Our 100 million credit union members are diverse. They reside in different states, cities, towns and hamlets. Members come from a broad swath of socio-economic backgrounds, some are the underserved and affluent, white and non-white, male and female, professionals and volunteers, blue-collared and white-collared, the list goes on and on. It's this diversity that makes our credit union movement strong.

However, diversity must be more than just anecdotal and cliché. True diversity must be substantive and participatory. To that end, the African-American Credit Union Coalition has forwarded a letter to Chairman NCUA Debbie Matz respectfully requesting a status update on the position of Director in the Office of Minority and Women Inclusion. The AACUC is the premier African-American credit union organization whose mission is to increase the strength of the credit union community through advocacy, professional development and diversity. In alignment with that stated mission, I believe it is imperative that this important position be filled.

Section 342 of Dodd-Frank not only requires each financial regulatory agency to establish an OMWI, but said agencies must appoint a director in the senior executive service who shall develop standards regarding equal employment opportunity and the racial, ethnic, and gender diversity of the workforce and senior management; increased participation of minority and women-owned businesses in the programs and contracts of the agency; and assessing the diversity policies and practices of entities regulated by the agency. To date, a director has yet to be chosen or announced for over a one-year period.

Additionally, in early 2014, several financial regulators, including the NCUA jointly requested comments on a Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies. Stakeholders were encouraged to submit comments on or before Feb. 7, 2014.

Currently, the final rule has not been issued, despite the anticipated release date at the end of 2014, according to Ballard Spahr, LLP, a CFPB monitor. Nevertheless, Spahr is of the opinion that "two reports recently issued by the Offices of Inspector General at the FDIC and the Office of the Comptroller of the Currency may provide some insight on the impending final standards." Both offices reported to the House Financial Services Committee "that more could be done."

It is my hope that the NCUA announces the appointment of an OMWI director sooner rather than later. Moreover, I am optimistic that the several financial regulators will issue a joint final rule that is substantive and meaningfully aligned with the intent of Section 342 of Dodd Frank.

If Ballard Spahr is correct in its prediction of greater government scrutiny of diversity practices by the credit union community, it behooves the NCUA to appoint an OMWI leader with the strategic vision necessary to accomplish the diversity goals established by Dodd-Frank.

Mark Brantley is chairman of Municipal Credit Union and vice chairman of the African-American Credit Union Coalition. He can be reached at 347-835-2047 or [email protected].