NCUA Clarifies New Call Report Questions’ Intent
January 17, 2012
January 17, 2012
The National Credit Union Administration (NCUA) has clarified that new questions addressing minority credit unions and workplace diversity, which were added to fourth-quarter call report documents with no explanation from the agency, are required by the Dodd-Frank Wall Street Reform Act.
The questions are:
- Does your credit union have more than 50 percent of its current members and management officials who are Black American, Native American, Hispanic American, or Asian American? If yes, please identify the minority groups(s) that apply.
- Does your credit union have more than 50 percent of its eligible potential members and management officials who are Black American, Native American, Hispanic American, or Asian American? If yes, please identify the minority groups(s) that apply.
One of the key things to note is the word “and.” A credit union must meet both conditions to answer “yes” to the questions.
The NCUA noted in its clarification sent to credit unions that the conditions in each question must be true for a credit union to be considered a minority credit union (MCUA).
Credit unions that answer “yes” are also asked to identify the minority groups(s) that comprise its membership or management.
The NCUA’s Office of Minority and Women Inclusion (OMWI), which is tasked with ensuring equal employment opportunity and workplace diversity at the NCUA and in the credit unions the agency regulates, is developing a program for preserving minority credit unions—as instructed under Dodd-Frank—and these questions will help the NCUA develop this program.
The NCUA has also added new questions on workplace diversity to the Credit Union Profile under “Regulatory Information,” but the questions are only to be answered by credit unions with 100 or more employees or credit unions with 50 or more employees that serve as a depository of government funds, serve as issuing and paying agents of U.S. Savings Bonds or Notes, or have a Federal Government contract of at least $50,000.
The NCUA doesn’t consider federal share insurance a government contract for purposes of this requirement, the Credit Union National Association (CUNA) has noted.
Credit unions have to provide the date on which they last filed the required EEO-1 Survey Report with the Equal Employment Opportunity Commission (EEOC) and must answer “yes” or “no” if they have a “diversity policy or program.”
These questions are meant to assess the number of credit unions that have diversity policies and practices in place and determine credit union compliance with EEOC reporting requirements, the agency has said. The NCUA has not established standards for diversity programs, but more guidance related to diversity programs could be released.
Questions? Contact the Compliance Hotline: 1.800.546.4465, firstname.lastname@example.org.