Increasing diversity by increasing self-assessment

by. Shelbey Ballantyne

Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies

If you are a financial institution regulated by the OCC, the Fed, the FDIC, the SEC, or the NCUA, diversity policies and practices are evolving. Not only is there a greater expectation to use minority-owned suppliers, but new self-assessment procedures are being added to document the success of an institution’s diversity policies.

Comments on the proposal are due by December 24, but this information is still relevant after that date for the affected institutions seeking to anticipate where the regulators are heading. Diversity is an ever-changing subject and financial institutions (FIs) would be wise to be current on all proposed amendments regarding this issue.

Overview

The five regulatory agencies have jointly proposed standards for assessing diversity policies and practices by the entities they regulate. Here’s what the proposal entails.

The standards come from the Office of Minority and Women Inclusion (OMWI Office), which each regulator was required to establish under the Dodd-Frank Act. Entities that have more than 100 employees or that are federal contractors with 50 or more employees and with contracts of $50,000 or more are required to file an Employer Information Report EEO-1 with the Equal Employment Opportunity Commission and the agencies have recommend that these entities use this data along with the proposed standards to assist them in developing their internal diversity policies and practices. Regulated entities that do not file EEO-1 Reports are encouraged to use the proposed standards as their guide in developing their internal policies and practices.

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