NAFCU urges easier MDI self-certification
Oct. 1, 2013 –NAFCU Regulatory Affairs Counsel PJ Hoffman on Monday urged NCUA to ease the self-certification process under its Minority Depository Institutions Preservation Program.
“In order to help facilitate self-certification, NCUA should provide a portal on their website for credit unions to use when searching for the data necessary for self-certification,” he said in a letter Monday to the agency. “The portal or Web page should contain links to relevant data sources for the U.S. Census data, HMDA data, and others.”
The MDI Preservation Program is designed to preserve the number of minority-owned and -operated credit unions by providing technical assistance, educational opportunities and outreach to participants.
NCUA’s proposed interpretive ruling and policy statement for the program defines a federally insured credit union eligible for the agency’s MDI designation as one with:
- more than 50 percent of current or eligible potential members falling within any of the eligible minority groups; and
- more than 50 percent of current management officials falling within any of the eligible minority groups.
Hoffman noted that under the proposal, “credit unions with $50 million or less in assets may self-certify based solely on the knowledge of their membership, but must still meet the 50 percent of management officials MDI requirement.” Credit unions with assets of more than $50 million can rely on data from the U.S. Census, Home Mortgage Disclosure Act and voluntary data collected from members to determine its minority composition of current or potential membership for self-certification.
Along with NCUA offering a portal on its website to help credit unions with self-certification, Hoffman also suggested that an individual within the Office of Minority and Women Inclusion be designated as a point person who could handle credit unions’ questions about MDI eligibility. The OMWI would administer the MDI program.
Minority Depository Institutions Preservation Program comment letter (9-30-13)