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Diversity Requirements Under Dodd-Frank

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April 20, 2015

A section of the Dodd-Frank law dealing with diversity hasn’t received as much attention as the rest of the law, but that is about to change, according to a labor and employment newsletter from Bradley Arant Boult Cummings. All banks and financial institutions regulated by the federal government, as well as the federal financial agencies themselves, are subject to diversity requirements under Dodd-Frank Section 342. This provision requires federal financial agencies to create an Office of Minority and Women Inclusion (OMWI), which in addition to managing diversity at the agencies, also has the authority to assess the diversity policies of regulated private entities. The OMWI offices from the various agencies – which includes all 12 regional Federal Reserve Banks, Federal Reserve Board of Governors, Departmental Offices of the Department of Treasury, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, Office of the Comptroller of the Currency, Securities and Exchange Commission, and Consumer Financial Protection Bureau – have not yet published final regulations, but OMWI directors from six of the agencies have proposed joint standards that authors say  could be considered a possible guide. One specific to consider: a statistical analysis of employment demographics, in tandem with serious attention to outreach programs.

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