On Compliance: Tackling Dodd-Frank’s diversity policies

Section 342 addresses under-representation of women and minorities.

by Brian D. Pedrow, Dee Spagnuolo, and Carolyn A. Pellegrini, CU Management

Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act mandated the creation of the Office of Minority and Women Inclusion in all agencies covered by the act and requires that each OMWI develop standards for assessing the diversity policies and practices of entities regulated by those agencies.

The National Credit Union Administration was among six federal agencies that published the Final Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies in June 2015. Additionally, the Consumer Financial Protection Bureau published a Diversity and Inclusion Strategic Plan 2016-2020.

These agencies have provided practical advice for compliance with Section 342, which was enacted to address the under-representation of women and minorities in the financial services industry. While programs will vary according to each organization’s characteristics, regulated entities of any size would be well served to heed the agencies’ guidance. This brief overview outlines recommendations for creating a compliant diversity and inclusion program and conducting annual self-assessments in four areas: (1) organizational commitment to D&I, (2) workforce and employment practices, (3) procurement and business practices, and (4) practices to promote transparency of organizational D&I.


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