The recent interagency guidance on improving diversity standards among banks and credit unions was an issuance, not a rule, but financial institutions will ignore that issuance at their own peril, according to Donna Cameron, regulatory and compliance expert with Continuity, a New Haven, Conn.-based provider of automated compliance solutions.
"We don't recommend you put this aside," Cameron, one of two Continuity webinar presenters on the topic, said. "You should consider it and make an intentional decision to have a program of some sort to address diversity in your financial institution."
The guidelines, jointly issued June 10 by six financial regulatory agencies including the NCUA, is a byproduct of a Dodd-Frank Act directive instructing each agency to develop an Office of Minority and Women Inclusion. The recommendations are designed to promote the development of standards that financial institutions can use to assess their own diversity and inclusion policies and practices for employment and vendor selection.
The new guidelines differ from past directives in that they are designed to foster a change in the organization that goes beyond serving mere numbers to create a greater cultural awareness, according to webinar co-presenter and attorney Michael Bookser.
"The guidelines do not create quotas [of minority members served or employed by the financial institution]," Bookser said. "It means that you're creating a culture in your institution that nurtures diversity."
All financial institutions are subject to the issuance, but the guidelines are designed to address institutions with 100 or more employees, Bookser said. While compliance is strictly voluntary, the attorney suggested that financial institutions of all sizes review and apply standards appropriate to their institution.
For the purposes of the guidelines, "diversity" means women and people of color, specifically African-Americans, Native Americans, Hispanics and Asian Americans, Bookser noted. It's also acceptable to broaden the definition to include other groups, such as the categories referenced by the EEOC in the EEO-1 report and individuals with disabilities, veterans and LGBT individuals.
The webinar identified five "pillars" that support any institution's diversity and inclusion program: Commitment, employment practices, vendor diversity, transparency and self-assessment. Institutions that choose to adopt these standards should plan on having some level of involvement in each of the five areas, Bookser said.
Having an appropriate policy and strategic plans is the single thread that runs throughout all five areas, Bookser said. Moreover, diversity obligations should be overseen at the board and management level so it becomes clear to regulators asking questions that the institution supports a diversity culture, and that it's not just another program within the institution, he added.
"This is not something unleashed and never discussed," Bookser noted. "Management should be in charge of bringing this forward for their institution."
Establishing a board policy is the best way to implement a diversity program, the webinar presenters said. A written plan then follows policy creation, with a self-assessment period to monitor progress and the ability to record and report steps taken should regulators ever question an institution's diversity initiatives.
In addition, the presenters suggested that HR and vendor management systems be updated to make sure they contain standards in step with the new issuance. Staff training and materials that meet the guidelines also go a long way toward addressing diversity compliance, presenters said.
According to the Final Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies, the formal document that outlines the diversity suggestions, the additional recordkeeping burden in following the issuance should have a minimal additional effect on an institutions workload.
"The agencies estimate that it would take a regulated entity approximately 12 burden hours on average to annually publish information pertaining to diversity policies and practices on the entity's website or in other appropriate communications, and retrieve and submit information pertaining to the entity's self-assessment of its diversity policies and practices to the primary federal financial regulator," language within the June 10 document itself explained
Cameron noted that the estimated additional recordkeeping may include board approval of the process, appointment of a diversity officer, and revamping of new employee and new vendors selection processes to make sure they properly address diversity issues. Other affected areas may include changes in employee promotion processes, outreach activities, training records and the publication history of the necessary information to meet the issuance's recommendation.
All of the information then needs to be pulled together to create reports to the board, annual self-assessments and other communiques that need to be created, Cameron noted.
"Twelve hours? Really?" she asked. "This doesn't seem like quite enough time if you are performing this process manually."
Daunting or not, adhering to the advice within the issuance is something all institutions should do, Cameron, a banking industry veteran, said.
"The agencies are encouraging adoption, but we who have been in the business believe encouragement leans ultimately toward application," she added.
© 2025 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.