The Missouri Credit Union Association (MCUA) recently filed a comment letter on a proposed interagency policy statement establishing joint standards for assessing the diversity policies and practices of regulated entities, which was issued by the National Credit Union Administration (NCUA) and other federal financial regulators. While MCUA strongly supports diversity in the workplace, they have a number of concerns and recommendations regarding specific aspects of the proposal, as described in their letter.
MCUA urges the agencies, while considering the limits of their authority, to be cognizant of the regulatory burdens that smaller financial institutions such as credit unions face and to limit the scope of the standards to those entities that are currently required to report to the Equal Employment Opportunity Commission (EEOC).
MCUA also urges 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 work force within the context of promoting diversity in the work place.
While MCUA strongly favors a self-assessment approach over an examination-based approach, even a self- assessment under the proposed standards is likely to be quite burdensome for many credit unions, including those already reporting diversity data to the EEOC.