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FEDERAL RESERVE BANK
OF NEW YORK

POLICY STA TEM EN T ON DISCRIM INATION
BY FIN A N CIA L INSTITU TIO NS

To All State Member Banks, and Others Concerned,
in the Second Federal Reserve District:

The Federal Financial Institutions Examination Council has announced that the
five Federal bank and thrift institution regulatory agencies represented on the Council
have adopted a policy statement on discrimination by financial institutions. The
statement concerns discrimination in providing lending and other financial services and
in employment practices.
A copy of the policy statement is enclosed. Questions regarding this matter may be
directed to Samuel H. Talley, Assistant Director, Division of Banking Supervision and
Regulation, Board of Governors of the Federal Reserve System (Tel. No. 202-452-3354),
or to this Bank’s Regulations Division (Tel. No. 212-791-5914).




T h o m a s M. T i m l e n ,
First Vice President

Federal Firuikta Inditutivn1' Examination Council. Waslun^tcm. L K \ 2021°

POLICY STATEMENT ON DISCRIMINATION

The Comptroller of the Currency, the Federal Deposit Insurance Corpora­
tion, the Federal Reserve Board, the Federal Home Loan Bank Board and
the National Credit Union Administration, as federal agencies responsible
for the regulation and supervision of depository institutions, in
cooperation with other responsible authorities, are committed to
identifying and eliminating illegal discrimination and to encouraging
non-discriminatory practices in the operations of these institutions.
Over the years, the attention of the federal financial regulatory
agencies has focused especially on such matters as discrimination on
the basis of race, religion, national origin, sex, and marital status
in the provision of lending and other financial services and the
discriminatory aspects of mortgage and other lending practices which
may have a disparate impact on various neighborhoods and communities.
The various efforts of the agencies have been directed towards the
enforcement of prohibitions against such discrimination, the development
by the institutions they supervise of appropriate remedial or affirma­
tive actions to help eradicate the effects of past discrimination, and
the sponsorship or support of numerous special-emphasis programs that
have the objective of assisting the financial institutions to meet
the credit needs of all segments of the communities which they serve.
Within the boundaries of their jurisdiction, the five federal financial
regulatory agencies are committed to effective enforcement or the
various civil rights laws of the nation. The agencies believe that
illegal discrimination is contrary to the best interests or not only
the people discriminated against but also the financial institutions
themselves.
The provision of employment opportunity without discrimination on any
prohibited basis is first and foremost the legal responsibility of the
employer, and it is the policy of the agencies that the financial
institutions which they regulate should review periodically their
employment practices to ascertain that they are, in ract, non—discriminate
and, to the extent that any discrimination is found, adopt appropriate
remedial policies and practices to eliminate it.
Such an examination of employment practices should include consideration
of the institutions’ policies regarding the payment of dues on behalf
of employees to private clubs which discriminate on the basis of race,
sex, religion, color, or national origin. Because business is commonly
conducted at such clubs, membership prohibition may have an adverse
and discriminatory effect upon the career advancement of employees who
are denied equal opportunity to access either as members or guests.
B o a rd o f G o v e r n o r s o f th e Federal R eserve S y s te m
N a t io n a l C r e d it U n io n

A d m in is t r a t io n .




Fe deral D e p o s it In s u ra n c e C o r p o r a t io n .

O f f ic e o t th e C o m p t r o lle r o f th e C u r r e n c y

Fe deral H o m o L o a n S a iA B o a rd .

POLICY STATEMENT ON DISCRIMINATION

Page 2

For this reason, the agencies discourage the payment by financial
institutions, on behalf of their employees, officers or directors, of
fees or dues for membership in private clubs where business is
commonly conducted, which so discriminate. Payment by financial
institutions of the costs of any business or social function held at
any such club or organization which practices discrimination is also
discouraged.