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NAFCU Regulatory Affairs Counsel Alexander Monterrubio urged NCUA to allow credit unions to submit anonymous self-assessments under the voluntary joint policy statement on diversity standards adopted by the agency in June.

Monterrubio pointed out that anonymous self-assessments will "encourage increased participation and candor." He also noted that, while participation in the assessments is voluntary and that NCUA allows credit unions to designate their information as confidential, the information submitted could still be requested by a member of the public through a Freedom of Information Act (FOIA) request.

"This process creates a situation where a credit union could potentially have its volunteered information released to the public," Monterrubio wrote. "NAFCU believes that in order to ‘enhance the quality, utility, and clarity of the information collection' and ‘minimize the … burden on respondents' credit unions should be given the option to submit information anonymously, not just confidentially."

NCUA has emphasized that the standards established by an interagency statement in June are voluntary and will not be incorporated into examinations. NCUA and five other financial regulators issued a final interagency statement establishing standards for financial institutions to follow in creating and maintaining diversity policies and practices; the agencies did this to comply with Section 342 of the Dodd-Frank Act.

The voluntary standards are meant for financial institutions with more than 100 employees. NCUA estimates that there are 619 federally insured credit unions with 100 or more employees, employing 68 percent of all employees who work for federally insured credit unions.

The NCUA letter also includes a voluntary, sample self-assessment checklist.