2024 Plain Writing Report

August 2024

The Plain Writing Act of 2010 (act) requires federal agencies to write “clear Government communication that the public can understand and use.” The National Credit Union Administration fully complies with the law.

Compliance with the act is a priority among the NCUA’s leadership, managers, and staff. The agency works continuously to improve its performance. This report is provided for the 2023–2024 compliance period, completing the twelfth annual review of the NCUA’s compliance with the act.

Agency Official for Plain Writing

Elizabeth A. Eurgubian
Director, Office of External Affairs and Communications

Questions or comments concerning the agency’s plain writing efforts may be sent to plainwriting@ncua.gov. The NCUA’s plain writing webpage meets the act’s requirements for accessibility to agency implementation and compliance reports and includes:

A link to the Digital.gov website;
Writing guidelines used by NCUA personnel; and
Contact information for plain writing public comments.

Training and Resources

The NCUA periodically educates its staff about plain writing requirements and produces public documents that are easier for stakeholders to understand and use. Examples of those efforts are listed below.

The agency’s new internal plain writing SharePoint site provides staff with on-demand resources, writing examples, and trainings.
Chapter 2 of the NCUA Communications Manual provides staff with guidance on following plain writing principles.
The agency’s Office of Human Resources (OHR) provides a Writing for Examiners course and a Writing for Office Staff course. Upon request, OHR arranges writing classes tailored to each office’s needs.
Agency staff use standardized templates for memorandums, reports, and correspondence that incorporate plain writing principles and help ensure consistency and clarity in agency communications.

Agency Activities and Accomplishments

This section of the report details actions by individual NCUA offices to ensure compliance with the act.

Office of External Affairs and Communications

The Office of External Affairs and Communications (OEAC) continues to encourage employees to complete plain writing training, as well as other related writing courses that stress plain writing principles. In 2023, the NCUA produced a new internal website that provides one centralized location for staff to locate resources and training, making it easier and more convenient for employees throughout the NCUA to implement plain writing principles.

Office of Human Resources

The Office of Human Resources generated numerous communications that were distributed in various formats and were relevant to the full range of human resources and human capital programs. Some of the topics included, but were not limited to, employee engagement, student intern programs, training and development programs, benefits, wellness, compensation, performance management, workforce and succession planning, and other key programs and information related to the employee life cycle.

The Division of Staffing and Classification (DSC) has been actively developing guides and special presentations to assist NCUA employees with understanding the hiring process and meeting the requirements to successfully apply for positions. These resources simplify the online application process, delineate various sections of a vacancy announcement, and clarify the terminology and verbiage used in the federal recruitment processes.

Additionally, DSC implemented a recruitment dashboard that provides directors, managers, and supervisors with access to real-time information to support large-scale recruitment efforts. This dashboard displays clear information about the education and experience, as well as the average assessment scores of the candidate pool by duty location. It also provides insight into how candidates learned about the position, which aids NCUA outreach efforts.
The Division of Labor and Employee Relations (LER) uses plain writing when the NCUA management team drafts language for the Collective Bargaining Agreement provisions and Memorandums of Understanding with the National Treasury Employees Union. The LER also uses understandable language when developing training materials that outline changes to Collective Bargaining Agreement articles and memoranda of understanding that have wide impact.
The Division of Benefits and Worklife (DBW) coordinated multiple communications around the celebration of Public Service Recognition Week, ensuring each announcement was written in plain language and in compliance with the NCUA Communications Manual. Additionally, DBW authored and published internal Engagement Planning Guides, Accomplishment Reports, Federal Employee Viewpoint Survey (FEVS) results and revised the Incentive Awards Personnel Manual Chapter using plain language principles.

As shown in the chart below, the Division of Training and Development sponsored in-person plain writing training for examiners as part of the STEP 7 curriculum, online training on the act, and virtual instructor-led Writing for Examiners, Office Staff Training and Supervisors.

Classes	Audience	Number of Class Sessions	Number of Attendees/ Completions
Plain Writing, 1 day (As part of STEP 7 training)	All New Examiners (mandatory)	7	76 Federal 51 State
The Plain Writing Act (One online module)	All new NCUA employees when they onboard (mandatory)	N/A	143 Federal
Writing for Examiners, 2 days	Experienced examiners needing a refresher on plain writing principles (optional)	6	26 Federal
Writing for Office Staff, 2 days	Administrative and support staff (optional)	1	11 Federal
Writing for Supervisors, 1 day	Supervisors (optional)	1	5 Federal

The Division of Human Capital Systems and Planning (HCSP) is not a primary creator of communications intended for the public but is a contributor. As such, HCSP uses Plain Writing principles to ensure that communications are clear, concise, and well-organized.
OHR also authored multiple newsletters with information important to NCUA staff. All documents, messages, and online content were written to comply with the act and the NCUA Communications Manual.

Office of Credit Union Resources and Expansion

The Office of Credit Union Resources and Expansion (CURE) continues to incorporate plain writing principles when it creates print communications. CURE’s internal and external communications are subject to an editorial process that includes a review for compliance with plain writing standards, and supervisors review materials to ensure the text is understood and the tone is appropriate for the intended audience.

Print materials

Examples of print materials produced by CURE included:

An annual report to Congress on the NCUA’s stewardship of the Community Development Revolving Loan Fund appropriation, including a description of grants and loans awarded, a description of examples of funded activities, and trend data showing appropriations, grant requests, and grant awards for the past 10 years;
CDRLF grant application and post-award guidelines, which are available on the Grants page of the agency’s website;
An annual congressional report on the activities of the agency’s Minority Depository Institution (MDI) Preservation Program that included detailed financial performance information on MDIs and a narrative describing agency support efforts;
Board presentations on a proposed provisional charter concept and an updated Interpretive Ruling and Policy Statement with respect to MDIs;
Internal office training materials; and
Talking points, briefing papers, and materials for use by the agency’s Chairman and Board members.

Webinars and Training

CURE also produced webinars, videos, and online training courses for credit union management and staff that are posted on the agency’s Webinar Schedule page, its YouTube channel, and in the Learning and Management Service. These included:

Online courses:
- Serving the Underserved: Credit Invisibles
- Role of the Credit Union Board—Governance and Regulatory Oversight
- Understanding Financial Statements
A video course on Selecting a Credit Union Mentor
Webinars:
- The Simplified CECL Tool
- New Cyber Incident Reporting Rule
- Strategic Partnering
- Discovering MDIs: the Key to Building a Strong and Inclusive Financial System
- What Makes a Successful Credit Union?
- Ginnie Mae 101
- Loan Risk in a Changing Economy
- The CDFI Fund’s Small Dollar Loan Program

Office of National Examinations and Supervision

The Office of National Examinations and Supervision (ONES) emphasized plain writing skills with its staff, including several articles in the office’s newsletter on the subject. ONES staff completed report writing training sessions at ONES meetings. The training stressed using plain writing, writing in active voice, using simplified sentence structure, and making information easier to read using headers and bullets. In addition, the ONES’s report and document creation and review procedures include the following:

Using spelling, grammar, and Section 508 compliance checks for all documents;
Using and maintaining agency-approved templates for correspondence and examination reports that comply with the act and the NCUA Communications Manual;
Recommending plain writing-related revisions when asked to provide comments on instructions, regulations, and guidance documents;
Providing feedback during pre-release secondary reviews and quality control reviews when plain writing is not observed in examination reports; and
Reviewing correspondence prepared by all ONES staff on multiple levels to ensure it meets the requirements of the act and the NCUA Communications Manual.

Office of Minority and Women Inclusion

Within the Office of Minority and Women Inclusion (OMWI), the Diversity Communications Specialist prepares and reviews all communications the office develops. Through an established editing and review process, the specialist ensures compliance with the act and improves the clarity and effectiveness of all external and internal communications. The office’s Diversity Communications Specialist also assists staff individually with informal training on plain writing principles through editing written work products created by the office’s contributors. This feedback and guidance contribute to ongoing improvements in the quality of written communications from the office.

After the Diversity Communications Specialist reviews all external and internal communications, the OMWI Deputy Director and Director conduct a final review. Examples of products produced by the office using plain writing principles include the following:

OMWI Annual Report to Congress;
Congressional Report on Notification and Federal Employee Antidiscrimination and Retaliation Act;
Federal Equal Opportunity Recruitment Program Report;
Management Directive 715 Annual Report;
Employee Resource Group Network Program Annual Report; and
Credit Union Diversity Self-Assessment Results Report.

Office of Consumer Financial Protection

The Office of Consumer Financial Protection (OCFP) included plain writing principles in written communications, scripts, and visual content for videos, public broadcasts, and webinars for staff and external audiences.

Staff Training

OCFP held mandatory Plain Writing training for all staff. Throughout the year, staff receive consistent feedback on their written work from their direct supervisors to ensure they use plain language.

Consumer Education Resources

OCFP developed consumer educational resources (including content on the NCUA’s consumer-focused website, MyCreditUnion.gov) that is clear, concise, well-organized, and consistent with plain writing best practices. Prior to publication, OCFP conducted a rigorous review of resources to ensure the style and tone were appropriate for the intended audience and conformed to the act.

Examples of consumer education resources include the following:

The Money Basics Guide to Budgeting and Savings
The Money Basics Guide to Savings and Checking Accounts
How to Develop a Financial Education Program at Your Credit Union
Avoid Fraud and Scams When Using Person-to-Person (P2P) Payment Apps
Buy Now Pay Later
Financial Preparedness in a Disaster

Consumer Assistance Center Communications

OCFP continued to revise consumer call-center scripts to reflect clear and conversational language with consumers. Additionally, the office revised several templates for communicating with credit unions and consumers about the consumer complaint process.

Videos and Webinars

OCFP used plain writing principles to develop scripts and visual content for all videos, public broadcasts, and webinars.

Examples include:

2023 Interagency Outlook Live Fair Lending Webinar
Cornerstone Hike the Hill Fair Lending Presentation
Expanding Consumer Credit Options for Households with Disabilities
Closing the Wealth Gap: A Conversation on Black Wealth and Increasing Financial Equity
Financial Capability Month: Understanding Your Credit and Debt
African American Credit Union Coalition Commitment to Change Conversation: Why Financial Literacy Matters
Reframe the Shame: A Conversation About Financial Crimes Against Older Adults
Discovering MDIs: The Key to Building a Strong and Inclusive Financial System
Expanding Homeownership Opportunities by Combating Appraisal Bias
Make a Difference in Your Community by Supporting the IRS VITA Program
Protect Your Credit and Identity with Cybersecurity Awareness. In recognition of National Cybersecurity Awareness
NCUA Consumer Tips: Appraisals and Appraisal Bias
NCUA Consumer Tips: Protect Your Money with a Trusted Contact
Consumer Compliance: Supervisory Observations & Hot Topics

Consumer Compliance Resources and Fair Lending Exam Materials

During the reporting period, OCFP used plain language principles to inform federal credit unions about consumer financial protection laws and regulations and their compliance requirements. OCFP used plain language principles in written fair lending examination reports and supervision contact reports issued to credit unions.

Education Materials and Presentations

OCFP used plain language principles to develop numerous educational materials for NCUA staff.

Office of General Counsel

The Office of General Counsel (OGC) continues to implement principles of the act in its reviews of other offices’ written communications as well as in its own written communications. In the past year, OGC attorneys were actively involved with the agency’s reviews of various reports to Congress, such as the annual compliance report on evidence-based policymaking, prepared by the NCUA Chief Data Officer. These types of projects typically included some writing responsibilities as well as final reviews of documents for consistency, accuracy, and readability.

As in past reporting cycles, OGC attorneys have continued to perform peer reviews of draft work product, including regulations and legal opinions, and continuously have sought to decrease the use of legal jargon in written work product. Although regulations are not included as covered documents under the act, except for preambles, OGC still strives to make sure regulations are plainly written and understandable. When participating in new rulemakings and in revising existing regulations, OGC often recommends word changes to make the regulations clear and consistent. OGC supervisors continue to provide a second level review of external documents to ensure compliance with the act.

Regarding training, OGC attorneys continue to have access to on-demand training through the WestLegalEdcenter.com website which allows each attorney, in consultation with their supervisor, to select the writing course work most relevant for their practice area and training needs. OGC attorneys also are encouraged to engage in outside training courses offered through various bar associations or legal training centers. For example, in this reporting cycle, some attorneys took intensive, Advanced Legal Writing & Editing live interactive courses with Professor Bryan A. Garner, as part of their Individual Development Plans. Staff continue to review the handout materials from these writing courses for practical use in their daily work.

Office of Examination and Insurance

The Office of Examination and Insurance (E&I) is responsible for developing a wide variety of written products intended for agency, state supervisory authority, credit union, and public audiences. Its two largest publications are the Examiner’s Guide and the National Supervision Policy Manual. Additional guidance documents include the Call Report Instructions and the CUOnline User Guides.

Editing Procedures

E&I has two dedicated editors who are an integral part of E&I’s daily operations, including its approval process. The editors review and edit all releases for adherence to plain writing principles. The editors work with staff to update and electronically publish manuals and guides in an interactive format.

An example of efforts using plain writing principles is the Examiner’s Guide, a collection of several hundred pages of content. The guide follows a set format that includes easy-to-follow steps for examiners of all experience levels. Recent efforts to improve the usability of the guide include adding a highlight feature when performing a keyword search and an interactive glossary.

The office also emphasizes plain language in its essential staff and industry manuals, such as internal examination policies contained in the National Supervision Policy Manual. Two version updates were released this past year. Staff and technical editors update the content in the Examiner’s Guide and National Supervision Policy Manual on an ongoing basis to provide up-to-date policies and guidance to examination staff, while adhering to plain language standards.

Staff Training

During the third quarter of 2023, E&I’s editors conducted a total of three plain writing training sessions. To prepare for the sessions, E&I’s editors surveyed staff to understand the most common issues and tailor the training to meet real-time needs.

Resources

To supplement training, E&I’s editors have developed resources to assist their colleagues in writing to federal plain language standards.

Office of the Chief Information Officer

The Office of the Chief Information Officer (OCIO) reviews formal correspondence and written reports prior to dissemination for compliance with the act, including reports, memorandums, alert notifications, and data requests. OCIO also encourages staff to seek information and attend training focused on clear communications and plain writing.

Office of Continuity and Security Management

The Office of Continuity and Security Management (OCSM) reviews all formal correspondence and written reports prior to dissemination for compliance with the act, including reports of findings, memorandums, after action reports, alert notifications, and data requests. All formal OCSM documentation is routinely reviewed by multiple staff from different areas of expertise to ensure clarity of content. OCSM does not typically create public facing content, but directly supports the Office of the Executive Director in the development of agency wide policy on issues related to safety, such as pandemic response policy, which may result in public facing documents. The multi-staff level review serves as an initial training platform for plain writing. Additionally, all OCSM training documents and presentations are reviewed by staff who do not specialize in the topic area to ensure the material is drafted in plain language.

Office of Ethics Counsel

The Office of Ethics Counsel (OEC) strived to apply the principles of the act in all OEC written communication, including individual employee advice, guidance documents, reports to management, staff training, and website content. To promote effective communication, staff is encouraged to follow the NCUA Communications Manual and to prioritize clarity and readability without compromising technical accuracy. For example, over the past year, OEC made efforts to streamline and simplify the notices of potential conflicts of interest and guidance provided to NCUA financial disclosure filers to improve understanding.

OEC also uses a robust peer review and supervisory review for any written products that are disseminated agency-wide or are releasable to the public. Occasionally, OEC seeks input from subject matter experts at other federal agencies to eliminate ambiguity and increase consistency government-wide on common topics. OEC understands that stakeholders, both internal and external to the NCUA, find some aspects of the laws and regulations of the Ethics and Anti-Harassment Programs to be opaque and difficult to navigate. OEC works diligently to make the requirements of these two programs meaningful to all stakeholders by using understandable, plain language.

Office of the Chief Economist

The Office of the Chief Economist (OCE) staff ensured that internal and external products were well written and understandable. In support of those objectives, the office utilized a workflow where a senior staff member reviewed written products before they are widely disseminated. While such reviews ensure that factual errors are identified, a primary review objective was ensuring that economic concepts are clearly explained and that key statistical findings are well articulated. OCE provides training on plain writing principles, when needed.

Office of Business Innovation

The Office of Business Innovation (OBI) upheld plain language standards for both internal and publicly disseminated products. Staff regularly reviewed and revised language, as necessary, to ensure memos, documents, and presentations complied with the NCUA Communications Manual and agency templates. For example, all user guides and training materials are reviewed before dissemination to system users or posted on the NCUA’s webpages.

Additionally, staff reviewed internal and external web-based postings to ensure application of plain writing guidelines and agency templates, including updates to content on the Data Exchange Application and the Share and Loan Record Layout Specification webpages.

Office of the Chief Financial Officer

The Office of the Chief Financial Officer (OCFO) used plain writing principles and quality control in the following documents: Board Action Memorandums and related documents for the agency’s:

2023 Midsession Budget;
2023–2024 Budget Justification;
NCUA Strategic Plan 2022–2026;
2023 Annual Performance Plan; and
2023 Annual Report.

In management’s review process of public-facing documents, plain writing attributes are communicated to staff who author documents. This serves as a form of continuous feedback and on-the-job training. Materials for external parties are reviewed under a normal supervisory review process with the final sign-off by OCFO management. External facing documents undergo further review by a technical editor prior to publication.

Asset Management and Assistance Center

The Asset Management and Assistance Center (AMAC) maintains a document library of approved templates for correspondence. These templates are reviewed, updated, and approved prior to publishing to ensure consistent use of plain writing principles. AMAC also incorporates a peer review of documents for readability and use of plain writing principals prior to issuance. AMAC held a dedicated training session on plain writing principals and staff receive bi-weekly briefings on policy and template updates. These briefings also include plain writing topics. AMAC recently updated the liquidation payout brochure to simplify the language and better align with plain writing requirements.

Office of the Inspector General

The Office of the Inspector General (OIG) continued to follow the Act’s requirements when reviewing and revising covered documents, as well as consistently producing publications that were well-organized, clearly written, concise, and reflected strong analysis. The OIG incorporated the principles of plain writing in their work by ensuring that audit and investigative reports were succinct and clear. They utilized the agency’s Communications Manual to implement agency standards and best writing practices. The OIG limited the number of acronyms in work products. If a report contained any acronyms, they included an acronym definitions page in the report.

Office of the Executive Director

The Office of the Executive Director (OED) conducts enhanced internal and external correspondence reviews in partnership with OEAC and the NCUA Chairman’s office. OED staff, OED management, the Executive Director, and OEAC management, review these communications for content and quality before they are widely disseminated, and ensure they are properly vetted with agency subject matter experts for conformity with agency communication policies. In addition, for public-facing communication and publications, OED contracts with FedWriters which provides technical editors who review documents and ensure compliance with the act. This service helps ensure clarity, conciseness, and compliance with regulatory standards, guaranteeing that documents are accessible and understandable to all stakeholders.

Eastern Region

The Eastern Region communicated monthly plain writing tips to its staff and reviewed office correspondence and examination reports for plain writing standards. Staff are evaluated annually during performance appraisals on their ability to apply plain writing techniques. Training is required for Eastern region staff, as needed.

Western Region

The Western Region maintains and updates correspondence templates, provides continuous feedback to staff, and implements training exercises during staff meetings to comply with the act. The region also encourages staff to attend webinars and other plain writing training.

Southern Region

The Southern Region ensures compliance with the act by reviewing examination reports, maintaining, and updating correspondence templates, and reviewing all correspondence prepared for external and internal parties to ensure compliance with the act. Additionally, the Southern region shares guidance periodically for examiners concerning the fundamentals of the act and evaluates field staff’s plain writing techniques on an annual basis during the performance appraisal process.

Future Actions

While the NCUA has improved communications during the reporting year, the agency recognizes that more can be accomplished. In that regard, the Office of External Affairs and Communications is updating the agency’s Style Guide, formerly the NCUA Communications Manual, and anticipates finalizing that guide in 2024. The agency will continue to conduct plain writing training, especially after the NCUA Style Guide is finalized, and review other internal processes and templates to further improve the NCUA’s performance in plain writing.