The Comptroller of the Currency,
the Federal Deposit Insurance Corporation, 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 depositary institutions, in cooperation with other responsible
authorities, are committed to identifying and eliminating illegal
discrimination and to encouraging nondiscriminatory 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 that may have a disparate impact on various
neighborhoods and communities. The various efforts of the agencies
have been directed toward the enforcement of prohibitions against
such discrimination, the development by the institutions they supervise
of appropriate remedial or affirmative 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
of the various civil rights laws of the nation. The agencies believe
that illegal discrimination is contrary to the best interests of 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 that they regulate should review periodically their employment
practices to ascertain that they are, in fact, nondiscriminatory 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 that 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 as either
members or guests.
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 that practices discrimination is
also discouraged.
Issued jointly by the Board of Governors
of the Federal Reserve System, the Office of the Comptroller of the
Currency, the Federal Home Loan Bank Board, and the National Credit
Union Administration, Oct. 16, 1979. 1979 Fed. Res. Bull. 903.