OFFICE OF MINORITY AND WOMEN INCLUSION 

ANNUAL REPORT

As Required by Section 342(e) of the 

Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010

This is a report prepared by the Staff of the Office of Minority and Women 

Inclusion of the U.S. Securities and Exchange Commission. The Commission 

has expressed no view regarding the analysis, findings, or conclusions 

contained herein. 

_________________________________ 

April 10, 2012 
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I. INTRODUCTION

The Office of Minority and Women Inclusion (“OMWI”) of the U.S. Securities and 

Exchange Commission (the “SEC” or the “Commission”) submits this report pursuant to Section 

342(e) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “DoddFrank Act”). 

Section 342(e) mandates the submission by OMWI to Congress of an annual report that 

includes the following: 

1. a statement of the total amounts paid to contractors during the reporting period; 

2. the percentage of the amounts paid to contractors that were paid to minority-owned and 

women-owned businesses; 

3. the successes achieved and challenges faced by the agency in operating minority and 

women outreach programs; 

4. the challenges the agency may face in hiring qualified minority and women employees 

and contracting with qualified minority-owned and women-owned businesses; and, 

5. any other information, findings, conclusions, and recommendations for legislative or 

agency action, as the OMWI Director determines appropriate.1

 

Unless otherwise noted, this report covers Section 342-related activities at the SEC from 

the establishment of OMWI in July 2011 through the fiscal year ended September 30, 2011. 

II. ESTABLISHMENT OF OMWI AT THE SEC 

Section 342 of the Dodd-Frank Act (“Section 342”) requires the SEC to establish an 

Office of Minority and Women Inclusion to be responsible for “all matters of the agency relating 

to diversity in management, employment, and business activities.”2 The SEC formally 

established its Office of Minority and Women Inclusion in July 2011, when the House and 

Senate Appropriations Committees approved the SEC’s reprogramming request to create the 

office. The SEC began the hiring process for a permanent OMWI Director soon thereafter and 

announced the selection of the permanent OMWI Director in December 2011. The permanent 

OMWI Director officially joined the office in January 2012. 

Among many duties, the OMWI Director is responsible for developing standards for 

equal employment opportunity and diversity of the workforce and senior management of the 

SEC, the increased participation of minority-owned and women-owned businesses in the SEC’s 

programs and contracts, and assessing the diversity policies and practices of entities regulated by 

                                                           

1 Section 342(e). 

2

 Section 342(a)(1)(A). 
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the SEC.3 The OMWI Director also is required to advise the Chairman of the Commission on 

the impact of the SEC’s policies and regulations on minority-owned and women-owned 

businesses.4

III. IMPLEMENTATION OF SECTION 342 

A. Contracting With Minority-Owned and Women-Owned Businesses

Section 342(e)(1) and (2) requires the SEC to report the total amount paid to contractors 

during the reporting period, as well as the amounts and related percentages paid to minorityowned and women-owned businesses. During FY 2011, the SEC awarded $228 million to 

contractors. Of this $228 million, the SEC awarded $38.38 million (16.8%) to minority-owned 

businesses and $15.69 million (6.9%) to women-owned businesses. This represents an increase 

in dollars paid to minority-and women-owned businesses when compared to FY 2010 and FY 

2009 data. In 2010, the SEC awarded a total of $223 million dollars to contractors; of that, 10% 

was paid to minority-owned businesses and 12% was to women-owned businesses. This 

represented an increase from FY 2009.5

 

Section 342(e)(3) also requires the SEC to report the successes achieved and challenges 

faced in operating minority and women outreach programs. Since the establishment of the 

OMWI office in July 2011, the SEC has focused on proactively increasing the awareness of the 

SEC’s contracting needs within the minority-owned and women-owned business communities. 

Our successes in operating minority and women outreach programs included the 

following: 

 In FY 2011, the SEC exceeded all U.S. Small Business Administration-defined 

socioeconomic goals for the number of contracts awarded to small businesses, with the 

exception of the 3% goal for those businesses located in Historically Underutilized 

Business Zones. 

 OMWI sponsored and attended conferences and participated in business matchmaking 

sessions to increase the interaction between minority and women suppliers and the SEC, 

including the national conferences for the following organizations: the Minority 

Corporate Counsel Association, the National Association of Minority and WomenOwned Law Firms, the United States Hispanic Chamber of Commerce, the National 

Minority Supplier Development Council, and FraserNet Power Networking. 

                                                           

3

 Section 342(b)(2)(A)-(C). 

4

 Section 342(b)(3). 

5

 In 2009, the SEC awarded a total of $151 million to contractors; $14 million to minority-owned businesses and 

$10 million to women-owned businesses. 
-3- 

 OMWI created a dedicated email address, telephone line, and brochure to facilitate 

communication and outreach to the minority-owned and women-owned business 

communities. As a result, many minority-owned and women-owned businesses are 

contacting OMWI directly to learn more about the SEC’s contracting needs. 

 OMWI hosts a monthly “Vendor Outreach Day” at the SEC for small, minority-owned, 

and women-owned businesses to learn about the SEC’s contracting needs and to present 

their services to OMWI’s Supplier Diversity Officer and other key SEC personnel. Since 

August 2011, OMWI has seen over fifty (50) vendors. 

OMWI is actively involved in the agency’s acquisition review process to advocate for the 

inclusion of a diversity component in the competitive process. 

Our challenges in operating minority and women outreach programs included the following: 

 In FY 2011, OMWI had limited staff as the office was newly created and was unable to 

provide in-depth technical assistance to minority-owned and women-owned businesses. 

In FY 2012, we are in the process of hiring more staff and will have the resources to 

provide businesses seeking contracts with the SEC with a comprehensive overview of the 

contracting process from the proposal phase to the contract award phase, including an 

overview of the process of bidding on a requirement. 

B. Employment of Minorities and Women at the SEC

Section 342(e)(4) requires the SEC to report on challenges it may face in hiring qualified 

minority and women employees and contracting with qualified minority-owned and womenowned businesses.6

 As of the end of FY 2011, there were 3,826 employees in the SEC’s 

workforce, of which 1,204 employees (31.5%) were minorities and 1,839 employees (48.1%) 

were women. Of the 1,204 minority employees and 1,839 women employees, respectively, 440 

minorities (36.5%) and 843 women (45.8%) were employed in the major SEC occupations of 

attorneys, accountants, and compliance examiners. Of the 1,129 supervisory and management 

positions, a total of 178 minorities (15.8%) and 332 women (29.4%) were in these positions. 

The SEC is taking proactive steps to increase the recruitment of underrepresented demographic 

groups at the agency in the major occupations of attorneys, accountants, and compliance 

examiners. In addition, the SEC continues to evaluate ways to address the underrepresentation 

of minorities and women in supervisory and management positions. 

The SEC is working toward a unified agency approach to recruitment and hiring that 

incorporates a comprehensive understanding of the value of workforce diversity. To increase 

awareness of the agency’s workforce diversity challenges, OMWI began meeting with the 

                                                           

6

 Our challenges in contracting with qualified minority-owned and women-owned businesses are discussed under 

Section III.A of this report. 
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leadership and hiring managers of each division and office to review employee demographic data 

and to discuss methods to enhance the SEC’s recruitment and hiring efforts to include a wider 

pool of diverse applicants. The OMWI Director continues to convene these meetings in an 

ongoing effort to improve the agency’s workforce diversity. 

OMWI actively partnered with the SEC’s Office of Human Resources to enhance the 

SEC’s diversity recruiting efforts, particularly for the recruitment of attorneys, accountants, 

managers, and senior officers. In addition, OMWI collaborated with the Office of Human 

Resources to initiate the development of a system to track candidates that submitted resumes to 

the agency or agency representatives at outreach events and through referrals. 

OMWI also worked with the SEC’s Office of Equal Employment Opportunity to host 

regular meetings in Washington D.C. with the local chapter leaders of many national minority 

professional organizations, including the Association of Latino Professionals in Finance and 

Accounting, the National Black MBA Association, and the Hispanic National Bar Association, 

to disseminate information about SEC employment opportunities to their members and networks. 

To increase the reach of our recruitment and hiring efforts, OMWI will continue to strategically 

leverage and expand these partnerships and alliances to include more organizations and their 

local chapter affiliates in our regional office locations. It is too early to assess the impact of 

these partnerships and alliances as most were initiated during FY 2011. 

Under the leadership of the recently appointed permanent OMWI Director, the SEC is 

developing an agency-wide diversity and inclusion strategic plan that incorporates the 

requirements of Section 342, the August 2011White House Diversity and Inclusion Executive 

Order, and the Government-Wide Diversity and Inclusion Strategic Plan. This strategic plan will 

focus on the recruitment, hiring, mentoring, career development, promotion, and retention of 

diverse employees. Moreover, the strategic plan will include standards that will allow the SEC 

to self-assess its ongoing diversity and inclusion efforts. The plan is expected to be completed 

by May 1, 2012. 

C. Other Information, Findings, Conclusions, and Recommendations

Section 342(e)(5) requires the SEC to report any other information, findings, conclusions, 

and recommendations for legislative or agency action, as the OMWI Director determines 

appropriate. Beginning in early 2011, the SEC staff, along with the directors and representatives 

from the other OMWI agencies,7

 participated in interagency meetings to develop comprehensive 

approaches to implementing the requirements of Section 342. These meetings were also used to 

draft proposed language for the written statement on the fair inclusion of women and minorities 

                                                           

7

 Section 342(g)(1). 
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in contracting activities8 and to discuss appropriate standards for assessing the diversity policies 

and practices of the entities regulated by each agency.9 Given that several OMWI agencies may 

concurrently regulate certain entities, a primary focus of the interagency group was to avoid the 

establishment of conflicting diversity standards upon these regulated entities. In early 2012, the 

OMWI directors held a joint roundtable with financial industry groups and trade organizations to 

foster a meaningful, informed dialogue regarding the development of standards for assessing the 

diversity policies and practices of regulated entities. The OMWI directors continue to convene 

these interagency meetings and roundtables on an as-needed basis. 

In addition, several trade groups, regulated entities, and minority professional 

organizations have requested informal meetings with our OMWI Director. Our OMWI Director 

meets with representatives of these groups and, to the extent necessary, facilitates their 

introduction to the other OMWI directors. 

IV. FOR FURTHER INFORMATION

Should you require any further information regarding this report, please contact Pamela 

Gibbs, Director, Office of Minority and Women Inclusion, at (202) 551-6046 or Julie Davis, 

Deputy Director, Office of Legislative and Intergovernmental Affairs, at (202) 551-2233. 

                                                           

8

 Section 342(c)(2). 

9

 Section 342(b)(2)(C).