, especially those with 100 or more employees, are encouraged to conduct and submit the Voluntary Self-Assessment Checklist to the NCUA’s Office of Minority and Women Inclusion before December 30, 2017. A copy of the self-assessment checklist is enclosed. The electronic version, instructions for completing it, a recorded webinar and video, and several other useful diversity-related tools and resources are located on the NCUA’s Credit Union Diversity webpage.
This voluntary collection is not part of the NCUA examination process and will have no impact on CAMEL ratings. There is no penalty for credit unions that have limited or no diversity practices in place. The NCUA will not publish diversity information that identifies any particular credit union or individual.
The NCUA, together with other federal financial regulatory agencies1 issued an Interagency Policy Statement in June 2015 establishing joint standards for assessing the diversity policies and practices of regulated entities. The policy statement was issued pursuant to a mandate in Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The statement encourages financial depository institutions, including credit unions, to consider adopting and incorporating these diversity standards into ongoing business and hiring practices. It is not a rule or regulation and does not create any legal compliance obligations; implementation or use of the diversity standards is completely voluntary.
For the purpose of the voluntary self-assessment, diversity is defined as minorities and women, consistent with Section 342(g)(3) of the Dodd-Frank Act. Minorities are defined as Black Americans, Native Americans, Hispanic Americans, and Asian Americans. However, a broader definition may be appropriate and can be used. For example, broader definitions may include people with disabilities, veterans, diverse age or faith groups, and lesbian, gay, bisexual, and transgender communities.
The diversity standards are summarized in the NCUA Letter to Credit Unions 15-CU-05. The standards provide a framework for credit unions to create and strengthen their diversity policies and practices, including their organizational commitment to diversity, workforce profile and employment practices, procurement and business practices, and practices to promote transparency of organizational diversity and inclusion. Each credit union may use the standards in a manner appropriate to its unique characteristics.
The NCUA Office of Minority and Women Inclusion aggregates the annual self-assessment data and only shares results anonymously. The data is used to monitor the credit union system’s progress and trends in diversity-related activities. The aggregate information is also used to highlight successful diversity policies and practices, primarily in the NCUA’s annual OMWI Congressional Reports.
We encourage you to use the checklist as a tool to assess your credit union’s diversity efforts, and as a source of diversity best practices. Diversity best practices are good business practices. Hiring qualified staff and vendors who reflect the diversity of your field of membership enriches the employee experience, extends member outreach, and provides a competitive advantage.
If you have any questions, please contact the NCUA’s Office of Minority and Women Inclusion at 703.518.1650 or by email at OMWImail@ncua.gov.
J. Mark McWatters
1 In addition to NCUA, the agencies include the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Bureau of Consumer Financial Protection, and the Securities and Exchange Commission.