Joint Standards for Assessing Diversity Policies and Practices
Overview of Proposed Statement
• The CFPB, FDIC, Fed, NCUA, OCC, and SEC have proposed joint standards
for assessing the diversity policies and practices of the entities they regulate.
• Under the Dodd-Frank Act, the Director of each Office of Minority and Women Inclusion (OMWI) is required to develop standards for “assessing the diversity policies and practices of entities regulated by the agency.” Such standards take into account section 342(b)(4), which states that nothing in section 342(b)(2)(C) “may be construed to mandate any requirement on or otherwise affect the lending policies and practices of any regulated entity, or to require any specific action based on the findings of the assessment.”
• The agencies believe that the term “assessment” encompasses many different types of assessments including self-assessment and provides an opportunity for the agencies and the public to understand the diversity policies and practices of regulated entities. The assessment envisioned by the agencies is not one of a traditional examination or other supervisory assessment. Thus, the agencies will not use the examination or supervision process in connection with these proposed standards.
• The OMWI Directors have worked together to develop a set of proposed standards for assessing the diversity policies and practices of entities regulated by the agencies. In developing these standards, the agencies took into account individual entities’ circumstances.
• Comments are due to the agencies by February 7; please submit comments to CUNA by January 15.
Contact CUNA Senior Assistant General Counsel Luke Martone