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STANDARDS FOR ASSESSING THE DIVERSITY POLICIES OF BANKS, INVESTMENT FIRMS, CREDIT UNIONS

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Under Dodd/Frank, "six federal financial regulatory agencies – the Securities and Exchange Commission, the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency –" must, by law, develop standards and an approach to assessing the diversity policies and practices of entities they regulate. This means looking at diversity at all banks, investment firms, and credit unions. All of them. Each of these agencies will develop a way to determine if the policies of the entities they regulate are fair, or at least, inclusive. They are asking for comments on this.
I suggest you comment, and have even drafted proposed comment text for you at: https://docs.google.com/document/d/1_dVF9yIbI5SU_QkiwuNFg3sOkImTdXnUk5J6-pEm0ZM/edit?usp=sharing
Comments are due by Feb. 7, 2014. Submit them via email by going to: Comments on …

OMWI Office Reports So Far....

Review of Office of Minority and Women Inclusion (OMWI) Performance: Opportunities for Minority and Women firms, Implications for Policymakers Friday, June 8, 2012 from 1:30 PM to 2:30 PM (ET). $100.00. Register by clicking on the link above.

Minority Business Contracting at the Fed

The BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM released its Report to the Congress on the Office of Minority and Women Inclusion. March 2012.

We note that "During 2011, the Board’s procurement contracts for goods and services totaled $125,070,569. Of this total, $15,414,147, or 12.3 percent, was awarded to minority-owned or women-owned businesses.

Specific awards by contractor classification are as follows
• minority-owned businesses (excludes women owned businesses) = $9,028,526 (7.2 percent of total);
• women-owned businesses (excludes minority women) = $4,237,038 (3.4 percent of total); and
• minority women-owned businesses = $2,148,583 (1.7 percent of total)."

http://federalreserve.gov/publications/other-reports/files/omwi-report-20120402.pdf

Federal Reserve Bank of Kansas City First to release OMWI Report to Congress

The Federal Reserve Bank of Kansas City released their Office of Women and Minority Inclusion (OMWI) Report to Congress today. (See: http://www.kc.frb.org/publicat/aboutus/2011-omwi-congress-report.pdf)

They are the first OMWI Office to do so.

Under the terms of the statute (Dodd/Frank Section 342) all OMWI offices will have to release a report to Congress on their initial activities.

The 21 page Report covers employment diversity, business inclusion and outreach in a pretty standard way. Their track record in this area is solid.

Of course, the Federal Reserve Bank of Kansas City is the only one with a woman CEO. This appears to have helped. (In the interst of full disclosure, let me note that I spoke at a Bank Symposium on Minority-owned banks. This was, however, some time ago....)

Credit Unions Worried about Dodd/Frank 342

According to recent news reports, the "Credit Union National Association (CUNA) has written NCUA's Office of Minority and Women Inclusion to urge the agency implement one of the requirements of the Dodd-Frank Act with as little additional reporting requirements as possible."

The referenced section of Dodd/Frank requires regulators to report on diversity at the financial institutions they firms regulate. This is an entirely new reporting requirement, and the first time a diversity reporting rule has been applied so broadly in an industry. This is also the first time a federal financial institution regulator has been tasked with this work.

Credit Union executives met with NCUA's OMWI office director, Tawana James, "on February 29 and..have written her a letter on March 26 expressing concern about a possible requirement to assess the diversity practices of credit union contractors and suppliers."

We will cover this and other recent Section 342 developments in …

Report on Diversity at OMWI Agencies

Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act contains a provision creating an Office of Minority and Women Inclusion (OMWI) at various agencies to monitor the diversity efforts of the agencies, the regulated entities and agency contractors. In a new report on workforce diversity at the 20 federal financial regulatory agencies subject to Dodd/Frank Section 342 (OMWI), a West Coast based NGO, the Greenlining Coalition, notes that "there is considerable variation amongst the financial regulatory agencies in workforce diversity. Our tiered analysis illustrates that some agencies have strong diversity records, while others still have considerable room for improvement."

Greenlining appears to be working from our ratings of OMWI Offices, released in September, 2011. We agree with their assessment and are glad that they have validated the work we did six months ago.....

The Report goes on to note that

"..some agencies have been more successful tha…

Pamela Gibbs Selected as SEC OMWI Director

"The Securities and Exchange Commission..announced that Pamela A. Gibbs has been named as the inaugural Director of the Office of Minority and Women Inclusion, which oversees diversity in the agency's employment, management, and business activities.

Ms. Gibbs comes to the SEC from the Commodity Futures Trading Commission, where she has served since October 2009 as the Director of its Office of Diversity and Inclusion. In that role, Ms. Gibbs was the principal advisor to the CFTC Chairman on equal employment and diversity matters, and oversaw outreach and recruitment of minority and women's groups. She also worked with the agency's Office of General Counsel and Office of Human Resources to ensure fairness and consistency in the agency's personnel policies and practices.

Prior to the CFTC, Ms. Gibbs.. started in 1991 as a trial attorney in the Civil Rights Division (of the Department of Labor). She later was Acting Deputy Director for Program Operation in the Office o…

Fed names Directors of Regional Fed Bank OMWI Offices.

According to the Fed,
"The Federal Reserve on Tuesday announced the establishment of offices to promote diversity and inclusion at the Federal Reserve Board and at all 12 of the Federal Reserve Banks.
The offices will build on the Federal Reserve System’s long-standing efforts to promote equal employment opportunity and diversity, and will continue to work to foster diversity in procurement, with a focus on minority-owned and women-owned businesses. The Dodd-Frank Wall Street Reform and Consumer Protection Act required that diversity and inclusion offices be established at certain federal agencies, including the Federal Reserve Board, and at the Federal Reserve Banks. In addition to promoting diversity at the Board and throughout the System, the Board’s Office of Diversity and Inclusion will play an integral role in the development of standards to assess the diversity practices at entities regulated by the Federal Reserve as required by the Dodd-Frank Act.
The heads of the diversit…