SELF-ASSESSMENTS OF DIVERSITY POLICIES

On August 2, 2016 the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency provided information on how the financial institutions may begin to submit self-assessments of their diversity policies and practices as of year-end 2015, and issued Frequently Asked Questions (FAQs) about the process.

Financial institutions are strongly encouraged to disclose on their websites their diversity policies and practices, as well as information related to their self-assessments, to maximize transparency, and to provide their policies, practices, and self-assessment information to their primary federal financial regulator. Additional information, with detailed submission instructions, will be provided at a later date directly to the institutions.

Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act required the federal financial regulatory agencies to establish an Office of Minority and Women Inclusion (OMWI) and instructed the OMWI Director at each agency to develop standards for assessing the diversity policies and practices of its regulated institutions.

The voluntary standards, which became effective on June 10, 2015, reflect input received during a public comment period, as well as information gathered during outreach sessions. The standards provide a framework for regulated institutions to assess and establish or strengthen their diversity policies and practices.

The standards are intended to promote transparency and awareness of diversity policies and practices within the institutions. On July 13, 2016, the agencies announced that the Office of Management and Budget had approved the collection of the voluntary self-assessment information. The information may be used by the agencies to monitor diversity and inclusion trends and identify leading policies and practices in the financial services industry.

Three of the 14 Qs and As are reprinted below:

Q3. What entities are covered by the Policy Statement?

The Policy Statement applies to entities that are regulated by the Agencies and by the other federal financial agencies that issued the Policy Statement. This includes depository institutions, holding companies and other financial service companies whose primary federal financial regulator is the Board, FDIC or OCC. The Agencies recognize that entities have unique characteristics, such as governance structure, workforce size, total assets, contract volume, geographic location, and community characteristics. The Policy Statement focuses primarily on regulated entities with more than 100 employees. Smaller regulated entities are also encouraged to use the Standards in a manner appropriate to their unique characteristics.

Q4. Are regulated entities required to conduct a self-assessment and provide the results to their regulators?

The Policy Statement states that regulated entities’ self-assessments of their diversity policies and practices are voluntary, and submissions of information regarding those self-assessments to their primary federal financial regulator are also voluntary.

Q12. Will the Agencies conduct examinations to assess the entities’ diversity policies and practices?

The Policy Statement specifically states that the Agencies will not use their examination or supervisory processes in connection with the Standards.

A list of all of the Frequently Asked Questions and Answers is available on the websites of the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency and is available at https://www.federalreserve.gov/newsevents/press/bcreg/bcreg20160802b1.pdf.

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