The federal banking agencies have said that they are now urging banks to conduct voluntary diversity self-assessments. The self-assessment is based on diversity and inclusion assessment standards issued by the agencies last summer; information about submitting the assessments will be provided by regulatory agencies directly to banks “at a later date.”
The agencies said banks are “strongly encouraged to disclose on their websites their diversity policies and practices,” as well as to “provide their policies, practices and self-assessment information to their primary federal regulator." The first round of self-assessments will cover calendar year 2015; for future years, assessments “should be submitted within 90 days of the close of the calendar year.” The diversity policy statement principally focuses on organizations with more than 100 employees, although smaller banks are encouraged to use the diversity standards “in a manner appropriate to their unique characteristics.”
Since the standards were first proposed in 2013 under the Dodd-Frank Act, ABA has worked with the agencies, urging them to keep the scope of the standards within the language of the statute and to recognize the many ways in which banks have long embraced diverse and inclusive workforces reflective of the communities they serve. As a result of ABA’s efforts, disclosure remains voluntary and “diversity” may cover more than sex, race and ethnicity -- as emphasized in an interagency FAQ recently released.
Moreover, in making any disclosures, each institution has discretion in determining whether and how to disclose their outreach efforts to the public and may ask that any information disclosed to a supervisor be kept confidential; the agencies stated that they will not assess banks’ diversity policies and practices, nor will they use the self-assessments in the examination process. ABA will continue to work with the agencies on outreach efforts to explain the standards and to monitor how supervisors apply the guidelines.
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