Ballard Spahr LLP
John L. Culhane, Jr, Mark J. Furletti, Alan S. Kaplinksy, Barbara S. Mishkin, Jeremy T. Rosenblum and Mercedes K. Tunstall
January 25 2011
Responding to a little-noticed provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act, federal agencies have begun establishing Offices of Minority and Women Inclusion.
Each agency’s Inclusion Office must develop standards for: equal employment opportunity and the racial, ethnic, and gender diversity of the agency’s workforce and senior management; and increased participation of minority- and women-owned businesses in the agency’s programs and contracts. More important to financial institutions, however, is that Directors of the Inclusion Offices must develop standards to assess the diversity policies and practices of the entities their agencies regulate.
Required to establish an Inclusion Office by January 21, 2011, were the Federal Reserve Board, 12 Federal Reserve Banks, Office of the Comptroller of the Currency, Department of the Treasury, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Securities and Exchange Commission. The Bureau of Consumer Financial Protection (CFPB) has until January 21, 2012, to meet the requirement of Section 342 of the Dodd-Frank Act.
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