Recent Dodd-Frank diversity and inclusion standards developments

Ballard Spahr LLP

Regulated entities should be aware of two recent developments concerning the final diversity and inclusion standards issued this summer under Dodd-Frank Section 342 by the CFPB, OCC, Fed, FDIC, NCUA and SEC. Given that the final standards have been in effect since June 10, 2015, entities should begin taking steps to incorporate them into their daily business practices and plan for their self-assessments.

The first development was the CFPB’s release of its Diversity and Inclusion Strategic Plan for 2016-2020. The plan sets forth the CFPB’s diversity and inclusion vision statement and describes how the CFPB will promote diversity and inclusion in the workforce and with its suppliers, as well as assess and strengthen diversity and inclusion within its regulated entities. The CFPB expects such entities to take similar steps within their organizations.

The second development is a joint notice, request for comment, and notice of information collection published in the Federal Register on November 6, 2015 by the six agencies that issued the final diversity and inclusion standards. In conjunction with the issuance of the final standards, the agencies had published a 60-day notice requesting public comments on the information collection process and parameters, and how this requirement might affect the regulated entities. The Notice addresses the four comments received during the 60-day comment period, and invites additional comments on the collection of information. Comments are due by December 7, 2015.

For more information about these developments, see our legal alert.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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