Joint Trades Letter Re: Proposed Interagency Standards for Assessing Diversity Policies (OMWI)

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


Dear OMWI Directors:

The Financial Services Roundtable (“FSR”), the Consumer Bankers Association
(“CBA”), the American Bankers Association (“ABA”) and the Independent Community
Bankers of America4 (“ICBA”) (collectively, the “Associations”) are pleased to respond
to the proposed joint standards for assessing the diversity policies and practices published
in the Federal Register on Friday, October 25, 2013 (the “Proposed Standards”) by the
Board of Governors of the Federal Reserve System, the Bureau of Consumer Financial
Protection, the Federal Deposit Insurance Corporation, the National Credit Union
Administration, the Office of the Comptroller of the Currency, and the Securities and
Exchange Commission (collectively, the “Agencies”). The proposal is intended to
implement Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection
Act (“Dodd-Frank”).

Section 342 of Dodd-Frank requires the Agencies each to establish an Office of
Minority and Women Inclusion with the primary focus of ensuring that the Agencies
themselves have a diverse workforce and take appropriate steps to include minorities and
women in their contracting and procurement practices. A less expansive provision
requires each Director “to develop standards for . . . assessing the diversity policies and
practices of entities regulated by the agency.” This mandate is further limited by Section
342(b)(4) of Dodd-Frank, which states that nothing in this requirement to assess diversity
practices “may be construed to mandate any requirement on or otherwise affect the
lending policies and practices of any regulated entity, or to require any specific action

To read the full Comment Letter, please download the PDF.