Public Comment

July 15, 2011
VIA E-MAIL TRANSMISSION
www.regulations.gov
Stephen Llewellyn, Executive Officer
Executive Secretariat
Equal Employee Opportunity Commission
131 M Street, NE, Suite 6NE03F
Washington, DC 20507
RE:

Proposed Rulemaking Regarding Recordkeeping and
Reporting Requirements under Title VII, the ADA and GINA
RIN 3046-AA89

Dear Mr. Llewellyn:
We appreciate the opportunity to respond on behalf of our member credit unions to the
rules proposed by the Equal Employment Opportunity Commission regarding the
recordkeeping and reporting requirements for the implementation of the Genetic
Information Nondiscrimination Act of 2008 (“GINA”). The Illinois Credit Union League
represents over 400 credit unions operating in Illinois.
As proposed, we support the recordkeeping responsibilities as the record retention
responsibilities for GINA mirrors that of Title VII and the ADA. Consistency among
recordkeeping responsibilities ensures appropriate record retention.
We appreciate the opportunity to provide our input to the EEOC regarding recordkeeping
and reporting requirements. Please feel free to contact me if you have any questions.
Very truly yours,
ILLINOIS CREDIT UNION LEAGUE
By:
LWE:ko
cc:
Regulatory Committee
Legislative Committee
Don Edwards
G:\REG\CMT-LTR\EEOC ADA GINA RECORD

Lynn W. Esp
Assistant General Counsel