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Diversity standards cannot be one-size-fits all: CUNA to NCUA
WASHINGTON (2/10/14)--Credit unions strongly support diversity in the workplace, but the Credit Union National Association is concerned about the one-size-fits-all approach of a proposed joint agency statement for assessing diversity policies and practices of financial institutions.

CUNA urged the rulemakers to clarify that the standards are not subject to enforcement and to limit their application to those institutions that are already reporting to the Equal Employment Opportunity Commission.

The proposed standards would encourage regulated entities to include diversity and inclusion considerations in both employment and contracting as an important part of their strategic plan.

The Dodd-Frank Act charged regulators with developing assessment standards regarding financial institutions' diversity policies, but did not authorize them to enforce them or subject institutions to additional supervision.

The NCUA, Federal Reserve, Consumer Financial Protection Bureau, Federal Deposit Insurance Corp., Office of the Comptroller of the Currency and the Securities and Exchange Commission developed the standards.

CUNA Deputy General Counsel Mary Dunn in the comment letter noted that while the U.S. Congress directed those agencies to develop standards for assessing diversity at the entities they regulate, it did not authorize the agencies to issue rules or enforce any new standards. An overall approach that does not result in new regulations, additional enforcement powers for regulators, or provide further support for private causes of action against covered entities is the only approach consistent with the intent and language of the Dodd-Frank Act, Dunn wrote.

The CUNA letter also urged the NCUA and other agencies to be cognizant of the regulatory burdens that smaller financial institutions such as credit unions face.

"We also urge the agencies to change and clarify the standards in a number of areas and to reflect in the standards the importance of developing a well-qualified workforce within the context of promoting diversity in the workplace," Dunn wrote.

For the full CUNA comment letter, use the resource link.
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CUNA Comment Letters
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