DIMIA Major Assets Prohibition Thresholds & Minority/Women Institution Presumption
Current understanding
The National Credit Union Administration (NCUA) has proposed raising both major assets prohibition thresholds under the Depository Institution Management Interlocks Act (DIMIA) to $10 billion, updating figures set in 1996 to reflect subsequent growth in the U.S. banking market. The proposal would also remove a longstanding regulatory presumption favoring management interlocks involving minority- or women-controlled depository institutions. Practical effect: fewer institutions would be subject to the interlocks prohibition (easing shared-director restrictions for larger banks and credit unions), while minority- and women-controlled institutions would lose a targeted regulatory accommodation intended to help them recruit experienced directors. Status: proposed rule.
Evidence log
- 2025-06-18 — Broadcast VOICES Act: cross-connection with broadcast-voices-act-minority-radio-ownership: Both use minority/women-owned institution or ownership status as a trigger for preferential federal treatment, raising parallel questions about how ownership and disadvantage are verified under equal-protection scrutiny. (novelty: 3)
- 2025-06-10 — Broadcast VOICES Act: cross-connection with broadcast-voices-act-minority-radio-ownership: Both apply targeted federal presumptions or incentives to increase minority and women participation in regulated industries (broadcast ownership vs. major asset transactions). (novelty: 3)
- 2026-05-07 — Thresholds Increase for the Major Assets Prohibition of the Depository Institution Management Interlocks Act Rule: cross-connection with ecoa-special-purpose-credit-programs-rescission: Both roll back targeted regulatory provisions supporting minority- and women-oriented participation in credit and banking — one via removing a management interlocks presumption for minority/women-controlled depositories, the other via rescinding SPCP interpretive guidance. (novelty: 2)