Compliance is the baseline for credit union diversity-equity-inclusion programs
As credit unions increasingly embrace diversity, equity, and inclusion (DEI) initiatives and seek to better represent and serve their ever-changing communities, understanding the regulatory components that touch such initiatives is an important starting place.
For example, laws such as the Equal Employment Opportunity (EEOA) and Equal Credit Opportunity (ECOA) acts outline baseline requirements for employers and financial services organizations to follow to ensure equal treatment regardless of ethnicity, national origin, gender and other protected classes. Viewed from a different perspective, these laws provide the baseline for inclusivity in hiring and lending.
While the EEOA speaks to the area of human resources, which is a robust area in and of itself, let’s focus on DEI from a membership standpoint. Certainly, few if any credit unions today consciously or actively discriminate against particular groups based on national origin, race, religion, or other criteria. But inclusion involves more than mere non-discrimination. It means proactively reaching out to underrepresented groups, understanding their needs, and striving to meet those needs through the credit union’s products and services in a compliant manner.
Adjusting Products and Services
Credit unions, like all organizations, have to make business decisions on a variety of matters every day. One such business decision could be expanding their services to underrepresented groups. A way to ensure the credit union is addressing the community at large is to consider the changing demographics in its membership area and aligning account opening and lending practices accordingly. If the credit union is serving immigrant groups for example, this may require an update to a member identification program, lending policies and procedures, in order to be inclusive of all.
End-to-end Mindfulness
It is important to keep the needs of the target community in mind from end-to-end, all the way from advertising to member service on the front-line. For example, if a credit union advertises its services on its website or elsewhere in a language other than English, be sure to have employees available to speak to members in that other language. This will not only make non-English speaking members more comfortable working with the credit union and can reduce misconceptions or misunderstandings among non-English speaking members, this will help you avoid any potential UDAAP ( Unfair, Deceptive, or Abusive Acts or Practices) violations and overall will avoid misleading members into thinking you offer services in another language if in fact you don’t
If you are going to provide materials in another language, a translation strategy is also important to ensure all relevant information is accurately translated, leaving no room for misunderstandings. Because there can be many ways to translate a word or phrase from one language to another, it is important to seek experts who not only understand the native language being translated to, but also understand financial and credit union terminology for any required translation work. Accuracy, consistency, and relevancy are important in translations. Avoid using Google Translate for something this important and seek outside consultants, if necessary, to assist.
Going Beyond Traditional Approaches
Serving diverse population groups is part of the credit union creed. While there are always regulations to consider, there are also many opportunities to grow credit union membership by tailoring products and services to specific needs of the membership base.
Serving people with non-traditional forms of identification, such as a consulate card, is one example of new membership a credit union could be serving. By expanding services to include underserved members and updating the credit union’s member identification policy and procedures to include non-traditional forms of identification, you do not have to turn down membership.
The IRS’s Individual Taxpayer Identification Number (ITIN), which is a taxpayer identification number that some immigrants may have, is a valid taxpayer identification number that credit unions can accept to lend and open interest-bearing accounts.
Another opportunity to be inclusive in lending is through the underwriting process. Members without traditional credit histories may not have the traditional forms of documentation you seek to verify credit, however, this does not mean that they have not established credit. The credit they have established however may be found in non-traditional sources such as alternate payment data, including that found in paying recurring bills such as utilities, or rent. While this likely would not alter your lending policy, it would require a change in underwriting procedures to ensure your requirements list is as inclusive as possible. This would apply for anyone seeking a loan at your credit union, whether it’s a young college student or a recent immigrant.
To achieve success in DEI initiatives you need to go beyond meeting the regulations. The regulations provide a baseline framework, however, it takes initiative and a commitment to ensure you go beyond what’s required to what’s needed in your communities.
