DIVERSITY 

MANAGEMENT

Trends and Practices 

in the Financial 

Services Industry and 

Agencies after the 

Recent Financial 

Crisis

Report to the Ranking Member, 

Committee on Financial Services, U.S. 

House of Representatives

April 2013

GAO-13-238

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-238, a report to the 

Ranking Member, Committee on Financial 

Services, U.S. House of Representatives

April 2013

DIVERSITY MANAGEMENT

Trends and Practices in the Financial Services 

Industry and Agencies after the Recent Financial 

Crisis 

Why GAO Did This Study

As the U.S. workforce has become 

increasingly diverse, many private- and 

public-sector entities recognize the 

importance of recruiting and retaining 

minorities and women for 

management-level positions to improve 

their business. The 2007-2009 

financial crisis has renewed questions 

about commitment within the financial 

services industry (e.g., banking and 

securities) to workforce diversity. The 

Dodd-Frank Act required that eight 

federal financial agencies and the 

Federal Reserve Banks implement 

provisions to support workforce and 

contractor diversity. GAO was asked to 

review trends and practices since the 

beginning of the financial crisis. This 

report examines (1) workforce diversity 

in the financial services industry, the 

federal financial agencies, and 

Reserve Banks, from 2007 through 

2011 and (2) efforts of the agencies 

and Reserve Banks to implement 

workforce diversity practices under the 

Dodd-Frank Act, including contracting. 

GAO analyzed federal datasets and 

documents and interviewed industry 

representatives and officials from the 

federal financial agencies and Reserve 

Banks.

What GAO Recommends

Each agency and Reserve Bank 

should include in its annual OMWI 

report to Congress efforts to measure 

the progress of its diversity practices.

The agencies and Reserve Banks 

agreed to include this information in 

the annual OMWI reports. Additionally, 

some agencies and the Reserve Banks 

described steps they have taken or 

plan to take to address the 

recommendation.

What GAO Found

Management-level representation of minorities and women in the financial 

services industry and among federal financial agencies and Federal Reserve 

Banks (Reserve Banks) has not changed substantially from 2007 through 2011. 

Industry representation of minorities in 2011 was higher in lower-level 

management positions—about 20 percent—compared to about 11 percent of 

senior-level manager positions. Industry representation of women at the overall 

management level remained at about 45 percent. Agency representation of 

minorities at the senior management level in 2011 ranged from 6 percent to 17 

percent and from 0 percent to 44 percent at the Reserve Banks. Women’s 

representation ranged from 31 to 47 percent at the agencies and from 15 to 58 

percent at the Reserve Banks. Officials said the main challenge to improving 

diversity was identifying candidates, noting that minorities and women are often 

underrepresented in both internal and external candidate pools.

Senior Management-Level Diversity, 2011

In response to the requirements in the Dodd-Frank Wall Street and Consumer 

Protection Act (Dodd-Frank Act), in 2011 federal financial agencies and Reserve 

Banks began to report annually on the recruitment and retention of minorities and 

women and other diversity practices. They all have established Offices of 

Minority and Women Inclusion (OMWI) as required. Many agencies and Reserve 

Banks indicated they had recruited from minority-serving institutions and 

partnered with organizations focused on developing opportunities for minorities 

and women, and most described plans to expand these activities. Some used 

employee surveys or recruiting metrics to measure the progress of their 

initiatives, as suggested by leading diversity practices, but OMWIs are not 

required to include this type of information in the annual reports to Congress. 

Better reporting of measurement efforts will provide Congress, agency officials, 

and other stakeholders additional insights on the effectiveness of diversity 

practices and demonstrate how agencies and Reserve Banks are following a 

leading diversity practice. Most federal financial agencies and Reserve Banks are 

in the early stages of implementing the contracting requirements required under 

the act. For example, most now include a provision in contracts for services 

requiring contractors to make efforts to ensure the fair inclusion of women and 

minorities in their workforce and subcontracted workforce and have established 

ways to evaluate compliance. The proportion of an agency’s dollars awarded or a 

Reserve Bank’s dollars paid to minority- or woman-owned businesses reported in 

2011 OMWI reports ranged between 3 percent and 38 percent.

View GAO-13-238. For more information, 

contact Daniel Garcia-Diaz at (202) 512-8678 

or GarciaDiazD@gao.gov.
Page i GAO-13-238 Financial Services Industry

Letter 1 

Background 4

Industry Diversity Levels Remained about the Same from 2007 

through 2011 8

Agency and Reserve Bank Workforce Diversity Varied, and 

Officials Reported Difficulty Identifying Diverse Candidates 24

Dodd-Frank Requirements Are Being Implemented, but Enhanced 

Reporting of Efforts to Measure Progress Is Needed 36

Procedures to Meet Dodd-Frank Inclusive Contracting 

Requirements Are Largely in Place 48

Conclusion 58

Recommendations for Executive Action 59

Agency Comments and Our Evaluation 59

Appendix I Objectives, Scope, and Methodology 62

Appendix II Additional Analysis of the Financial Services Industry 69

Appendix III Additional Analysis of Overall Workforce Diversity at 

Agencies and Reserve Banks 73

Appendix IV Representation of Minorities and Women at Federal 

Financial Agencies and Reserve Banks 81

Appendix V Comments from the Consumer Financial Protection 

Bureau 95

Appendix VI Comments from the Federal Reserve Banks 97

Appendix VII Comments from the Federal Reserve Board 99

Contents 
Page ii GAO-13-238 Financial Services Industry

Appendix VIII Comments from the Federal Deposit Insurance 

Corporation 101

Appendix IX Comments from the Federal Housing Finance Agency 103

Appendix X Comments from the National Credit Union Administration 104

Appendix XI Comments from the Comptroller of the Currency 105

Appendix XII Comments from the Securities and Exchange Commission 106

Appendix XIII Comments from the Treasury Department 108

Appendix XIV GAO Contact and Staff Acknowledgments 109

Tables

Table 1: Federal Financial Agencies Subject to Dodd-Frank Act 

Section 342 5

Table 2: Percentage of Students Enrolled in MBA Degree Programs 

at AACSB Member Schools in the United States by 

Race/Ethnicity, 2007-2011 23

Table 3: OMWI Staffing Levels for Federal Financial Agencies, as of 

January 2013 38

Table 4: OMWI Staffing Levels for Reserve Banks, as of January 

2013 39

Table 5: Federal Financial Agency and Reserve Bank 

Implementation of Dodd-Frank Act Section 342 Diversity 

Recruitment Requirements 41

Table 6: Estimated Percentages and Standard Errors for 

Race/Ethnicity in Management Positions in the Financial 
Page iii GAO-13-238 Financial Services Industry

Services Industry Using the Current Population Survey 

(CPS), 2007-2011 64

Table 7: Percentage of Minorities among Senior Management-Level 

Employees at Seven Federal Financial Agencies, 2007-2011 82

Table 8: Percentage of Minorities among Senior Management-Level 

Employees at the 12 Reserve Banks, 2007-2011 84

Table 9: Percentage of Women among Senior Management-Level 

Employees at Seven Federal Financial Agencies, 2007-2011 86

Table 10: Percentage of Women among Senior Management-Level 

Employees at the 12 Reserve Banks, 2007-2011 87

Table 11: Percentage of Minorities among All Employees at Seven 

Federal Financial Agencies, 2007-2011 89

Table 12: Percentage of Minorities among All Employees at the 12 

Reserve Banks, 2007-2011 91

Table 13: Percentage of Women among All Employees at Seven 

Federal Financial Agencies, 2007-2011 93

Table 14: Percentage of Women among All Employees at the 12 

Reserve Banks, 2007-2011 94

Figures

Figure 1: Percentage of White and Minority Managers in the 

Financial Services Industry, 2007-2011 10

Figure 2: Percentage of Whites and Minorities in First- and MidLevel Management and Senior Management Positions in 

the Financial Services Industry, 2007-2011 11

Figure 3: Percentage of Specific Races/Ethnicities in the Financial 

Services Industry in Overall Management Positions, 2007-

2011 12

Figure 4: Percentage of Specific Races/Ethnicities in the Financial 

Services Industry at Various Management Levels, 2007-

2011 13

Figure 5: Percentage of Men and Women in Management Positions 

in the Financial Services Industry, 2007-2011 14

Figure 6: Percentage of White and Minority Men and White and 

Minority Women in Management Positions in the 

Financial Services Industry, 2007-2011 15

Figure 7: Percentage of Women in the Financial Services Industry 

by Management Level and Race/Ethnicity, 2007-2011 16

Figure 8: Percentage of Whites/Minorities and Men/Women at 

Financial Services Firms of Different Sizes, 2007-2011 17
Page iv GAO-13-238 Financial Services Industry

Figure 9: Percentage of Whites/Minorities and Men/Women in 

Various Financial Services Industry Workforce Positions, 

2007-2011 21

Figure 10: Percentage of Minorities among Senior ManagementLevel Employees at Six Federal Financial Agencies, 2007-

2011 26

Figure 11: Percentage of Minorities among Senior ManagementLevel Employees at the 12 Reserve Banks, 2007-2011 28

Figure 12: Percentage of Women among Senior Management-Level 

Employees at Six Federal Financial Agencies, 2007-2011 30

Figure 13: Percentage of Women among Senior Management-Level 

Employees at the 12 Reserve Banks, 2007-2011 32

Figure 14: Dollar Amount and Percentage of Total Awarded to 

Minority- and Women-Owned Businesses (MWOB) by 

Agency, 2011 52

Figure 15: Dollar Amount and Percentage of Total Paid to Minorityand Women-Owned Businesses (MWOB) by Reserve 

Bank, 2011 53

Figure 16: Percentage of Minority Women and Minority Men in 

Various Industry Workforce Positions in the Financial 

Services Industry, 2007-2011 70

Figure 17: Percentage of Whites/Minorities and Men/Women in 

Various Sectors of the Financial Services Industry, 2007-

2011 72

Figure 18: Percentage of Minorities among All Employees at Seven 

Federal Financial Agencies, 2007-2011 74

Figure 19: Percentage of Women among All Employees at Seven 

Federal Financial Agencies, 2007-2011 76

Figure 20: Percentage of Minorities among All Employees at the 12 

Reserve Banks, 2007-2011 78

Figure 21: Percentage of Women among All Employees at the 12 

Reserve Banks, 2007-2011 80
Page v GAO-13-238 Financial Services Industry

Abbreviations

AACSB Association to Advance Collegiate Schools of 

Business 

CFPB Bureau of Consumer Financial Protection, 

known as the Consumer Financial Protection

Bureau

CPS Current Population Survey

Dodd-Frank Act Dodd–Frank Wall Street Reform and 

Consumer 

Protection Act 

EEO equal employment opportunity

EEO-1 Employer Information Report 

EEOC Equal Employment Opportunity Commission 

FAR Federal Acquisition Regulation

FDIC Federal Deposit Insurance Corporation 

Federal Reserve Board Board of Governors of the Federal Reserve 

System 

FHFA Federal Housing Finance Agency

FSOC Financial Stability Oversight Council

HERA Housing and Economic Recovery Act of 2008

MWOB minority- and women-owned business

MBA Master of Business Administration

MD-715 EEOC Management Directive 715

NAICS North American Industry Classification System

NCUA National Credit Union Administration 

NPO National Procurement Office

OCC Office of the Comptroller of the Currency

OMWI Office of Minority and Women Inclusion

Reserve Banks Federal Reserve Banks 

SBA Small Business Administration

SBS security-based swap

SEC Securities and Exchange Commission

Treasury Departmental Offices of the Department of the 

Treasury

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Page 1 GAO-13-238 Financial Services Industry

United States Government Accountability Office

Washington, DC 20548

April 16, 2013

The Honorable Maxine Waters

Ranking Member

Committee on Financial Services

House of Representatives

Dear Ms. Waters:

As the U.S. workforce has become increasingly diverse, many private and 

public-sector organizations have recognized the importance of recruiting 

and retaining minorities and women for key positions to improve their 

business or organizational performance. Studies have associated a 

diversity of perspectives in organizations with innovation. However, 

congressional hearings have raised questions about diversity in the 

workforce of the financial services industry, which provides services that 

are essential to the continued growth and economic recovery of the 

country. During hearings on the financial services industry between 2004 

and 2010, congressional members and witnesses expressed concern 

about the level of inclusion of women and minorities in the industry, 

particularly in key management-level positions.1

 

1

GAO has conducted prior work on the challenges faced in the financial sector for 

promoting and retaining a diverse workforce. See GAO, Financial Services Industry: 

Overall Trends in Management-Level Diversity and Diversity Initiatives, 1993-2004, 

The 2007-2009 financial 

crisis has renewed concerns about commitment within the financial 

services industry to workforce diversity and the number of federal 

contracting opportunities available to minority- and women-owned 

businesses. The Dodd-Frank Wall Street Reform and Consumer 

Protection Act (Dodd-Frank Act) included provisions requiring selected 

federal financial agencies and Federal Reserve Banks (Reserve Banks) 

GAO-06-617 (Washington, D.C.: June 1, 2006) and Financial Services Industry: Overall 

Trends in Management-Level Diversity and Diversity Initiatives, 1993-2008, GAO-10-736T 

(Washington, D.C.: May 12, 2010).

 
 

Page 2 GAO-13-238 Financial Services Industry

each to establish an Office of Minority and Women Inclusion (OMWI).2

The act required that these agencies and Reserve Banks establish the 

new diversity and inclusion offices to replace existing diversity programs 

by January 2011 and to begin addressing a number of other requirements 

in the act.3

This report updates our previous work by discussing changes in 

management-level diversity or diversity practices used in this industry 

since the beginning of the financial crisis in 2007. It also reviews the 

implementation of requirements in section 342 of the Dodd-Frank Act on 

workforce diversity. Specifically, our objectives were to discuss (1) what 

available data show about how the diversity of the financial services 

industry workforce and how diversity practices by the industry have 

changed from 2007 through 2011; (2) what available data show about 

how diversity in the workforces of the federal financial agencies and the 

Reserve Banks has changed from 2007 through 2011; (3) how these 

federal financial agencies and Reserve Banks are implementing 

workforce diversity practices under section 342 of the Dodd-Frank Act, 

including the extent to which their workforce diversity practices have 

changed since the financial crisis; and (4) the status of federal financial 

agencies’ and Reserve Banks’ implementation of the contracting 

provisions of the Dodd-Frank Act related to the inclusion of women and 

minorities.

To describe how diversity in the financial services industry and how the 

diversity practices it uses have changed from 2007 through 2011, we 

analyzed 2007-2011 workforce data from the Equal Employment 

Opportunity Commission’s (EEOC) Employer Information Report (EEO-1) 

and from the Current Population Survey (CPS) produced by the Bureau of 

 

2

Pub. L. No. 111-203 § 342,124 Stat.1376,1441-1443 (2010).The federal agencies 

required to meet the workforce diversity provisions in section 342 of the Dodd-Frank Act 

include the Departmental Offices of the Department of the Treasury (Treasury), the 

Federal Deposit Insurance Corporation (FDIC), the Federal Housing Finance Agency 

(FHFA), the Board of Governors of the Federal Reserve System (Federal Reserve Board), 

the National Credit Union Administration (NCUA), the Office of the Comptroller of the 

Currency (OCC), the Securities and Exchange Commission (SEC), and the Bureau of 

Consumer Financial Protection, commonly known as the Consumer Financial Protection 

Bureau (CFPB). Throughout the report we refer to these as either federal financial 

agencies or agencies.

3

CFPB had until January 21, 2012, to establish its OMWI and begin addressing the other 

requirements of the act. 
 

Page 3 GAO-13-238 Financial Services Industry

the Census and the Bureau of Labor Statistics. Through a review of 

documentation, electronic testing, and interviews with knowledgeable 

officials, we found these data sufficiently reliable for our use. We 

conducted a literature review to identify academic and industry studies on 

financial services workforce diversity, and we interviewed 10 industry 

representatives on these issues.

To review changes to the representation of women and minorities in the 

workforces of the agencies and Reserve Banks, we analyzed data the 

agencies submitted to EEOC from 2007 through 2011 in annual Equal 

Employment Opportunity Program Status Reports required by EEOC’s 

MD-715 and analyzed EEO-1 reports provided by the 12 Reserve Banks.4

To determine the extent to which agencies and Reserve Banks are 

implementing the requirements of the Dodd-Frank Act regarding the 

inclusion of women and minorities in contracting, we reviewed annual 

OMWI reports submitted to Congress and interviewed officials on their 

efforts in this area. We collected and reviewed agency documentation of 

procedures developed to address the act’s requirements, such as policy 

manuals, contract provisions related to promoting a diverse workforce, 

process workflows, and technical assistance materials.

We assessed the reliability of these data by conducting electronic testing, 

reviewing agency documentation, and interviewing agency officials. We 

determined that the data were sufficiently reliable for our use. We 

reviewed agency and Reserve Bank documentation of efforts to respond 

to the Dodd-Frank Act requirements, including annual OMWI reports to 

Congress. Additionally, we interviewed agency and Reserve Bank 

officials on changes in the inclusion of women and minorities in their 

workforces and any changes in the practices they used to further 

workforce diversity goals.

We conducted this performance audit from January 2012 through April

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

 

4

The race/ethnicity categories in EEOC data include White, Black, Hispanic, Asian, and 

other races. All non-White categories in EEOC data are considered racial/ethnic minorities 

in this report. 
 

Page 4 GAO-13-238 Financial Services Industry

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The financial services industry is a major source of employment in the 

United States. EEOC data we obtained and analyzed showed that 

financial services firms we reviewed for this work employed more than 2.9 

million people in 2011. We defined the financial services industry to 

include the following sectors:

• depository credit institutions, which include commercial banks, thrifts 

(savings and loan associations and savings banks), and credit unions;

• holdings and trusts, which include investment trusts, investment 

companies, and holding companies;

• nondepository credit institutions, which extend credit in the form of 

loans and include federally sponsored credit agencies, personal credit 

institutions, and mortgage bankers and brokers;

• the securities sector, which is composed of a variety of firms and 

organizations that bring together buyers and sellers of securities and 

commodities, manage investments, and offer financial advice; and

• the insurance sector, including carriers and insurance agents that 

provide protection against financial risks to policyholders in exchange 

for the payment of premiums.

We previously conducted work on the challenges faced in the financial 

sector for promoting and retaining a diverse workforce, focusing on 

private-sector firms.5

 

5

See 

In 2010, we reported that overall diversity at the 

management level in the financial services industry did not change 

substantially from 1993 through 2008 and that diversity in senior positions 

was limited. We also found that without a sustained commitment among 

financial services firms to overcoming challenges to recruiting and 

retaining minority candidates and obtaining “buy-in” from key employees, 

limited progress would be possible in fostering a more diverse workplace.

GAO-06-617 and GAO-10-736T. 

Background 

Financial Services Industry 

and Diversity
 

Page 5 GAO-13-238 Financial Services Industry

In a 2005 report, we defined diversity management as a process intended 

to create and maintain a positive work environment that values

individuals’ similarities and differences, so that all can reach their 

potential and maximize their contributions to an organization’s strategic 

goals and objectives.6 We also identified a set of nine leading diversity 

management practices that should be considered when an organization is 

developing and implementing diversity management. They are (1) 

commitment to diversity as demonstrated and communicated by an 

organization’s top leadership; (2) the inclusion of diversity management in 

an organization’s strategic plan; (3) diversity linked to performance, 

making the case that a more diverse and inclusive work environment 

could help improve productivity and individual and organizational 

performance; (4) measurement of the impact of various aspects of a 

diversity program; (5) management accountability for the progress of 

diversity initiatives; (6) succession planning; (7) recruitment; (8) employee 

involvement in an organization’s diversity management; and (9) training 

for management and staff about diversity management.

Section 342 of the Dodd-Frank Act required specific federal financial 

agencies and Reserve Banks each to establish, by January 21, 2011, an 

OMWI, responsible for matters relating to diversity in management, 

employment, and business activities.7

Table 1: Federal Financial Agencies Subject to Dodd-Frank Act Section 342

Table 1 describes the affected 

agencies.

Agency Function

Bureau of Consumer Financial 

Protection (CFPB)

Commonly known as the Consumer Financial Protection Bureau, writes rules to implement federal 

consumer financial law across banks and nonbanks; supervises for consumer protection purposes 

banks, thrifts, and credit unions with over $10 billion in assets and their affiliates, as well as nonbank 

mortgage-related firms, private student lenders, payday lenders, and certain other larger consumer 

financial companies; and enforces federal consumer financial law with respect to supervised entities 

and other nonbank entities. 

 

6

GAO, Diversity Management: Expert-Identified Leading Practices and Agency Examples, 

GAO-05-90 (Washington, D.C.: Jan. 14, 2005).

7

Pub. L. No. 111-203. § 342, 124 Stat. 1376, 1541-1544 (2010). CFPB had until January 

21, 2012, to comply with the requirements. 

Diversity Requirements 

under Section 342 of the 

Dodd-Frank Act
 

Page 6 GAO-13-238 Financial Services Industry

Agency Function

Federal Deposit Insurance 

Corporation (FDIC)

Regulates FDIC-insured state-chartered banks that are not members of the Federal Reserve 

System, as well as federally insured state savings banks and thrifts; insures the deposits of all 

banks and thrifts that are approved for federal deposit insurance; and resolves all failed insured 

banks and thrifts and may resolve certain bank holding companies and nonbank financial 

companies. 

Federal Housing Finance 

Agency (FHFA)

Supervises and regulates Fannie Mae, Freddie Mac, and the 12 Federal Home Loan Banks and

their Office of Finance. Acts as conservator for Fannie Mae and Freddie Mac.

Board of Governors of the 

Federal Reserve System 

(Federal Reserve Board)

Regulates state-chartered banks that opt to be members of the Federal Reserve System, bank 

holding companies and certain subsidiaries, thrift holding companies, securities holding companies, 

Edge and agreement corporations, U.S. branches of foreign banks, any firm that is designated as 

systemically significant by the Financial Stability Oversight Council (FSOC), and payment, clearing, 

and settlement systems designated as systemically significant by FSOC, unless regulated by SEC 

or the Commodity Futures Trading Commission.

National Credit Union 

Administration (NCUA)

Charters and supervises federally chartered or insured credit unions and operates the National 

Credit Union Share Insurance Fund, which insures savings in federal and most state-chartered 

credit unions.

Office of the Comptroller of the 

Currency (OCC)

Charters and regulates national banks and federal thrifts and U.S. federal branches of foreign 

banks.

Securities and Exchange 

Commission (SEC)

Regulates securities exchanges, broker-dealers, investment companies, investment advisers, 

nationally recognized statistical rating organizations, security-based swap (SBS) dealers, major SBS 

participants, and SBS execution facilities.

Departmental Offices of the 

Department of the Treasury 

(Treasury) 

The Department of the Treasury is organized into two major components: the departmental offices 

and the operating bureaus. The departmental offices are primarily responsible for the formulation of 

policy and management of the department as a whole, and include domestic finance, economic 

policy, international affairs, and others.

Source: GAO review of agency documentation.

The act’s diversity provisions also apply to the Reserve Banks. The 

Federal Reserve System consists of a central governmental agency, the 

Board of Governors, in Washington, D.C., and 12 regional Reserve 

Banks. The 12 Reserve Banks are each responsible for a particular 

geographic area or district of the United States. They are located in 

Atlanta, Boston, Chicago, Cleveland, Dallas, Kansas City, Minneapolis, 

New York, Philadelphia, Richmond, San Francisco, and St. Louis. Unlike 

the Federal Reserve Board, the Reserve Banks are not federal agencies. 

Each Reserve Bank is a federally chartered corporation with a board of 

directors and member banks who are stockholders in the Reserve Bank. 

Under the Federal Reserve Act, Reserve Banks are subject to the general 

supervision of the Federal Reserve Board.8

 

8

Federal Reserve Act, 63 Cong. Ch. 6, 38 Stat. 251-275 (Dec. 23, 1913). 
 

Page 7 GAO-13-238 Financial Services Industry

The act’s diversity provisions require the director of each OMWI to 

develop standards for (1) equal employment opportunity and the racial, 

ethnic and gender diversity of the workforce and senior management for 

the agency; (2) increased participation of minority- and women-owned 

businesses in the programs and contracts of the agency, including 

standards for coordinating technical assistance to such businesses; and 

(3) assessing the diversity policies and practices of entities regulated by 

the agency. It also provides that each OMWI director advise his or her 

agency on the impact of agency policies and regulations on minority- and 

women-owned businesses.9

The act also outlines steps the specific agencies and Reserve Banks 

should take to seek workforce diversity at all levels of their organizations. 

Among other things, these steps include recruiting from colleges serving 

primarily minority populations, sponsoring and recruiting at job fairs in 

urban communities, and advertising positions in newspapers and 

magazines oriented toward minorities and women.

In addition, the act provides that each OMWI director develop and 

implement standards and procedures to ensure, to the maximum extent 

possible, the fair inclusion and utilization of minorities, women, and 

minority- and women-owned businesses in all business and activities of 

the agency at all levels, including in procurement, insurance, and all types 

of contracts. Agency procedures for reviewing and evaluating applicable 

contract proposals and for hiring service providers should include a 

component that gives consideration to applicant diversity, to the extent 

consistent with applicable laws.10

 

9

For purposes of the act, minority means any Black American, Native American, Hispanic 

American, or Asian American. Minority-owned business means a business (i) more than 

50 percent of the ownership or control of which is held by one or more minority individuals; 

and (ii) more than 50 percent of net profit and loss of which accrues to one or more 

minority individuals. Women-owned business means a business (i) more than 50 percent 

of the ownership or control of which is held by one or more women; (ii) more than 50 

percent of the new profit or loss of which accrues to one or more women; and (iii) a 

significant percentage of senior management positions are held by women. 

Additionally, the act mandates that the 

10Section 342 applies to all contracts of an agency for services of any kind, including the 

services of financial institutions, investment-banking firms, mortgage banking entities, 

underwriters, accountants, investment consultants, and providers of legal services. It also 

includes all contracts for all business and activities of an agency, at all levels, including 

contracts for the issuance or guarantee of any debt, equity, or security; the sale of assets; 

the management of assets of the agency; the making of equity investments by the agency; 

and the implementation of programs to address economic recovery. 
 

Page 8 GAO-13-238 Financial Services Industry

OMWI director develop procedures to determine whether contractors, or 

subcontractors when applicable, have made a good faith effort to include 

minorities and women in their workforces. It requires that each OMWI 

director recommend that contracts be terminated if they determine that an 

agency contractor, and as applicable, a subcontractor has failed to make 

a good faith effort to include minorities and women in their workforce. 

Upon receipt of such a recommendation, the head of an agency may 

terminate the contract, make a referral to an office in the Department of 

Labor, or take other appropriate action.

Finally, the act requires each OMWI to submit to Congress an annual 

report detailing the actions taken by the agency and the OMWI to comply 

with the provisions in section 342. The annual reports are required to 

include, among other things, annual amounts paid to contractors, 

including the percentage of the amounts that were paid to minorities, 

women, and minority- and women-owned businesses; any challenges in 

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

challenges in hiring qualified minority and women employees; and any 

other information, findings, conclusions, and recommendations for 

legislative or agency action as the OMWI director determines appropriate.

Diversity has remained about the same at the management level in terms 

of the representation of both minorities and women, while industry 

representatives noted the continued use of leading diversity practices and 

some challenges. According to EEOC data, the representation of 

minorities at the management level stood at 19 percent in 2011. The 

representation of women in management remained at about 45 percent, 

according to EEOC data. The nine leading diversity practices that we 

previously identified in 2005 remain relevant today, according to industry 

representatives with whom we spoke. Industry representatives also noted 

some challenges, such as the difficulty in recruitment because of a limited

supply of diverse candidates.

Industry Diversity 

Levels Remained 

about the Same from 

2007 through 2011
 

Page 9 GAO-13-238 Financial Services Industry

At the overall management level, the representation of minorities 

increased from 17.3 percent to 19 percent from 2007 through 2011 

according to EEOC data we obtained, which are reported by financial 

services firms (see fig. 1).11 While this is not a substantial increase, it 

shows a continued upward trend from our 2006 report, in which data 

showed that management-level representation by minorities increased 

from 11.1 percent to 15.5 percent from 1993 through 2004.12

 

11EEOC compiles EEO-1 data from the reports it collects annually from private employers 

with 100 or more employees or federal contractors with 50 or more employees. Similar to 

our 2006 report, we obtained data from EEOC for private employers with 100 or more 

employees. Consequently, the analysis included in this report may not match the analysis 

found in EEOC’s website, which would also include federal contractors with 50 or more 

employees. The financial services industry EEO-1 data analysis provided in this section of 

the report includes workforce information from the 12 Federal Reserve Banks, as they are 

considered part of the financial services industry. We provide a separate analysis of the 

12 Federal Reserve Banks’ workforce later in the report because they were also covered 

by the Dodd-Frank Act provisions. 

12GAO-06-617.

Diversity in the Financial 

Services Industry 

Remained about the Same 

at the Management Level 

from 2007 through 2011
 

Page 10 GAO-13-238 Financial Services Industry

Figure 1: Percentage of White and Minority Managers in the Financial Services 

Industry, 2007-2011

The representation of minorities varied among management positions, 

which EEOC splits into two categories: (1) first- and mid-level officials and 

managers and (2) senior-level officials and managers. In 2011, the 

representation of minorities among first- and mid-level managers stood at 

20.4 percent, about 1 percentage point higher to the representation of 

minorities among all management positions, according to EEOC data 

(see fig. 2). In contrast, at the senior management level, representation of 

minorities was 10.8 percent in 2011, about 8 percentage points below 

their representation among all management positions; yet representation 

of minorities in first- and mid-level management positions consistently 

increased from 18.7 percent to 20.4 percent over the 5-year period. Firstand mid-level management positions may serve as an internal pipeline in 

an organization through which minority candidates could move into senior 

management positions.
 

Page 11 GAO-13-238 Financial Services Industry

Figure 2: Percentage of Whites and Minorities in First- and Mid-Level Management 

and Senior Management Positions in the Financial Services Industry, 2007-2011

Similar to the total representation of minorities across all management 

positions, specific races/ethnicities have not changed significantly, but 

EEOC data show slight variations of representation for specific 

races/ethnicities. For example, the representation of African Americans 

decreased from 6.5 percent in 2007 to 6.3 percent in 2011, according to 

EEOC data (see fig. 3). In contrast, representation of most other 

races/ethnicities increased, and the highest increase was in the 

representation of Asians, from 5.4 percent to 6.5 percent over the same 

time period.
 

Page 12 GAO-13-238 Financial Services Industry

Figure 3: Percentage of Specific Races/Ethnicities in the Financial Services 

Industry in Overall Management Positions, 2007-2011

From 2007 to 2011, the representation of African Americans went down in 

both management levels, while the representation of other specific 

races/ethnicities either increased or remained stable (see fig. 4). At the 

senior management level, the representation of Asians remained stable at 

about 4.1 percent from 2007 through 2011. However, the representation 

of African Americans in senior management positions decreased from 3.1 

percent to 2.7 percent, and the representation of Hispanics increased 

from 3 percent to 3.3 percent. Among first- and mid-level management 

positions, the representation of Asians increased from 5.6 percent to 6.9 

percent and the representation of Hispanics increased from 5.2 percent to 

5.5 percent, while the representation of African Americans decreased 

from 7.2 percent to 6.9 percent.
 

Page 13 GAO-13-238 Financial Services Industry

Figure 4: Percentage of Specific Races/Ethnicities in the Financial Services 

Industry at Various Management Levels, 2007-2011

Over the same 5-year period, the representation of women at the 

management level remained at about 45 percent in EEOC data, which 

show a slight decrease from 45.1 percent to 44.7 percent (see fig. 5). In 
 

Page 14 GAO-13-238 Financial Services Industry

2006, we reported an increase with representation of women at about 

42.9 percent in 1993 to about 45.8 percent in 2004.13

Figure 5: Percentage of Men and Women in Management Positions in the Financial 

Services Industry, 2007-2011

Among all women in management positions, EEOC data showed that the 

representation of minority women increased, from 20.4 percent to 22 

percent over the same 5-year period (see fig. 6). In addition, EEOC data 

show that the representation of minority men increased from 14.8 percent 

to 16.6 percent.

 

13GAO-06-617.
 

Page 15 GAO-13-238 Financial Services Industry

Figure 6: Percentage of White and Minority Men and White and Minority Women in Management Positions in the Financial 

Services Industry, 2007-2011

Among first- and mid-level management positions, the representation of 

women has been at about 48 percent, slightly higher than the 

representation of women among all management positions. In contrast, 

women represented about 29 percent of all senior management positions 

from 2007 through 2011—about 16 percentage points below the 

representation of women for all management positions, according to 

EEOC data (see fig. 7).
 

Page 16 GAO-13-238 Financial Services Industry

Figure 7: Percentage of Women in the Financial Services Industry by Management 

Level and Race/Ethnicity, 2007-2011

Based on EEOC data, minority women had greater representation at the 

first and mid levels of management compared to the senior level over the 

5-year period. As shown in figure 7, among female senior managers, 

representation of minority women remained at about 13 percent over the 

5-year period. In contrast, among female first- and mid-level managers, 

the proportion of minority women increased during the same period from 

21.2 percent to 22.9 percent.

The representation of minorities increases for both women and men as 

the firm size increases (see fig. 8). For example, in 2011 the 

representation of minorities at firms with 100-249 employees was about 

18 percent among women and about 12 percent among men, while at 

firms with more than 1,000 employees, the representation of minorities 
 

Page 17 GAO-13-238 Financial Services Industry

was about 23 percent among women and about 17 percent among men. 

For additional analysis of EEOC data by workforce position and industry 

sector, see appendix II.

Figure 8: Percentage of Whites/Minorities and Men/Women at Financial Services Firms of Different Sizes, 2007-2011

A survey of the general population shows some similar trends in the 

representation of both women and minorities in the financial services 

industry. The CPS is administered by the Bureau of the Census for the 

Bureau of Labor Statistics and is a monthly survey of about 60,000 

households across the nation. The CPS is used to produce official 

government figures on total employment and unemployment issued each 

month. According to the CPS data, from 2007 through 2011 the 

representation of women at the management level decreased from an 

estimated 49.1 percent to 47.3 percent. In addition, CPS data show a 

smaller increase from an estimated 14.1 percent to 15.1 percent in the 
 

Page 18 GAO-13-238 Financial Services Industry

representation of minorities in management over the same 5-year 

period.14

The nine leading diversity practices that we previously identified in 2005 

are still relevant today, according to industry representatives with whom 

we spoke.15 Some industry representatives highlighted practices among 

these nine that they considered the most important to foster diversity and 

inclusion in their organizations. For example, top leadership commitment 

drives the other eight leading diversity practices, according to 9 of 10 

industry representatives. In addition, accountability helps to promote the 

implementation of the other leading diversity practices because an issue 

is more likely to be addressed if it is tracked, according to 2 industry 

representatives. Moreover, creating awareness of the benefits of diversity 

for an organization among management and employees is important 

because it increases commitment to further the diversity goals of the 

organization, according to 7 industry representatives whom we 

interviewed.16

 

14We determined the CPS-estimated minority percentages of management positions 

within the financial services industry cannot be precisely measured. However, CPSestimated minority percentages were included in this report to provide some more context. 

Since many of the percentage estimates have wide confidence intervals, we encourage 

the reader to interpret the CPS-estimated minority percentages in this report with caution. 

Please see appendix I for the estimated minority percentages and standard errors. 

However, 1 industry representative told us there are still 

some firms that do not see the importance of diversity. In addition, 2 

industry representatives said these 9 leading diversity practices should be 

expanded beyond workforce management to include, for example, an 

organization’s contracting efforts.

15As previously discussed the nine leading diversity practices are (1) commitment to 

diversity as demonstrated and communicated by an organization’s top leadership; (2) the 

inclusion of diversity management in an organization’s strategic plan; (3) diversity linked to 

performance, making the case that a more diverse and inclusive work environment could 

help improve productivity and individual and organizational performance; (4) measurement 

of the impact of various aspects of a diversity program; (5) management accountability for 

the progress of diversity initiatives; (6) succession planning; (7) recruitment; (8) employee 

involvement in an organization’s diversity management; and (9) training for management 

and staff about diversity management. See GAO-05-90. 

16This relates to leading practice diversity linked to performance, which refers to the 

understanding that a more diverse and inclusive work environment can yield greater 

productivity and help improve individuals’ and organization performance, while employee 

involvement refers to the contribution of employees in driving diversity throughout an 

organization. See GAO-05-90. 

Leading Diversity 

Practices Remain Relevant 

but Challenges Exist 

Regarding Recruitment 

and Other Issues
 

Page 19 GAO-13-238 Financial Services Industry

Some industry representatives also noted that measuring the impact of 

various diversity practices is an important practice but that it can also be 

challenging; for example, it can be difficult to link specific practices to 

diversity outcomes and it can be a long-term process. According to some 

industry representatives, financial services organizations may measure 

the effectiveness of their diversity practices by assessing attrition, 

recruiting, and promotion rates, which are similar to measures we had 

previously reported.17

Additional diversity practices identified by some industry representatives 

that can support the leading diversity practices include the following:

For example, a financial services organization may 

measure the proportion of certain minority groups or women in its 

workforce or among its promotions to determine the effectiveness of its 

practices. Further, financial services firms may use surveys to gather 

employee perspectives on workforce diversity issues in the organization, 

such as perceived fairness in the promotion process or factors that affect 

an employee’s decision to remain with the firm, among other topics.

• Sponsor individuals. Sponsorship of women within an organization 

where an executive acts as a guide to help women navigate the 

organization and expand their networks is an important diversity 

practice, according to three industry representatives. This sponsorship 

practice goes beyond the mentoring programs we previously reported 

in 2006, as a sponsor acts as an advocate to help the individual 

advance within the organization.18

• Address biased perceptions. One industry representative told us 

about an effort to combat unconscious bias in promotions. They 

described a promotion system designed to address biased 

perceptions, such as a view of leaders as being typically male. 

According to the industry representative, the firm that employed this 

diversity practice gathered complete and objective evaluations of 

employees and trained its managers to recognize and address these 

perceptions. The result was that the firm promoted greater numbers of 

women into management.

No industry representatives that we contacted reported changes to 

diversity practices as a result of the challenges faced by many firms 

 

17GAO-06-617 and GAO-10-736T. 

18GAO-06-617. 
 

Page 20 GAO-13-238 Financial Services Industry

during the financial crisis. Although representation of minorities and 

women has remained about the same from 2007 through 2011, according 

to some industry representatives, the industry continues to be focused on 

diversity. However, three industry representatives did cite specific 

instances where funding was scaled back as a result of the recent 

financial crisis. One industry representative told us that investment in 

training programs was reduced across the organization, but when a 

measureable impact on employees was identified at this organization, 

steps were taken to address the impact.

Some industry representatives cited challenges to achieving a diverse 

workforce in general. We have previously reported some of these 

challenges, which can affect some of the leading diversity practices.19 Six 

industry representatives said that diversity recruitment is difficult because 

the supply (or “pipeline”) of minority and women candidates is limited. 

This has been a consistent challenge that we previously reported in 2006 

and 2010.20

 

19

Available data indicate that for the internal pool of potential 

candidates for some management positions, representation of women 

varied, while representation of minorities was higher in every 

nonmanagement category compared to management positions (see fig. 

9). For example, in 2011 the representation of women was greater in 

professional positions (about 51 percent) compared to sales positions 

(about 38 percent). In addition, the representation of minorities was 

higher in all nonmanagement positions than at the management level in 

2011, but especially higher in technical and clerical positions at more than 

29 percent in both types of positions. Further analysis of diversity in 

various workforce positions can be found in appendix II.

GAO-06-617 and GAO-10-736T. 

20GAO-06-617 and GAO-10-736T. 
 

Page 21 GAO-13-238 Financial Services Industry

Figure 9: Percentage of Whites/Minorities and Men/Women in Various Financial Services Industry Workforce Positions, 2007-

2011
 

Page 22 GAO-13-238 Financial Services Industry

Note: The following are descriptions of the job categories in EEO-1 data from EEOC: (1) 

“Executive/Senior Level Officials and Managers,” includes individuals who reside in the highest levels 

of organizations and plan, direct, and formulate policies, set strategy, and provide the overall direction 

of enterprises/organizations for the development and delivery of products or services, within the 

parameters approved by boards of directors or other governing bodies; (2) “First/Mid-Level Officials 

and Managers,” includes individuals who receive directions from Executive/Senior Level 

management, and oversee and direct the delivery of products, services, or functions at group, 

regional, or divisional levels of organizations; (3) “professionals” include occupations requiring either 

college graduation or experience of such kind and amount as to provide a comparable background; 

(4) “technicians” include occupations requiring a combination of basic scientific knowledge and 

manual skill that can be obtained through 2 years of post-high school education; (5) “sales workers” 

include occupations engaging wholly or primarily in direct selling; (6) “office and clerical” includes all 

clerical-type work regardless of level of difficulty, where the activities are predominantly nonmanual; 

and (7) the category “other” includes craft workers, operatives, laborers, and service workers.

In recent years, representation in business graduate programs, a 

potential source of future managers in the financial industry, has 

remained stable for women and has increased slightly for minorities, but 

representation is still low for both women and minorities when compared 

to the overall representation of students in the university system.21 To 

assess one possible external pool of candidates for financial services 

firms, we obtained data from the Association to Advance Collegiate 

Schools of Business (AACSB) on the number of students enrolled in 

Master of Business Administration (MBA) degree programs in AACSB 

member schools in the United States from 2007 through 2011 as well as 

the number of students in the university system.

22

 

21We refer to overall representation of students from undergraduate, graduate, and 

doctoral programs as the university system. These data exclude specialized graduate 

programs, such as Master of Economics. In addition, these overall percentages only 

represent enrolled students for which race/ethnicity or gender were indicated.

According to AACSB 

data, the representation of women remained constant over this period, 

while the representation of minorities increased. For example, the 

representation of women among MBA students remained at about 37 

percent over the 5-year period, while representation of women was 

slightly higher in the overall university system at about 41 percent. In 

contrast, as table 2 shows, the representation of minorities increased 

among MBA students from about 26 percent in 2007 to about 29 percent 

in 2011. However, when compared to the university system, 

representation of minorities in the overall university system was slightly 

higher from about 29 percent in 2007 to 34 percent in 2011. 

22AACSB, the world’s largest accreditation association for business schools, conducts an 

annual survey called “Business School Questionnaire” of all its member schools. 

Participation in this survey is voluntary. 
 

Page 23 GAO-13-238 Financial Services Industry

Table 2: Percentage of Students Enrolled in MBA Degree Programs at AACSB 

Member Schools in the United States by Race/Ethnicity, 2007-2011

Year

Total 

enrolled White

Total 

minority

African 

American Hispanic Asian Other

2007 100% 74% 26% 7% 6% 12% 0%

2008 100 73 27 8 6 12 0 

2009 100 73 27 8 7 12 0 

2010 100 72 28 9 7 11 1 

2011 100 71 29 9 7 11 2 

Source: GAO analysis of AACSB International data.

Note: The “other” category includes Native American, and updated race/ethnicity categories 

implemented in 2011 to include “two or more races” and “Native Hawaiian or Other Pacific Islander.” 

Percentages may not always add exactly due to rounding. In addition, these ratios only represent 

MBA enrolled students for whom race/ethnicity was indicated.

Some industry representatives stated that the negative perception of the 

industry could also limit the external pipeline of potential candidates, 

which can make recruitment challenging. Multiple industry representatives 

discussed the need to take a new approach to diversity recruiting as a 

result of the negative image many potential candidates may have about 

the financial services industry following the recent financial crisis. For 

example, to counter negative perceptions that may have resulted from the 

foreclosure crisis or the Occupy Wall Street movement, one industry 

representative told us that it explains to prospective employees the social 

contributions financial services firms make through microfinance or 

economic and community development.

In addition to these difficulties with recruiting, two industry representatives 

highlighted maintaining accountability as a particular challenge for 

financial services firms.23

 

23Accountability refers to the means to ensure that leaders are responsible for diversity by 

aligning their performance assessment and compensation to the progress of diversity 

initiatives. See 

For example, an industry representative said it 

is difficult to promote results in diversity by linking diversity management 

with managers’ performance ratings because this practice may not 

provide enough incentive to many managers. Another industry 

representative told us that recognizing and compensating managers and 

employees for their diversity efforts can result in increased commitment to 

foster workforce diversity and an increase in diversity at firms.

GAO-05-90. 
 

Page 24 GAO-13-238 Financial Services Industry

Since the financial crisis, senior management-level minority and gender 

diversity at the federal financial agencies and Reserve Banks has varied 

across individual entities.24 The representation of minorities at the senior 

management-level increased slightly overall at both the agencies and 

Reserve Banks. In addition, the representation of women at the senior 

management-level increased slightly overall for both the agencies and 

Reserve Banks. Agency and Reserve Bank officials identified key 

challenges to increasing workforce diversity overall and at the senior 

management-level, including limited representation of minorities and 

women among internal and external candidate pools.

Senior management-level representation of minorities and women varied 

across individual federal financial agencies and the 12 Reserve Banks. 

The agencies included FDIC, the Federal Reserve Board, NCUA, OCC, 

and Treasury. Complete data for this period were not available for CFPB, 

FHFA, and SEC, and we excluded these agencies from our analysis of 

changes in senior management-level diversity from 2007 through 2011, 

but provide recent data when available. Data for each agency are 

provided in appendix IV. CFPB assumed responsibility for certain 

consumer financial protection functions in July 2011 and has not yet 

reported workforce information to EEOC.25 However, we received recent 

employment profile data from CFPB as of May 2012.26

 

24Our analysis of employment data in this section of the report differs from how EEOC 

typically reports data. While EEOC reports on individual equal employment opportunity 

groups, we report on minorities as a group. Additional data and figures supporting this 

section of the report are in appendixes III and IV. 

FHFA, which was 

established in July 2008, started reporting workforce data for 2010; while 

our analysis provides 2010 and 2011 data for FHFA, our analysis across 

the agencies excludes FHFA from aggregated totals. SEC reported data 

for 2007 through 2011, but revised how it reported officials and managers 

during the 5-year period; while our analysis provides 2011 senior 

25On July 21, 2010, the Consumer Financial Protection Act established CFPB as an 

independent bureau within the Federal Reserve System to be headed by a director. 

Effective July 21, 2011, CFPB assumed responsibility for certain consumer financial 

protection functions formerly the responsibilities of the Board of Governors of the Federal 

Reserve System, the Comptroller of the Currency, the Director of the Office of Thrift 

Supervision, FDIC, the Federal Trade Commission, NCUA, and the Secretary of the 

Department of Housing and Urban Development.

26CFPB provided to us workforce diversity data for all employees, senior officials, and 

supervisors as of May 19, 2012.

Agency and Reserve 

Bank Workforce 

Diversity Varied, and 

Officials Reported 

Difficulty Identifying 

Diverse Candidates

Senior Management-Level 

Representation of 

Minorities and Women 

Varied at Agencies and 

Reserve Banks, with Slight 

Changes Overall
 

Page 25 GAO-13-238 Financial Services Industry

management-level data for SEC, we excluded SEC from our senior 

management-level trend analysis.

In our review of agency reports, we found that from 2007 through 2011, 

the representation of minorities among senior management-level 

employees, when aggregated across FDIC, the Federal Reserve Board, 

NCUA, OCC, and Treasury, increased slightly, from 16 to 17 percent for 

the agencies combined (see fig. 10).27 From 2007 through 2011, three 

agencies—FDIC, the Federal Reserve Board, and Treasury—showed an 

increase in the representation of minorities at the senior managementlevel, by between 1 and 3 percentage points. Two agencies—NCUA and 

OCC—experienced no percentage point change in their representation of 

minorities at the senior management-level from 2007 through 2011.28 In 

2011, the representation of minorities among senior management-level 

employees of these agencies, FHFA, and SEC ranged from 11 percent at 

SEC to 24 percent at FHFA. Additionally, CFPB employment data 

showed about 28 percent representation of minorities among senior 

officials as of May 2012.29

 

27Federal financial agencies provided us reports they issued according to EEOC 

Management Directive 715, known as MD-715 reports. This directive does not apply to the 

Federal Reserve Banks, as they are not federal agencies. Our analysis of the 

representation of minorities and women at the senior management level for agencies 

reviewed the numbers of employees the agencies reported as “Executive/Senior Level” 

from 2007 through 2011. Though the MD-715 reports allow for this category to cover 

Grades 15 and above, agencies have discretion to decide which positions are included in 

this senior level versus those the agencies include at lower levels of management. 

Therefore, comparisons of a given management level between the agencies do not 

necessarily involve the same set of managers at each agency. Figures in our analysis are 

rounded to the nearest percent. 

28Percentage changes in the representation of minorities among senior management-level 

employees from 2007 through 2011 for NCUA and OCC were zero when rounded to the 

nearest percent. The representation of minorities among senior management-level 

employees was 12 percent at NCUA in 2007 and 2011, and at OCC, 17 percent in 2007 

and 18 percent in 2011. 

29CFPB identified these employees as Executive/Senior Officials. 
 

Page 26 GAO-13-238 Financial Services Industry

Figure 10: Percentage of Minorities among Senior Management-Level Employees at Six Federal Financial Agencies, 2007-

2011

Notes: Percentages are rounded to the nearest percent.

For our analysis, we reviewed the numbers of employees the agencies reported according to 

race/ethnicity and gender in table A3 of their MD-715 reports from 2007 through 2011. These data 
 

Page 27 GAO-13-238 Financial Services Industry

are based on information self-reported by employees to each agency and there were some 

differences in reporting across the agencies. In some years, some agencies reported all employees—

permanent and temporary—in their A3 tables while others reported permanent employees only. We 

considered employees reported by agencies in the category “Executive/Senior Level” as senior 

management-level employees. Though the MD-715 report guidelines instruct agencies to identify 

employees Grades 15 and above who have supervisory responsibility in this category, agencies have 

discretion to include employees who have significant policymaking responsibilities but do not 

supervise employees. As a result, the composition of the “Executive/Senior Level” category may vary 

among the different agencies and does not necessarily involve the same set of managers at each 

agency.

a

Our trend analysis for “all agencies” excludes CFPB, FHFA, and SEC. CFPB assumed responsibility 

for certain consumer financial protection functions in July 2011 and has not yet reported workforce 

information to EEOC. FHFA was established in 2008 and started reporting workforce data for 2010. 

SEC revised how it reported officials and managers between 2007 and 2011. While our analysis 

includes 2011 management-level data for SEC, we excluded SEC from our trend analysis.

In our review of EEO-1 reports provided by the Reserve Banks, we found 

that the representation of minorities among senior management-level 

employees in aggregate across the 12 Reserve Banks increased from 11 

percent to 14 percent from 2007 through 2011 (see fig.11).30

 

30Reserve Banks provided us reports they issued to EEOC according to form EEO-1. Our 

analysis of senior management-level representation for the Reserve Banks included 

employees the banks reported as “Executive/Senior Officials and Managers.” Figures in 

our analysis are rounded to the nearest percent.

The 

population of senior management-level employees at each bank in 2011 

ranged from 9 employees at the Reserve Banks of Chicago, Dallas, and 

Minneapolis, to 59 employees at the Reserve Bank of New York, and the 

population of minority senior management-level employees at each bank 

ranged from zero employees at the Reserve Bank of Cleveland to 7 

employees at the Reserve Bank of New York. Specific information on 

each Reserve Bank is provided in appendix IV. 
 

Page 28 GAO-13-238 Financial Services Industry

Figure 11: Percentage of Minorities among Senior Management-Level Employees at 

the 12 Reserve Banks, 2007-2011

Notes: Data are rounded to the nearest percent. 

Reserve Bank data are presented in aggregate because the population of senior management-level

employees at most Reserve Banks is generally small and the gain or loss of one employee can result 

in a large percentage point change in the representation of minorities. Specific information on each 

Reserve Bank is provided in appendix IV.
 

Page 29 GAO-13-238 Financial Services Industry

In general, the representation of women at the senior management-level 

increased slightly since the beginning of the financial crisis in 2007 at 

agencies, but representation percentages varied for each entity. In our 

review of agency reports, we found that from 2007 through 2011, the 

representation of women at the senior management-level increased 

slightly from 34 to 36 percent across FDIC, the Federal Reserve Board, 

NCUA, OCC, and Treasury, in aggregate (see fig. 12). Changes varied by 

agency, from a decrease of 5 percentage points at OCC to an increase of 

5 percentage points at NCUA. Four of the five agencies—FDIC, the 

Federal Reserve Board, NCUA, and Treasury—showed an increase of 

between 3 and 5 percentage points in the representation of women at the 

senior management-level from 2007 through 2011. In 2011, the 

representation of women among senior management-level employees 

ranged among the agencies from 31 percent at FDIC to 47 percent at 

FHFA. Additionally, CFPB employment data showed the representation of 

women among senior officials at about 35 percent as of May 2012.
 

Page 30 GAO-13-238 Financial Services Industry

Figure 12: Percentage of Women among Senior Management-Level Employees at Six Federal Financial Agencies, 2007-2011
 

Page 31 GAO-13-238 Financial Services Industry

Notes: Percentages are rounded to the nearest percent.

For our analysis, we reviewed the numbers of employees the agencies reported according to 

race/ethnicity and gender in table A3 of their MD-715 reports from 2007 through 2011. These data 

are based on information self-reported by employees to each agency and there were some 

differences in reporting across the agencies. In some years, some agencies reported all employees—

permanent and temporary—in their A3 tables while others reported permanent employees only. We 

considered employees reported by agencies in the category “Executive/Senior Level” as senior 

management-level employees. Though the MD-715 report guidelines instruct agencies to identify 

employees Grades 15 and above who have supervisory responsibility in this category, agencies have 

discretion to include employees who have significant policymaking responsibilities but do not 

supervise employees. As a result, the composition of the “Executive/Senior Level” category may vary 

among the different agencies and does not necessarily involve the same set of managers at each 

agency.

a

Our trend analysis for “all agencies” excludes CFPB, FHFA, and SEC. CFPB assumed responsibility 

for certain consumer financial protection functions in July 2011 and has not yet reported workforce 

information to EEOC. FHFA was established in 2008 and started reporting workforce data for 2010. 

SEC revised how it reported officials and managers between 2007 and 2011. While our analysis 

includes 2011 management-level data for SEC, we excluded SEC from our trend analysis.

In our review of EEO-1 reports provided by the Reserve Banks, we found 

that from 2007 through 2011, the representation of women at the senior 

management-level increased from 32 percent to 38 percent for the 

Reserve Banks, in aggregate (see fig. 13). As mentioned previously, the 

population of senior management-level employees at each bank in 2011 

ranged from nine employees at the Reserve Banks of Chicago, Dallas, 

and Minneapolis, to 59 employees at the Reserve Bank of New York. The 

population of women among senior management-level employees at 

each bank in 2011 ranged from two employees at the Reserve Bank of 

Boston to 25 employees at the Reserve Bank of New York. Specific 

information on each Reserve Bank is provided in appendix IV. 
 

Page 32 GAO-13-238 Financial Services Industry

Figure 13: Percentage of Women among Senior Management-Level Employees at 

the 12 Reserve Banks, 2007-2011

Notes: Data are rounded to the nearest percent. 

Reserve Bank data are presented in aggregate because the population of senior management-level 

employees at most Reserve Banks is generally small and the gain or loss of one employee can result 

in a large percentage point change in the representation of women. Specific information on each 

Reserve Bank is provided in appendix IV.
 

Page 33 GAO-13-238 Financial Services Industry

Several agencies reported on existing diversity practices related to 

retaining and promoting employees to build management-level diversity. 

For example, according to agency reports, some Treasury offices conduct 

formal mentoring programs, and the Federal Reserve Board has 

customized mentoring programs within its divisions, which in conjunction 

with a leadership exchange program sponsored by the Federal Reserve 

System, provide employees opportunities to develop new skills and 

experiences. Further, OCC reported having development programs for 

employees within its bank supervision division that provide leadership and 

development opportunities to staff, and agency-sponsored employee 

network groups implemented mentoring circles to assist in the career 

development and retention of the agency’s workforce.

Several Reserve Banks identified practices targeted to improve 

management-level diversity, including changes to hiring practices and 

mentoring programs. For example, officials from several Reserve Banks 

we contacted said their organizations revised their hiring policies to open 

all management-level positions to external applicants in addition to 

current employees as a way to build management-level diversity by hiring 

diverse, experienced candidates from outside the organization. 

Additionally, the Reserve Banks of Dallas and New York began piloting 

new mentoring programs in 2011, and each planned to expand its 

program based on initial feedback its OMWI had received. These banks 

and several others with existing mentoring programs reported that 

mentoring programs were important to retaining and developing minorities 

and women within their organizations. Later in this report, we provide 

additional information on the agencies’ and Reserve Banks’ recruitment 

practices as part of their efforts to implement section 342 of the DoddFrank Act.31

 

31Among other things, the act outlines steps the specific agencies and Reserve Banks 

should take to seek workforce diversity at all levels of their organizations. These steps 

include recruiting from colleges serving primarily minority populations, sponsoring and 

recruiting at job fairs in urban communities, and advertising positions in newspapers and 

magazines oriented toward minorities and women.
 

Page 34 GAO-13-238 Financial Services Industry

Based on our analysis of minority and gender diversity at all levels from 

2007 through 2011, workforce diversity varied at the federal financial 

agencies and Reserve Banks, with slight decreases in aggregate. 

Specifically, the representation of minorities decreased slightly from 31 

percent to 30 percent from 2007 through 2011 across FDIC, the Federal 

Reserve Board, NCUA, OCC, SEC, and Treasury, in aggregate. 

Additionally, CFPB employment data showed the representation of 

minorities of all agency employees at about 33 percent as of May 2012. 

Three agencies—NCUA, OCC, and SEC—showed a 1 percentage point 

or greater increase in the overall representation of minorities during the 5-

year period, according to agency reports. In 2011, the representation of 

minorities at the agencies ranged from 25 percent at NCUA to 44 percent 

at the Federal Reserve Board. Our analysis of EEO-1 reports provided by 

the Reserve Banks for 2007 through 2011 showed that the representation 

of minorities across the Reserve Banks declined slightly in aggregate, 

from 38 percent to 36 percent. The Reserve Banks of Minneapolis and 

New York showed a 2 percentage point increase in the overall 

representation of minorities working at Reserve Banks, the Reserve Bank 

of Boston showed no percentage point change, and the remaining nine 

banks showed decreases of 1 to 8 percentage points. In 2011, the 

representation of minorities at the Reserve Banks ranged from 16 percent 

at the Reserve Bank of Kansas City to 53 percent at the Reserve Bank of 

San Francisco.

Similarly, we found that overall gender diversity varied at individual 

agencies and Reserve Banks, and generally declined slightly from 2007 

through 2011. The overall representation of women in the workforce 

aggregated across FDIC, the Federal Reserve Board, NCUA, OCC, SEC, 

and Treasury declined slightly from 47 percent to 45 percent over the 5-

year period. Additionally, CFPB employment data showed the 

representation of women of all agency employees at about 49 percent as 

of May 2012. Two agencies—NCUA and SEC—showed no percentage 

point change in the representation of women during the 5-year period; 

OCC showed a decrease of about 1 percentage point, and the other three 

agencies—FDIC, the Federal Reserve Board, and Treasury—

experienced decreases of 2 percentage points. In 2011, the 

representation of women among all employees at the agencies ranged 

from 42 percent at FDIC to 48 percent at SEC and Treasury. The overall 

representation of women across the Reserve Banks, in aggregate, 

declined from 49 percent to 45 percent from 2007 through 2011. All 

Reserve Banks showed declines in the representation of women among 

all employees during the 5-year period, ranging from a 1 percentage point 

decrease at the Reserve Bank of New York to a 7 percentage point 

Total Workforce Minorities 

and Women 

Representation Varied but 

Decreased Slightly Overall
 

Page 35 GAO-13-238 Financial Services Industry

decrease at the Reserve Bank of Cleveland. For example, in 2007, 827 of 

the Reserve Bank of Cleveland’s 1,568 employees were women, and in 

2011, 500 of the bank’s 1,094 employees were women; the bank’s 

workforce changed from having around 53 percent women employees to 

about 46 percent women employees. In 2011, the overall representation 

of women at Reserve Banks ranged from 40 percent at the Reserve 

Banks of Philadelphia and Richmond to 53 percent at the Reserve Bank 

of Minneapolis. See appendix III for additional information on the overall 

workforce representation for the agencies and Reserve Banks.

According to officials from five Reserve Banks and the Federal Reserve 

Board, consolidation of check processing and other operations, some of 

which occurred since the financial crisis, had eliminated many 

administrative and service worker positions. Since these positions are 

often held by minorities and women, these consolidations affected overall 

employment diversity at affected Reserve Banks. In response to declines 

in the use of paper checks and greater use of electronic payments, the 

Reserve Banks took steps beginning in 2003 to reduce the number of 

locations where paper checks were processed. In 2001, the Federal 

Reserve System employed around 5,500 people in check processing 

functions across 45 locations, and in 2008, around 2,800 employees 

supported check processing functions across 18 locations. By 2010, one 

paper check processing site remained in Cleveland, along with an 

electronic check processing site in Atlanta. As of January 2013, 

approximately 480 employees supported check processing functions 

across the Federal Reserve System. The Federal Reserve System is 

projected to complete its consolidation of check processing functions in 

2013.

OMWI officials described challenges to building workforce diversity both 

at the management level and overall. Four agencies—FDIC, the Federal 

Reserve Board, FHFA, and OCC—and three Reserve Banks—the 

Reserve Banks of Chicago, Minneapolis, and St. Louis—cited 

underrepresentation of minorities and women within internal candidate 

pools as a challenge to building management-level diversity, as many 

management-level positions are filled through promotions or internal 

hiring processes. Additionally, the Reserve Banks of Dallas, Minneapolis, 

Philadelphia, and San Francisco said low turnover was a challenge to 

increasing their management-level diversity profiles because it limited 

opportunities to increase organizational diversity through hiring and 

promotion.

Officials Reported 

Difficulty Identifying 

Diverse Candidates as the 

Main Challenge to Building 

Workforce Diversity
 

Page 36 GAO-13-238 Financial Services Industry

Federal financial agencies and Reserve Banks identified other challenges 

to building workforce diversity generally. The Reserve Banks of Atlanta, 

Boston, Chicago, Kansas City, and St. Louis cited competition from the 

private sector for recruiting diverse candidates as a challenge. In addition, 

FHFA and the Reserve Banks of Cleveland, Philadelphia, and San 

Francisco cited limited representation of minorities within external 

candidate pools as another challenge. The Federal Reserve Board and 

the Reserve Banks of Chicago and Kansas City reported that the 

availability of external candidates could be an issue in particular for hiring 

certain specialized positions, such as economists, which would involve a 

small candidate pool with limited representation of minorities. Additionally, 

three Reserve Banks identified geographic impediments to their national 

recruitment efforts, explaining that it is difficult to attract candidates from 

outside their region. For example, the Reserve Banks of Kansas City and 

St. Louis said it was difficult to recruit candidates lacking ties to the 

central United States, and the Reserve Bank of San Francisco cited 

difficulty recruiting from the eastern United States. Further, several 

agencies and Reserve Banks identified other challenges to building 

workforce diversity. For example, Treasury cited budget constraints on 

hiring and the Reserve Bank of Cleveland cited time constraints on 

recruitment practices as challenges. Additionally, NCUA cited as a 

challenge establishing tracking systems to help identify barriers to 

recruiting, hiring, and retaining minorities.

Federal financial agencies and Reserve Banks have begun implementing 

key requirements of section 342 of the Dodd-Frank Act. First, all agencies 

and Reserve Banks have established OMWIs. Most agencies and all of 

the Reserve Banks used existing policies to establish standards for equal 

employment opportunity required by the act. Although many agencies and 

Reserve Banks had been using recruitment practices required by the act 

prior to its enactment, the majority of OMWIs have expanded these or 

initiated other practices. In addition to meeting requirements regarding 

their diversity policies, the federal financial agencies have taken 

preliminary steps to develop procedures for assessing the diversity 

policies and practices of entities they regulate, as required under the act. 

Finally, nearly all the agencies and all of the Reserve Banks are reporting 

annually on their diversity practices. While many OMWIs have 

implemented or are planning efforts to measure and evaluate the 

progress of their diversity and inclusion activities, information on such 

efforts is not yet reported consistently across the OMWI annual reports. 

Such information could enhance their efforts to report on measuring 

outcomes and the progress of their diversity practices.

Dodd-Frank 

Requirements Are 

Being Implemented, 

but Enhanced 

Reporting of Efforts 

to Measure Progress 

Is Needed
 

Page 37 GAO-13-238 Financial Services Industry

All federal financial agencies and all Reserve Banks have established an 

OMWI. Six of the seven agencies that existed when the Dodd-Frank Act 

was enacted established OMWIs by January 2011, pursuant to the time 

frame established in the act. Additionally, SEC formally established its 

OMWI in July 2011, following House and Senate Appropriations 

Committees’ approvals of the agency’s request to create an OMWI.32

SEC selected an OMWI director in December 2011, who officially joined 

the office in January 2012. CFPB, which assumed responsibility for 

certain consumer financial protection functions in July 2011, established 

its OMWI in January 2012 and its OMWI director officially joined the 

agency in April 2012.33

Many agencies and most of the Reserve Banks established their OMWIs 

as new, separate offices. Four of eight agencies and 9 of 12 Reserve 

Banks established their OMWIs separate from other offices, including four 

banks that refocused existing diversity offices as their OMWIs. Three

agencies—FDIC, the Federal Reserve Board, and OCC—and three 

banks—the Reserve Banks of Atlanta, Kansas City, and Philadelphia—

established their OMWIs within existing offices of equal employment 

opportunity (EEO) or diversity. FHFA established its OMWI and then 

merged its EEO function into that office. OMWI officials from several 

agencies with separate OMWIs said their staff worked with their EEO

offices to address agency diversity issues. Similarly, many agency and 

Reserve Bank OMWI officials said they coordinated with other offices 

across their organizations, such as human resources, recruiting, 

procurement, and management, to support ongoing diversity and 

inclusion efforts organizationwide.

Federal financial agencies and Reserve Banks all have taken steps to 

staff their OMWIs. As of January 2013, the agencies had allocated 

 

32SEC determined it could not use appropriated funds for the purpose of establishing an 

OMWI without first obtaining congressional approval. Its reprogramming request was 

approved by the House and Senate Appropriations Committees in July 2011. 

33As mentioned previously, on July 21, 2010, the Consumer Financial Protection Act of 

2010 established CFPB as an independent bureau within the Federal Reserve System to 

be headed by a director. Effective July 21, 2011, CFPB assumed responsibility for certain 

consumer financial protection functions formerly the responsibilities of the Board of 

Governors of the Federal Reserve System, the Comptroller of the Currency, the Director 

of the Office of Thrift Supervision, FDIC, the Federal Trade Commission, NCUA, and the 

Secretary of the Department of Housing and Urban Development. CFPB had until January 

21, 2012, to establish its OMWI and begin addressing the other requirements of the act.

Agencies and Reserve 

Banks Have Established 

Offices of Minority and 

Women Inclusion and 

Diversity Standards
 

Page 38 GAO-13-238 Financial Services Industry

between 3 and 40 full-time equivalent positions to their OMWIs (see table 

3), and all agencies had open positions they planned to fill among these 

allocated positions. FDIC had allocated 40 full-time equivalent positions to 

its combined OMWI/EEO office as of January 2013. Many of FDIC’s 

OMWI staff, including eight EEO specialists, support the office’s EEO 

functions, and OCC and FHFA also reported EEO specialists among their 

staff. The agency OMWIs included directors and analysts among their 

staff, as well as some positions specific to certain functions of the 

OMWIs. For example, four of the agencies—CFPB, FDIC, NCUA, and 

SEC—had allocated staff specifically to recruitment and outreach 

functions, and four of the agencies—NCUA, OCC, SEC, and Treasury—

had allocated staff specifically to business and supplier diversity. Four

agencies—the Federal Reserve Board, FHFA, NCUA, and OCC—had 

each allocated a position to help implement the Dodd-Frank Act 

requirement to review the diversity practices of regulated entities.

Additionally, two of the agencies—CFPB and SEC—had attorney

positions among their OMWI staff.

Table 3: OMWI Staffing Levels for Federal Financial Agencies, as of January 2013

Agency Allocated Filled

CFPB 4 3 

Federal Reserve Board 3 a 2 

FDIC 40 a 35

FHFA 9 a,b 8 

NCUA 6 5 

OCC 12 a 11

SEC 9 c 8 

Treasury 11 8 

Source: GAO analysis of federal financial agency information.

a

Totals for FDIC, FHFA, and OCC include EEO staff, as the OMWI offices for these agencies include 

both functions. The Federal Reserve Board also established its OMWI within an existing office, but it 

provided information for OMWI staff only and excluded the office’s director position, as agency 

officials said additional funds for the director position were not allocated because the director’s 

primary duties included overseeing EEO compliance, diversity, and inclusion.

b

Totals for FHFA include part-time staff.

c

The Reserve Banks had allocated between three and seven full-time 

equivalent positions to their OMWIs as of January 2013 (see table 4). Ten 

of the 12 Reserve Banks had filled all of these positions, while the 

In addition to these staff, SEC’s OMWI is supported by two full-time contract positions, a program 

analyst and a recruitment coordinator.
 

Page 39 GAO-13-238 Financial Services Industry

Reserve Banks of Cleveland and St. Louis each had one open position. 

The Reserve Bank OMWIs included directors and analysts among their 

staff. Few Reserve Banks designated specific OMWI functions to certain 

positions. Three banks, the Reserve Banks of Atlanta, Boston, and St. 

Louis, had each allocated one position to supplier or business diversity, 

and two other banks, the Reserve Banks of Chicago and Cleveland, had 

each allocated one position to help carry out the reporting functions of the 

OMWIs.

Table 4: OMWI Staffing Levels for Reserve Banks, as of January 2013

Reserve Bank Allocated Filled

Atlanta 4.5 a 4.5

Boston 5 5 

Chicago 7 7 

Cleveland 4 3 

Dallas 4 b 4 

Kansas City 5 b 5 

Minneapolis 3 b 3 

New York 5 5 

Philadelphia 3 b 3 

Richmond 5 5 

San Francisco 3 3 

St. Louis 5 4 

Source: GAO analysis of Reserve Bank information.

a

Totals for the Reserve Bank of Atlanta include part-time staff. 

b

Perspectives on the role of OMWIs varied across some Reserve Bank 

officials with whom we spoke. While several Reserve Bank officials said 

their OMWIs were involved in policy development with a commitment to 

improving the Reserve Bank’s diversity efforts over time, officials from 

one Reserve Bank said their OMWI was compliance-focused and 

primarily analyzed the banks’ human capital resources and recruiting 

functions for compliance with Dodd-Frank Act requirements. Reserve 

Bank of Dallas officials told us they considered the OMWI staff members 

as objective critics of the Reserve Bank’s recruitment, procurement, and 

financial education efforts, and that bank management is responsible for 

fostering diversity and inclusion across the organization.

Totals for the Reserve Banks of Dallas, Kansas City, Minneapolis, and Philadelphia include full-time 

employees with shared duties that help support the OMWI. 
 

Page 40 GAO-13-238 Financial Services Industry

The act also required federal financial agency and Reserve Bank OMWIs 

to develop standards for equal employment opportunity and the racial, 

ethnic, and gender diversity of the workforce and senior management.34

Six of eight agencies and most Reserve Banks indicated either their 

previously established equal employment opportunity standards or MD715 requirements for agencies helped satisfy the Dodd-Frank Act 

requirement to establish equal employment opportunity standards with 

minimal changes, while two agencies and one Reserve Bank were still 

determining how to respond to the requirement. Treasury and CFPB 

planned to develop benchmarks of best practices as standards for 

diversity and inclusion. For example, Treasury officials said they planned 

to identify qualitative measures or indicators for assessing workforce 

diversity practices. Additionally, the Reserve Banks of Kansas City and 

San Francisco revised their diversity and inclusion policies pursuant to 

Dodd-Frank Act requirements. One agency established new standards 

separate from its existing equal employment opportunity policies as 

standards for the diversity of the workforce and senior management. 

Specifically, NCUA developed a diversity and inclusion strategic plan in 

response to a government-wide executive order that provides diversity 

standards and goals, which officials said the agency used to help 

establish expectations for staff.35

OMWI Annual Reports to Congress and officials we contacted indicated 

that federal financial agencies and Reserve Banks have implemented 

various practices pursuant to the Dodd-Frank Act’s requirements 

regarding diversity recruiting, outlined in table 5. Most agency and 

Reserve Bank OMWIs indicated that they had been conducting various 

diversity recruitment practices prior to the enactment of the Dodd-Frank 

Act—such as partnering with organizations focused on developing 

opportunities for minorities and women.

 

34 Pub. L. No. 111-203. § 342(b)(2) (2010).

35Exec. Order 13583 (2011).

Agencies and Reserve 

Banks Are Implementing 

Recruitment Practices
 

Page 41 GAO-13-238 Financial Services Industry

Table 5: Federal Financial Agency and Reserve Bank Implementation of Dodd-Frank Act Section 342 Diversity Recruitment 

Requirements 

Section Requirement Agency and Reserve Bank implementation efforts

Sec. 342(f)(1) Recruiting at historically black 

colleges and universities, Hispanicserving institutions, women’s 

colleges, and colleges that typically 

serve majority minority populations

Seven of eight agencies and all Reserve Banks reported on efforts to recruit 

from historically black colleges and universities and other minority-serving 

institutions.

Additionally, a few Reserve Banks reported on regional diversity recruitment 

efforts that included recruiting from two California State University locations 

that serve Latino communities. 

Sec. 342(f)(2) Sponsoring and recruiting at job 

fairs in urban communities

All agencies and all Reserve Banks participated in diversity job fairs sponsored 

by minority-serving groups.

These practices included participating in national job fairs sponsored by the 

National Urban League, National Black MBA Association, National Association 

of Black Accountants, National Society of Hispanic MBAs, Association of Latino 

Professionals in Finance and Accounting, Society for Women Engineers, 

National Association of Asian MBAs, and the Pacific Asian Consortium in 

Employment.

Sec. 342(f)(3) Placing employment 

advertisements in newspapers and 

magazines oriented toward 

minorities and women

Five agencies and all Reserve Banks reported on efforts to place 

advertisements in minority- and women-serving publications. These included 

posting jobs in IMDiversity, Hispanic Business, EOE Journal, Diversity Life, 

Diversity Women, and Hispanic Life magazines.

Sec. 342(f)(4) Partnering with organizations 

focused on developing opportunities 

for minorities and women to place 

talented young minorities and 

women in industry internships, 

summer employment, and full-time 

positions

Seven agencies and all Reserve Banks have partnerships with organizations 

for internship programs, including the Hispanic Association of Colleges and 

Universities, Washington Internships for Native Students, and INROADS, a 

nonprofit organization that trains and develops minority students for careers in 

business and industry.

Sec. 342(f)(6) Any other mass media 

communications that the OMWI 

determines necessary

Two agencies and all Reserve Banks identified additional mass media 

communications to support their diversity recruiting efforts, including using 

social media networking sites such as Facebook and Twitter to reach diverse 

candidates. For example, CFPB created a recruitment website based on the 

agency’s review of best practices for developing diverse applicant pools, and 

the Federal Reserve System (the Board and all the Reserve Banks) maintains 

a presence on the LinkedIn networking website. 

Source: GAO summary of Dodd-Frank Act section 342 and information provided by federal financial agencies and Reserve Banks.

Note: Sec. 342(f)(5) pertains to partnering with inner-city high schools, girls’ high schools, and 

majority-minority population high schools to establish or enhance financial literacy programs and 

provide mentoring and is not included in this list or addressed in this report.

The majority of agencies and Reserve Banks focused their recruitment 

efforts on attending job fairs and maintaining partnerships with minorityserving institutions and organizations. According to Federal Reserve 

Board and Reserve Bank officials, they collectively participate in and fund 

recruitment activities, including national career fairs, advertisements in 

diverse publications, and social media initiatives. The Reserve Bank of 

Chicago coordinates the Federal Reserve System’s participation in 

national diversity recruitment events and oversees an internal training 
 

Page 42 GAO-13-238 Financial Services Industry

initiative aimed at developing and retaining employees within the Federal 

Reserve System. In addition to participating in these efforts, Reserve 

Banks conduct some activities independently.

Some OMWIs indicated their diversity activities had changed due in part 

to recent efforts to satisfy section 342 requirements as well as broadening 

their approaches to diversity and inclusion. For example, some OMWIs 

indicated the scope of their diversity and inclusion practices had 

broadened to include persons with disabilities as well as the lesbian, gay, 

bisexual, and transgender community. Further, the majority of OMWIs 

reported on plans to improve or expand existing practices. For example, 

many OMWIs described plans to pursue new or further develop existing 

partnerships with organizations focused on developing opportunities for 

minorities and women, and some OMWIs described recent efforts to 

expand internship opportunities for minority students.

Some OMWI officials identified practices targeted to improve 

organizationwide diversity, which could eventually help build 

management-level diversity. These included targeted recruitment to 

attract minorities and women, training for hiring managers and other 

employees on diversity hiring practices, and expanded internship 

programs as a way to hire a greater number of female and minority 

interns.

• Targeted recruitment. All agencies and Reserve Banks with whom we 

spoke had participated in career fairs or partnerships with minorityserving organizations, as outlined in section 342 of the Dodd-Frank 

Act, to target diversity recruitment, and in several cases bolster 

recruitment of particular populations, such as Hispanics. The OMWIs 

at FDIC, FHFA, and SEC work with the agencies’ hiring and 

recruitment staff to identify strategies for recruiting diverse candidates. 

Additionally, the Federal Reserve Board OMWI reported that including 

hiring managers at diversity career fairs had made their targeted 

recruitment activities more effective.

• Training for hiring managers. Some OMWIs reported they 

implemented practices to educate supervisors and hiring managers 

on diversity hiring practices. For example, the Reserve Bank of New 

York designed a training course to enhance cross-cultural interviewing 

skills of recruitment staff. OCC also provides diversity recruitment 

training to the agency’s recruitment staff, and CFPB planned to 
 

Page 43 GAO-13-238 Financial Services Industry

provide its hiring managers a toolkit with tips on diversity hiring 

practices.

• Internship programs. Many agencies and Reserve Banks 

implemented internship programs to build employment diversity by 

developing a more diverse pipeline of potential entry-level candidates. 

For example, the Reserve Bank of San Francisco reported that it 

expanded its internship program to support more interns and 

leveraged partnerships with organizations representing minorities and 

women to increase the diversity of the bank’s internship program 

applicant pool.

In response to section 342 of the Dodd-Frank Act, seven federal financial 

agencies have taken preliminary steps to respond to the requirement to 

develop standards for assessing the diversity policies and practices of 

entities they oversee. While these agencies have made initial progress, it 

is too soon to evaluate how effectively the agencies are responding to this 

requirement. The affected agencies include CFPB, FDIC, FHFA, the 

Federal Reserve Board, NCUA, OCC, and SEC.36 In addition to this 

requirement under the Dodd-Frank Act, FHFA is also subject to the 

Housing and Economic Recovery Act of 2008 (HERA), under which it 

must assess its regulated entities’ diversity activities and meet other 

provisions similar to those in section 342.37

 

36Although this report reviews eight federal agencies, this requirement does not apply to 

Treasury Departmental Offices, as the agency does not have regulated entities. 

Additionally, the requirement does not directly apply to the Reserve Banks. However, the 

Federal Reserve Board has delegated some of its supervisory responsibilities to the 

Reserve Banks—such as responsibility for examining bank and thrift holding companies 

and state member banks under rules, regulations, and policies established by the Federal 

Reserve Board. The scope of these delegated authorities does not include section 342 

oversight of regulated entities at this time.

37Pub. L. No. 110-289 § 1116, 122 Stat. 2654, 2681-2683 (2008). Under HERA, FHFA’s 

regulated entities must establish an OMWI and develop and implement standards and 

procedures to ensure, to the maximum extent possible, the inclusion and utilization of 

minorities and women, and minority- and women-owned businesses in all business and 

activities of the regulated entity at all levels, including in procurement, insurance, and all 

types of contracts. Additionally, each of its regulated entities must report annually to FHFA 

on actions taken pursuant to these requirements. Further, the act requires FHFA to take 

affirmative steps to seek diversity in its workforce at all levels, consistent with the 

demographic diversity of the United States.

Agencies Have Taken 

Preliminary Steps to 

Develop Procedures to 

Assess Diversity Policies 

and Practices of Regulated 

Entities 
 

Page 44 GAO-13-238 Financial Services Industry

In 2010, FHFA developed an agency regulation implementing HERA 

requirements, in part, to ensure that diversity is a component of all 

aspects of its regulated entities’ business activities. The agency’s 

regulated entities include Fannie Mae, Freddie Mac, Federal Home Loan 

Banks, and the Federal Home Loan Bank System’s Office of Finance. 

HERA requires the agency’s regulated entities to develop diversity 

policies and procedures, staff an OMWI, and report annually to FHFA on 

their OMWI activities, among other requirements.38

According to OMWI officials, other agencies reviewed FHFA’s regulation 

as a possible option for responding to the section 342 requirement; 

however, the enforcement authority included in FHFA’s regulation is 

unique to the agency. They said that under the Dodd-Frank Act their 

agencies do not have enforcement authority to require regulated entities 

to implement diversity standards and practices.

In addition, FHFA has 

enforcement authority under HERA and FHFA’s promulgated regulation 

to ensure its regulated entities have diversity standards in place. 

According to FHFA OMWI officials, the agency’s response to HERA also 

satisfies the section 342 requirement.

39

The agency OMWI directors began meeting periodically in 2011 and 

began in 2012 to explore the possibility of developing a uniform set of 

standards that agencies could use as a baseline for developing standards 

for assessing the diversity practices of their regulated entities. Agency 

OMWI officials said the working group aimed to develop a set of 

standards for review and feedback from industry participants. As part of 

these efforts, some OMWI directors of the affected agencies participated 

in meetings with members of Congress to explore issues involving 

collection and analysis of workforce diversity data. Some members of the 

working group also held meetings with industry and advocacy groups to 

Officials from the 

affected agencies also told us their OMWIs collaborated on initial steps to 

determine how to respond to these requirements by meeting periodically 

as a group, meeting with members of Congress, and performing outreach 

to industry participants and advocacy groups.

 

38Minority and Women Inclusion. 12 C.F.R. § 1207.1 -24 (Dec. 28, 2010).

39Pub. L. No. 111-203. § 342(b)(4) (2010). Even though section 342 provides for the 

development of standards for the assessment of diversity policies and practices of 

regulated entities, it further provides that nothing in the requirement may be construed to 

require any specific action based on the findings of the assessment.
 

Page 45 GAO-13-238 Financial Services Industry

understand industry views on developing standards for assessing 

diversity policies and practices. One OMWI reported that industry 

representatives discussed options for evaluating diversity with respect to 

a regulated entity’s size, complexity, and market area.

OMWI officials told us responding to the requirement was a challenge for 

several reasons. Specifically, differences across regulated entities in 

terms of size, complexity, and market area made it challenging to develop 

a uniform standard. Determining the process and format for developing 

standards was also a challenge. OMWI officials also said they want to 

minimize adding a new regulatory burden to meet this provision. 

Therefore, the agencies would like to leverage existing information 

sources—data that regulated entities already provide—in evaluating the 

diversity activities of regulated entities. For example, to find ways to avoid 

duplicating existing data-collection efforts, CFPB and NCUA were working 

with EEOC for access to EEO-1 data for regulated entities. OCC officials 

said OCC had also considered using EEO-1 data, but some regulated 

entities had concerns about maintaining proprietary information, given the 

potential for Freedom of Information Act requests.

40

In addition to establishing an OMWI, the act required federal financial 

agencies and Reserve Banks to report annually on their diversity 

practices, and nearly all of the agencies and all the Reserve Banks have 

begun reporting annually on their diversity practices. As discussed earlier, 

the act required each OMWI to submit to Congress an annual report on 

the actions taken pursuant to section 342, including information on the 

percentage of amounts paid to minority-and women-owned contractors 

and successes and challenges in recruiting and hiring qualified minority 

and women employees, and other information as the OMWI director 

determines appropriate. Including more information on the outcomes and 

progress of their diversity practices could enhance the usefulness of 

these annual reports. Seven of eight agencies and all Reserve Banks 

issued annual reports in 2011. CFPB, which was created in July 2010 and 

assumed responsibility for certain consumer financial protection functions 

in July 2011, issued an agencywide semiannual report for 2011. Its OMWI 

 

40 5 U.S.C. § 552. The Freedom of Information Act requires that federal agencies provide 

the public with access to government records and information on the basis of the 

principles of openness and accountability in government.

Efforts to Report on 

Measuring Outcomes and 

Progress Could Be 

Enhanced 
 

Page 46 GAO-13-238 Financial Services Industry

planned to issue an annual report for 2012 at the same time as the other 

agencies, in March 2013.

In their 2011 Annual OMWI Reports to Congress, several agencies and 

Reserve Banks reported on efforts to measure outcomes and progress of 

various diversity practices, which provide examples of the types of 

outcomes and measures of progress that could be helpful for OMWIs to 

include in their annual reports. Although the act requires information on 

successes and challenges, it does not specifically require reporting on 

effectiveness; however, the act provides some leeway to the federal 

financial agencies and the Reserve Banks to include “any other 

information, findings, conclusions, and recommendations for legislative or 

agency action, as the Director determines appropriate.”41 Measurement of 

diversity practices is one of the nine leading diversity management 

practices we previously identified. We have reported that quantitative 

measures—such as tracking employment demographic statistics—and 

qualitative measures—such as evaluating employee feedback survey 

results—could help organizations translate their diversity aspirations into 

tangible practice.42

The Federal Reserve Board reported that it tracks job applicant 

information to assess the diversity of applicant pools, candidates 

interviewed, and employees hired as a result of diversity recruiting efforts, 

and FDIC reported that it monitors participation and attrition rates and 

diversity characteristics of participants in a development program. SEC 

reported plans to develop standards for assessing its ongoing diversity 

and inclusion efforts and include them in a strategic plan. The Reserve 

Banks of Chicago, Philadelphia, Richmond, and San Francisco reported 

on the number of internships each bank supported and the ethnic and 

gender diversity of the interns. The Reserve Bank of Chicago also 

reported on the number of job offers extended and candidates hired from 

its internship program, as well as on the number of candidates 

successfully hired from a diversity career expo. Further, the Reserve 

Bank of Cleveland identified reporting tools developed to monitor the 

bank’s inclusion in contracting efforts. In addition to using these 

measures, some OMWI officials said they used annual employee surveys 

as a measurement tool to gather information about the progress of their 

 

 

41Pub. L. No. 111-203, § 342(e)(5) (2010). 

42GAO-05-90. 
 

Page 47 GAO-13-238 Financial Services Industry

diversity practices, including retention practices. For example, FDIC’s 

annual employee survey includes specific questions related to diversity, 

and the agency uses responses to assess the effectiveness of policies 

and programs and outline action steps for improvement. OCC officials 

told us the government-wide federal employee viewpoint survey provided 

information on employee perspectives about diversity, and the agency 

measured its results against government-wide scores. Further, OMWI 

officials from the Reserve Bank of Minneapolis said exit surveys and 

employee declination surveys provided additional information for 

evaluating their retention and recruiting programs.

Federal financial agencies and Reserve Banks have focused their initial 

OMWI efforts on implementing section 342 of the Dodd-Frank Act. While 

many OMWIs have implemented or are planning efforts to measure and 

evaluate the progress of their diversity and inclusion activities, which is 

consistent with the leading diversity management practices, information 

on such efforts is not yet reported consistently across the OMWI annual 

reports. According to OMWI officials as well as industry representatives 

we interviewed, measuring the progress of diversity recruitment and 

retention practices is a challenging, long-term process. For example, 

NCUA officials told us measuring the progress of certain recruiting 

practices could be a challenge, as access to demographic information 

about job applicants might be limited. Additionally, FHFA officials told us 

that while measuring the progress of diversity practices was needed to 

identify best practices, such measurement needs to be efficient and 

meaningful. However, without knowledge of OMWI efforts to measure 

outcomes and the progress of their diversity practices, Congress lacks 

information that would help hold OMWIs accountable for achieving 

desired outcomes. In addition, increased attention to evaluation and 

measurement through annual reporting of these efforts could help the 

OMWIs improve management of their diversity practices. Reporting such 

information would provide an opportunity for the agencies and Reserve 

Banks to learn from others’ efforts to measure their progress and indicate 

areas for improvement.
 

Page 48 GAO-13-238 Financial Services Industry

Section 342 of the Dodd-Frank Act requires federal financial agencies 

and Reserve Banks to develop procedures to ensure, to the maximum 

extent possible, the fair inclusion and utilization of women and minorities 

in contracting. Specifically, the act requires agency and Reserve Bank 

actions to ensure that its contractors are making efforts to include women 

and minorities in their workforce. Also, the act has requirements for 

actions to increase contracting opportunities for minority- and womenowned businesses (MWOB).43 Most agencies and Reserve Banks have 

developed and included a provision in contracts for services requiring 

their contractors to make efforts to ensure the fair inclusion of women and 

minorities in their workforce and subcontracted workforces. The extent to 

which these agencies and Reserve Banks have contracted with MWOBs 

varied widely. These entities reported multiple challenges to increasing 

contracting opportunities for MWOBs and used various technical 

assistance practices to address these challenges.

To address the act’s requirement to ensure the fair inclusion of women 

and minorities, to the maximum extent possible, in contracted workforces, 

agencies either have developed or are in the process of developing fair 

inclusion provisions in their contracts for services, and all Reserve Banks 

have done so. In addition, some agencies and all Reserve Banks have 

developed procedures to assess contractors’ efforts for workforce 

inclusion of women and minorities.

Five agencies—FDIC, FHFA, NCUA, OCC, and the Federal Reserve 

Board—and all Reserve Banks have created a fair inclusion provision and 

are using it in contracts for services. Section 342 of the Dodd-Frank Act 

requires agencies and Reserve Banks to develop procedures for review 

and evaluation of contract proposals for services and for hiring service 

providers that include a written statement that the contractor, and as 

applicable subcontractors, shall ensure, to the maximum extent possible, 

the fair inclusion of women and minorities in the workforce of the 

contractor and, as applicable, subcontractors. The act does not specify 

 

43For purposes of the act, minority-owned business means a business for which more than 

50 percent of the ownership is held by one or more minority individuals and more than 50 

percent of net profit and loss of the business accrues to one or more minority individuals. 

Women-owned business means a business for which more than 50 percent of the 

ownership is held by one or more women, more than 50 percent of the net profit or loss of 

the business accrues to one or more women, and a significant percentage of senior 

management positions are held by women. 

Procedures to Meet 

Dodd-Frank Inclusive 

Contracting 

Requirements Are 

Largely in Place

Most Agencies and 

Reserve Banks Are 

Implementing 

Requirements Related to 

Inclusiveness in 

Contractor Workforces

Fair Inclusion Provision in 

Contracts
 

Page 49 GAO-13-238 Financial Services Industry

the elements to be included in the written statement and provides that 

each OMWI director prescribe the form and content of the statement.

CFPB, SEC, and Treasury are each in the process of developing a fair 

inclusion provision. CFPB is developing procurement procedures to 

address the requirements of the act and required more time because its 

OMWI office was established in January 2012. SEC is subject to the 

Federal Acquisition Regulation (FAR) and is currently developing its 

inclusive contract provision.44

The fair inclusion provisions we reviewed contained the following:

While CFPB and SEC develop inclusion 

statements pursuant to the act, both agencies have been using the equal 

employment opportunity statement contained in the FAR in executed 

contracts. Treasury has developed its fair inclusion provision to add to 

future contracts. It has issued a notice of proposed rulemaking in the 

Federal Register for public comments on this change to its contracting 

procedures as required under the law. The comment period ended on 

October 22, 2012. Treasury received eight comments which included, 

among other things, suggestions to make the fair inclusion provision 

applicable to all contracts regardless of the dollar amount of the contract 

and to better specify the documentation required of contractors to 

demonstrate that they have met the requirements of the fair inclusion 

provision. Treasury is currently reviewing the public comments and 

considering changes to the proposed rule.

• Equal employment opportunity statement: Fair inclusion provisions 

include a commitment by the contractor to equal opportunity in 

employment and contracting and, to the maximum extent possible 

consistent with applicable law, the fair inclusion of women and 

minorities in the contractor’s workforce.

 

44The FAR is the primary regulation for use by all federal executive agencies in their 

acquisition of supplies and services with appropriated funds. Two federal financial 

agencies subject to the contracting provisions in section 342 of Dodd-Frank are also 

governed by the FAR because they receive appropriated funds: SEC and Treasury. The 

other agencies included in this report are not legally required to follow the FAR because 

they do not receive appropriated funds. However, according to CFPB, FDIC, FHFA, and 

OCC these agencies choose to adhere to part or all of this regulation. According to NCUA, 

it used the FAR as guidance when establishing its contracting procedures. The Federal 

Reserve Board described their procurement policy as consistent with the FAR.
 

Page 50 GAO-13-238 Financial Services Industry

• Documentation: To enforce the fair inclusion provision, agencies 

require contractors to provide documentation of their efforts to include 

women and minorities in the contractor’s workforce, such as a written 

affirmative action plan; documentation of the number of employees by 

race, ethnicity, and gender; information on subcontract awards, 

including whether the subcontractor is an MWOB; and any other 

actions describing the contractor’s efforts toward the inclusion of 

women and minorities.

• Contract amount threshold: Agencies apply the fair inclusion provision 

to contracts exceeding a certain dollar amount. For two agencies 

subject to the act, this threshold is any amount over $150,000. For 

three agencies subject to the act, this threshold is any amount over 

$100,000. The Reserve Bank fair inclusion provisions we reviewed did 

not generally include a dollar-amount threshold.

None of the officials from five agencies that have implemented a fair 

inclusion provision required by the act described to us receiving an 

adverse reaction from contractors, but officials from a majority of the 

Reserve Banks we spoke with described resistance or concerns from 

some contractors. OCC stated that smaller businesses had expressed 

confusion about the requirement because the businesses are too small to 

report workforce demographics to EEOC. Eight Reserve Banks described 

contractors expressing some disagreement or concern at the inclusion of 

the language in contracts. According to some Reserve Bank officials, 

contractors were concerned that accepting the fair inclusion provision 

would trigger other federal requirements for their businesses, or subject 

the contractor to meeting hiring or subcontracting targets.45

 

45As previously discussed, the Reserve Banks are not federal agencies. 

Some 

Reserve Banks described explaining the limited scope of the provision to 

concerned contractors. Other Reserve Banks described modifying the 

language in the fair inclusion provision, for example, in one case, 

changing a phrase regarding the contractor’s efforts to include women 

and minorities from “to the maximum extent possible” to read “to the 

maximum extent required by law.” Other Reserve Banks described 

occurrences where, in response to a contractor’s concern, they excluded 

the fair inclusion language from contracts for a procurement with a small 

dollar amount or because the vendor provided a service critical to the 
 

Page 51 GAO-13-238 Financial Services Industry

Reserve Bank and alternate vendors were not available.46

Some agencies and all Reserve Banks have developed procedures to 

assess contractors’ efforts toward workforce inclusion of women and 

minorities. Section 342 of the Dodd-Frank Act requires the 8 federal 

financial agencies in the act and 12 Reserve Banks to develop 

procedures to determine whether a contractor and, as applicable, a 

subcontractor, has failed to make a good faith effort to include minorities 

and women in their workforces. Good faith efforts include any actions 

intended to identify and remove barriers to employment or to expand 

employment opportunities for minorities and women in the workplace, 

according to the policies some agencies have developed. For example, 

recruiting minorities and women or providing these groups job training 

may be considered good faith efforts for diversity inclusion. Contractors 

must certify that they have made a good faith effort to include women and 

minorities in their workforces, according to most policies we reviewed. At 

the same time, contractors may provide documentation of their inclusion 

efforts such as workforce demographics, subcontract recipients, and the 

contractor’s plan to ensure that women and minorities have opportunities 

to enter and advance within its workforce. Agencies and Reserve Banks 

plan to conduct a review of each contractor’s certifications and 

documentation annually, once in a 2-year period, or at other times 

deemed necessary, such as when contracts are executed or renewed, to 

make a determination of whether the contractor made a good faith effort 

to include women and minorities in its workforce. Failure to make a good 

faith effort may result in termination of the contract, referral to the Office 

of Federal Contract Compliance Programs, or other appropriate action.

Finally, one

Reserve Bank described declining a contract and seeking an alternate 

vendor that accepted the provision.

47

 

46According to one Reserve Bank, there are certain types of contracts from which the fair 

inclusion provision would be automatically excluded. For example, the Reserve Bank of 

Chicago would not include the provision in a new contract with a vendor that has an 

existing contract with the National Procurement Office of the Federal Reserve System 

because in that previous contract the vendor had already agreed to make efforts to 

include women and minorities in its workforce. 

Four agencies and all Reserve Banks have established good faith effort 

47The Office of Federal Contract Compliance Programs enforces, for the benefit of job 

seekers and wage earners, the contractual promise of affirmative action and equal 

employment opportunity required of those who do business with the federal government.

Procedures to Assess 

Contractors’ Inclusion Efforts
 

Page 52 GAO-13-238 Financial Services Industry

determination procedures, and four agencies have yet to implement such 

procedures.

In 2011, the proportion of a federal financial agency’s contracting dollars 

awarded to businesses owned by minorities or women varied, ranging 

between 12 percent and 38 percent according to the OMWI reports of the 

agencies (see fig. 14).48

Figure 14: Dollar Amount and Percentage of Total Awarded to Minority- and Women-Owned Businesses (MWOB) by Agency, 

2011

Seven federal financial agencies awarded a total 

of about $2.4 billion for contracting for external goods and services in 

fiscal year 2011, with FDIC awarding about $1.4 billion of this amount.

 

48The act does not set a standard that the federal agencies or Reserve Banks must meet 

in making contracting awards to MWOBs. 

Levels of Contracting with 

Minority- and WomenOwned Businesses Varied 

by Agency and Reserve 

Bank 
 

Page 53 GAO-13-238 Financial Services Industry

Note: CFPB was not required to issue an OMWI report to Congress in 2011. Percentages of dollar 

amounts awarded to minority-owned businesses and women-owned businesses displayed separately 

may not be mutually exclusive for all agencies and do not always total to the combined percent to 

minority- and women-owned business category. Some businesses are both minority- and womenowned and may be counted by agencies under both categories.

Similarly, according to Reserve Bank OMWI reports, Reserve Bank 

contracting dollars paid to businesses owned by minorities or women 

ranged between 3 percent and 24 percent in 2011 (see fig. 15). Reserve 

Banks paid about $897 million in fiscal year 2011 in contracting.

Figure 15: Dollar Amount and Percentage of Total Paid to Minority- and Women-Owned Businesses (MWOB) by Reserve 

Bank, 2011

Note: Reserve Banks reported amounts paid to contractors in OMWI reports rather than amounts 

awarded as reported by agencies.

Among federal financial agencies, OCC awarded the largest proportional 

amount of contracting dollars to MWOBs—about 38 percent (almost $67 

million). OCC officials told us that its contract needs tend to be for 
 

Page 54 GAO-13-238 Financial Services Industry

services for which there is often a pool of MWOB suppliers and most of 

OCC’s 2011 contract dollars were spent on computer related services. 

The Federal Reserve Board awarded the smallest proportion of its 

contracting dollars to MWOBs, with about 12 percent going to such 

businesses. According to the Federal Reserve Board, a significant 

amount of its procurement is for economic data, which are generally not 

available from MWOBs. Although federal agencies are not generally 

required to report on MWOBs, most are required to report on certain 

small business contracting goals, including goals for women and small 

disadvantaged businesses (which include minority-owned businesses).49

In a 2012 report, we found that 35 percent of funds all federal agencies 

obligated to small businesses in 2011 were obligated to minority-owned 

small businesses and 17 percent were obligated to women-owned 

businesses.50

Among Reserve Banks, the Reserve Bank of Minneapolis paid the largest 

proportion of its contracting dollars to MWOBs with about 24 percent 

going to such businesses (18.5 percent to minority-owned businesses 

and about 5 percent to women-owned businesses). According to the 

Reserve Bank of Minneapolis, almost half of its MWOB contract dollars 

were paid for software and related technology integration services from 

minority-owned firms. All other Reserve Banks paid under 13 percent of 

contracting dollars to MWOBs, with the Reserve Bank of New York 

awarding the smallest percentage of its contracting dollars to such 

businesses (3 percent). The Reserve Bank of New York described its 

commitment to increasing diversity in its pool of potential contractors 

through its outreach efforts to us and in its 2011 OMWI report. For 

example, the Reserve Bank of New York held an event with its primary 

 

49The Small Business Administration (SBA) negotiates goals with federal agencies for 

contract dollars awarded to small businesses to meet statutory government-wide goals. 15 

U.S.C. § 664(g) sets forth a statutory goal for 23 percent of all aggregated federal 

contracting dollars to be awarded to small businesses. These include current goals for 5 

percent of all prime contract and subcontract dollars to be awarded to small 

disadvantaged businesses and 5 percent of all prime contract and subcontract dollars to 

be awarded to women-owned small businesses. SBA also negotiates goals for the award 

of contract dollars to service-disabled veteran-owned and HUBZone small businesses.

50See GAO, Government Contracts: Federal Efforts to Assist Small Minority Owned 

Businesses, GAO-12-873 (Washington, D.C.: Sept. 28, 2012). We analyzed data from the 

Federal Procurement Data System—Next Generation. Minority designations are selfreported, and some businesses are both minority- and women-owned and may be 

counted under both categories.
 

Page 55 GAO-13-238 Financial Services Industry

contractors and small firms to identify potential partnerships and an event 

that provided small firms consultation on business plans and credit 

applications to increase the capacity of the small firms.

Seven federal financial agencies included in this report and all 12 

Reserve Banks identified challenges in increasing contracting 

opportunities for MWOBs. Section 342 of the Dodd-Frank Act requires 

federal financial agencies and Reserve Banks to include in their annual 

OMWI report a description of the challenges they may face in contracting 

with qualified MWOBs. As a new agency, CFPB has not been required to 

complete an annual OMWI report and did not identify any contracting 

challenges to us. In interviews with us and in the 2011 OMWI reports to 

Congress, the remaining agencies and all Reserve Banks discussed a 

number of common challenges to increasing contracting with MWOBs, 

including the following:

• Limited capacity of MWOBs: Some agencies and Reserve Banks 

stated that reporting or other requirements under federal contracts 

were often too great a burden for MWOBs or that MWOBs needed to 

build capacity to meet federal contracting requirements. Some 

agencies and Reserve Banks also stated that at times the need for 

goods or services is not scaled to the capacity of MWOBs. For 

example, some agencies and Reserve Banks faced challenges 

identifying MWOBs that can meet procurement needs on a national 

scale.

• Developing staff or procedures to meet contracting requirements of 

the act: According to some agencies, new OMWIs require additional 

staff or staff development, or procedures to meet the requirements of 

the act, including providing technical assistance to increase 

opportunities for MWOBs, identifying qualified MWOBs in the 

marketplace, and incorporating the use of a fair inclusion provision in 

contracts and good faith effort determination processes, which we 

discussed earlier, into established procurement processes. 

• MWOB classification challenges: Multiple agencies and Reserve 

Banks described difficulty identifying and classifying suppliers as 

diverse entities. Some Reserve Banks noted that no central agency is 

responsible for certifying MWOBs. Some agencies and Reserve 

Banks also discussed a need for new procedures or information 

systems to identify and classify diverse ownership of businesses.

Agencies and Reserve 

Banks Report Challenges 

to Increasing Contracting 

Opportunities and Have 

Offered Technical 

Assistance to Minority- and 

Women-Owned Businesses
 

Page 56 GAO-13-238 Financial Services Industry

• Availability: Some agencies and Reserve Banks noted that 

specialized services are often only available from a limited pool of 

suppliers that may not include MWOBs.

• Centralized procurement: Reserve Banks may use the National 

Procurement Office (NPO), the centralized procurement office for the 

12 Reserve Banks, to contract for some goods and services.51

• No MWOB bids: In some cases, agencies and Reserve Banks found 

that potentially eligible MWOB applicants decided not to bid without 

explanation.

When 

a Reserve Bank procures through the NPO, access to MWOBs may 

be limited because the NPO procures for volume discounts with larger 

contractors. However, the Reserve Bank of Richmond, in its 2011 

OMWI report, described efforts to work with existing large contractors 

to increase subcontracting with smaller, diverse firms.

Other challenges were described on a limited basis by one agency or 

Reserve Bank. For example, NCUA explained that MWOBs are not 

familiar with the agency. According to NCUA, to address this issue it 

increased its outreach budget and attendance to MWOB events and 

published an online guide on doing business with the agency. According 

to FDIC, in some cases MWOBs do not have relationships with large 

federal contractors for subcontracting opportunities. To address this 

problem, FDIC emphasizes to larger firms the importance of 

subcontracting with MWOBs and has negotiated increases in MWOB 

subcontracting participation with large contractors. FDIC participated in 

procurement events where small and large contractors could meet and 

match capabilities. The Reserve Bank of Chicago stated that MWOBs 

have a hard time standing out in highly competitive industries, such as 

staff augmentation services. Finally, according to the Reserve Bank of 

Richmond, MWOBs may have incorrect perceptions that Reserve Banks 

are subject to federal procurement rules that they cannot meet.

To counter challenges MWOBs may face in accessing federal contracting 

opportunities, all agencies and Reserve Banks described providing 

various specific forms of technical assistance to MWOBs, which they 

described in discussions with us and in 2011 OMWI reports to Congress. 

 

51The NPO, housed in the Reserve Bank of Richmond, conducts research and negotiates, 

manages, and administers contracts on behalf of the 12 Reserve Banks, but the 

purchases are made by the individual Reserve Bank that chooses to use the contract.
 

Page 57 GAO-13-238 Financial Services Industry

No agency or Reserve Bank stood out as coordinating technical 

assistance better than others, although some agencies pointed to 

longstanding efforts at FDIC to provide technical assistance to MWOBs 

as model practices. Section 342 of the Dodd-Frank Act requires federal 

financial agencies and Reserve Banks to develop standards for 

coordinating technical assistance to MWOBs. These activities included 

developing and distributing literature, such as manuals and brochures 

describing contracting procedures and resources to prospective 

contractors. Most agencies also established websites that function as 

informational portals on doing business with agencies and act as an 

agency entry point to prospective contractors. Agencies and Reserve 

Banks described outreach activities to MWOBs, including conducting 

expert panels, hosting meetings and workshops, and exhibiting at trade 

shows and procurement events. Some of these outreach activities have 

been coordinated with SBA. For example, FDIC has partnered with SBA 

to develop a technical assistance program for small businesses, including 

MWOBs, on money management. OCC worked with SBA to create a 

technical assistance workshop that they conducted in 2012 with womenowned small businesses. Some agencies have included SBA 

representatives in supplier diversity events they sponsor. Even prior to 

the passage of the Dodd-Frank Act, the Federal Reserve Board had 

participated in SBA procurement fairs and used SBA information and 

events to market its procurement opportunities among diverse suppliers. 

Treasury has participated in SBA outreach events and created a mentorprotégé program to assist small businesses with contracting 

opportunities.52

Agencies and Reserve Banks also provide one-on-one technical 

assistance, which is intended to meet the specific needs of a prospective 

MWOB contractor. According to Treasury, they coordinate with SBA to 

leverage SBA’s knowledge of one-on-one technical assistance practices 

 

52A mentor-protégé program is an arrangement in which mentors—businesses, typically 

experienced prime contractors—provide technical, managerial, and other business 

development assistance to eligible small businesses, or protégés. Overall, mentor-protégé 

programs seek to enhance the ability of small businesses to compete more successfully 

for federal government contracts by furnishing them with assistance to improve their 

performance. See GAO, Mentor-Protégé Programs Have Policies that Aim to Benefit 

Participants but Do Not Require Postagreement Tracking, GAO-11-548R (Washington, 

D.C.: June 15, 2011) and Small Business Contracting: Opportunities to Improve the 

Effectiveness of Agency and SBA Advocates and Mentor-Protégé Programs, 

GAO-11-844T (Washington, D.C.: Sept. 15, 2011).
 

Page 58 GAO-13-238 Financial Services Industry

with MWOBs. FHFA and SEC have created dedicated e-mail addresses

and telephone lines for MWOBs to reach their OMWIs, and SEC has 

established monthly vendor outreach days when MWOBs can speak oneon-one with SEC’s supplier diversity officer and small-business specialist. 

Some Reserve Banks described conducting one-on-one meetings with 

prospective contractors in 2011, some of which were held during 

procurement events. Finally, FDIC offered its database of MWOBs to the 

OMWIs and some agencies described using or planning to use it to 

identify potential contractors for outreach regarding procurement 

opportunities. According to FDIC, it sends an updated version of the 

database to the agencies each quarter.

Across financial services firms, federal financial agencies, and Reserve 

Banks, available data showed the representation of minorities and women 

varied, and there was little overall change in workforce diversity from 

2007 through 2011. Our findings suggest the overall diversity of the 

financial services industry has generally remained steady following the 

financial crisis. Since 2011, federal financial agencies and Reserve Banks 

have taken initial steps to respond to the Dodd-Frank Act’s requirements 

to promote workforce diversity, and OMWIs have begun reporting on both 

planned and existing diversity practices, in addition to reporting on 

workforce demographic statistics according to EEOC requirements. While 

many OMWIs have implemented or are planning efforts to measure and 

evaluate the progress of their diversity and inclusion activities, a leading 

diversity management practice, information on these efforts is not 

reported consistently across the OMWI annual reports. Although the act 

requires information on successes and challenges, it does not specifically 

require reporting on measurement; however, the act provides that the 

federal financial agencies and the Reserve Banks can include additional 

information determined appropriate by the OMWI director. Measurement 

of diversity practices is one of the nine leading diversity management 

practices we have previously identified. Reporting on these efforts as part 

of annual OMWI reporting would provide Congress, other OMWIs, and 

the financial services industry with potentially useful information on the 

ongoing implementation of diversity practices. Such information could be 

helpful industrywide, as management-level diversity at federal financial 

agencies, Reserve Banks, and the broader financial services industry 

continues to be largely unchanged. Without information on OMWI efforts 

to report outcomes and the progress of diversity and inclusion practices, 

Congress lacks information that would help hold agencies accountable for 

achieving desired outcomes or whether OMWI efforts are having any 

impact.

Conclusion 
 

Page 59 GAO-13-238 Financial Services Industry

To enhance the availability of information on the progress and impact of 

agency and Reserve Bank diversity practices, we are recommending to 

CFPB, FDIC, the Federal Reserve Board, FHFA, NCUA, OCC, SEC, 

Treasury, and the Reserve Banks that each OMWI report on efforts to 

measure the progress of its employment diversity and inclusion practices, 

including measurement outcomes as appropriate, to indicate areas for 

improvement as part of their annual reports to Congress.

We provided drafts of this report to CFPB, the Federal Reserve Board, 

FDIC, FHFA, NCUA, OCC, SEC, Treasury, and each of the Federal 

Reserve Banks for review and comment. We received written comments 

from each of the agencies and a consolidated letter from all of the

Reserve Banks. Their comment letters are reproduced in appendixes V 

through XIII. The agencies and Reserve Banks generally agreed with our 

recommendation. CFPB, Federal Reserve Banks, FDIC, FHFA, NCUA, 

OCC, and SEC provided technical comments, which we incorporated as 

appropriate. We also provided a draft of the report to EEOC for comment. 

EEOC is not subject to the requirements of section 342 of the act but did 

provide technical comments, which we incorporated as appropriate. 

With respect to our recommendation that each OMWI report on efforts to 

measure the progress of its employment diversity and inclusion practices, 

including measurement outcomes as appropriate, to indicate areas for 

improvement as part of their annual reports to Congress, all the federal 

financial agencies and Reserve Banks indicated that they plan to 

implement the recommendation:

• the OMWI Director of CFPB explained that its OMWI was the newest 

of such offices because the agency was created with the enactment of 

the Dodd-Frank Act and that it planned to include measurement 

information in future reports; 

• the OMWI Director of the Federal Reserve Board stated that the 

recommendation was consistent with its ongoing practices and that it 

would look for additional ways to report on diversity practices;

• FDIC’s OMWI Director agreed with the recommendation and stated 

that it will include efforts to measure the progress of its diversity 

practices in its annual reports to Congress; 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 60 GAO-13-238 Financial Services Industry

• the Acting Associate Director of FHFA’s OMWI stated that it would 

include measurement information in its 2013 OMWI report to 

Congress;

• the Executive Director of NCUA said the agency will work toward 

reporting on its efforts to measure the progress of workforce diversity 

and practices; 

• the Comptroller of the Currency stated that OCC had a welldeveloped diversity and inclusion program through which the agency 

measures its progress and that OCC has included additional metrics 

in its 2013 OMWI report to Congress; 

• SEC’s OMWI Director noted that the agency plans to incorporate 

measurement information on its diversity and inclusion practices in its 

future OMWI reports to Congress; 

• Treasury’s OMWI Director agreed with our recommendation and 

stated that it was consistent with the agency’s efforts to use more than 

demographic representation to measure the progress of diversity and 

inclusion efforts; and 

• the Federal Reserve Banks’ OMWI directors noted that the banks 

currently include some measurement information in annual reports 

and said that they will consider additional ways to measure and report 

on Reserve Banks’ diversity practices.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of this report until 30 

days from the report date. At that time, we will send copies of this report 

to the appropriate congressional committees; the Chairman, Board of 

Governors of the Federal Reserve; Director, Bureau of Consumer 

Financial Protection, commonly known as the Consumer Financial 

Protection Bureau; Chair, Equal Employment Opportunity Commission; 

Chairman, Federal Deposit Insurance Corporation; Acting Director, 

Federal Housing Finance Agency; Chairman, National Credit Union 

Association; Comptroller, Office of the Comptroller of the Currency; 

Chairman, Securities and Exchange Commission; Secretary, Department 

of the Treasury; and to the Directors of the Offices of Minority and 

Women’s Inclusion for the Federal Reserve Banks; and other interested 

parties. We will make copies available to others upon request. The report 

will also be available at no charge on our website at http://www.gao.gov. 
 

Page 61 GAO-13-238 Financial Services Industry

If you or your staffs have any questions about this report, please contact 

me at (202) 512-8678 or garciadiazd@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs are listed on the last 

page of this report. GAO staff who made major contributions to this report 

are listed in appendix XIV. 

Sincerely yours,

Daniel Garcia-Diaz

Director, Financial Markets and Community Investment
Appendix I: Objectives, Scope, and 

Methodology

Page 62 GAO-13-238 Financial Services Industry

The objectives for this report were to examine (1) what available data 

show about how the diversity of the financial services industry workforce

and how diversity practices taken by the industry have changed from 

2007 through 2011; (2) what available data show about how diversity in 

the workforces of the federal financial agencies and the Federal Reserve 

Banks (Reserve Banks) has changed from 2007 through 2011; (3) how 

these federal financial agencies and Reserve Banks are implementing 

workforce diversity practices under section 342 of the Dodd-Frank Act, 

including the extent to which their workforce diversity practices have 

changed since the financial crisis; and (4) the status of federal financial 

agencies’ and Reserve Banks’ implementation of the contracting 

provisions of the Dodd-Frank Act related to the inclusion of women and 

minorities.

To describe how diversity in the financial services industry has changed 

since the beginning of the 2007-2009 financial crisis, we analyzed 2007-

2011 workforce data from the Equal Employment Opportunity 

Commission’s (EEOC) Employer Information Report (EEO-1). EEO-1 is 

data annually submitted to EEOC generally by private-sector firms with 

more than 100 employees.1 We obtained EEO-1 data on October 2012, 

from the finance and insurance industry categorized under the North 

American Industry Classification System (NAICS) code 52 for these 

industries from 2007 through 2011. EEO-1 data were specifically obtained 

from the EEOC’s “officials and managers” category by gender, 

race/ethnicity, firm size, and industry sectors.2

 

1

Federal contractors with 50 or more employees are also required to submit to EEOC 

annual reports showing the composition of their workforce; however, we did not include 

these firms in our analysis. Accordingly, our EEO-1 analysis presented in this report may 

not match the EEO-1 data presented on EEOC’s website. As required under the Civil 

Rights Act of 1964, EEOC collects periodic reports from public and private employers and 

unions and labor organizations that indicate the composition of their work forces by sex 

and by racial/ethnic category. Key among these reports is the EEO-1.

The EEO-1 “officials and 

managers” category was further divided into two management-level 

categories of first- and mid-level managers and senior-level managers 

2

EEOC defines the job category of “officials and managers” as occupations requiring 

administrative and managerial personnel, who set broad policies, exercise overall 

responsibility for execution of these policies, and direct individual departments or special 

phases of a firm’s operation.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 63 GAO-13-238 Financial Services Industry

and then analyzed by gender, race/ethnicity, and firm size.3

To corroborate the results of the EEO-1 data, we used an additional 

source of workforce diversity data from the Current Population Survey 

(CPS), a monthly survey of households the Bureau of the Census 

administers on behalf of the Bureau of Labor Statistics. CPS data provide 

information on labor force characteristics and demographic data, among 

other topics. Similar to the EEO-1 “officials and managers” job category, 

we used the CPS “management occupations” category—unlike EEO-1, 

CPS does not split its management into two levels—for our discussion of 

management-level diversity within the financial services industry. 

However, the statistics from these two sources are not exactly 

comparable. We determined the CPS-estimated percentages of minorities 

in management positions within the financial services industry could not 

be precisely measured.

To 

understand the potential internal candidate pools available for 

management positions in the financial industry, we obtained EEO-1 data 

under NAICS code 52 for all positions, including nonmanagement 

positions, by gender and race/ethnicity. To determine the reliability of the 

EEO-1 data that we received from EEOC, we interviewed knowledgeable 

EEOC officials and reviewed relevant documents provided by agency 

officials and obtained on its website. We also conducted electronic testing 

of the data. We determined that the EEO-1 data were sufficiently reliable 

for our purposes.

4

 

3

In 2007, EEOC subdivided the “officials and managers’ category into two subcategories. 

The first one, “Executive/Senior Level Officials and Managers,” includes individuals who 

reside in the highest levels of organizations and plan, direct, and formulate policies, set 

strategy, and provide the overall direction of enterprises/organizations for the development 

and delivery of products or services, within the parameters approved by boards of 

directors or other governing bodies. The second category, “First/Mid-Level Officials and 

Managers,” includes individuals who receive directions from Executive/Senior Level 

management and oversee and direct the delivery of products, services, or functions at 

group, regional, or divisional levels of organizations. 

See table 6 for the estimated percentages and 

standard errors. The standard errors for the minority percentages were 

greater than the standard errors for the white percentages, and they were 

relatively large compared to the estimated percentage for minorities. 

However, CPS minority percentages were included in this report for 

additional context. To determine the reliability of CPS data, which we 

4

We used monthly averages over 3 months—July, August, and September—from the 

Basic Monthly CPS for each year and then calculated the estimated percentages, as 

EEOC’s EEO-1 reports are collected over this period of time every year.
Appendix I: Objectives, Scope, and 

Methodology

Page 64 GAO-13-238 Financial Services Industry

obtained from a publicly accessible federal statistical database, we 

gathered and reviewed relevant documentation from the Bureau of the 

Census website, conducted electronic testing, and determined the 

standard errors of the CPS estimates. We determined that the CPS data 

were sufficiently reliable for our purposes.

Table 6: Estimated Percentages and Standard Errors for Race/Ethnicity in 

Management Positions in the Financial Services Industry Using the Current 

Population Survey (CPS), 2007-2011

Year Race/ethnicity Percentage Standard errors

2007 White 85.9% 1.7%

2007 Minority 14.1 4.5

2008 White 85.9 1.7

2008 Minority 14.1 4.5

2009 White 83.1 1.9

2009 Minority 16.9 4.5

2010 White 86.0 1.8

2010 Minority 14.0 4.7

2011 White 84.9 1.8

2011 Minority 15.1 4.6

Source: GAO analysis of CPS data.

To gather information on a potential external pipeline of diverse 

candidates for management positions in the financial industry, we 

obtained demographic data on minority and female students enrolled in 

undergraduate, Master of Business Administration (MBA), and doctoral 

degree programs from 2007 through 2011 from the Association to 

Advance Collegiate Schools of Business (AACSB). We focused on MBA 

programs as a source of potential future managers and senior executives. 

Financial services firms compete for minorities in this pool with one 

another and with firms from other industries. We combined this 

information with undergraduate and doctoral degree programs to provide 

information on the overall diversity of the university system. AACSB 

conducts an annual voluntary survey called “Business School 

Questionnaire” of all its member schools. In 2011, AACSB updated its 

survey to include two additional race/ethnicity categories to include “two 

or more races” and “Native Hawaiian or Other Pacific Islander.” For 

consistency purposes, we combined these two additional categories 

along with the representation of Native Americans into an “other” 

category. To determine the reliability of the AACSB data, we interviewed 

a knowledgeable AACSB official and reviewed relevant documents 
Appendix I: Objectives, Scope, and 

Methodology

Page 65 GAO-13-238 Financial Services Industry

provided by the official and obtained on its website. We determined that 

the data from AACSB were sufficiently reliable for our purposes.

To determine how diversity practices in the financial services industry 

have changed since the beginning of the financial crisis, we conducted a 

literature review of relevant studies that discussed diversity best practices 

within the financial services industry from 2007 through 2011. In addition, 

we interviewed 10 selected industry representatives to determine whether 

the nine leading diversity practices we previously identified are relevant 

today and how diversity practices changed since 2007. We also reviewed 

documents produced by these industry representatives. These 

representatives were selected based on their participation in our previous 

work, suggestions from federal agencies we interviewed for this report, as 

well as the type of industry representative—such as an industry 

association or private firm.5

To describe diversity in the workforces of the federal financial agencies 

and Reserve Banks, we analyzed data we received from agencies and 

banks. To review changes in the representation of minorities and women 

in the workforces of federal financial agencies, we obtained from the 

agencies annual Equal Employment Opportunity Program Status Reports 

from 2007 through 2011, required under U.S. EEOC Management 

Directive 715 and known as MD-715 reports.6

 

5

In our 2006 report we selected industry representatives based on a variety of criteria 

including whether they had received public recognition of their diversity programs or on 

the type of sector (such as securities or commercial banking) they were involved in. 

We obtained data from 

seven of the eight federal agencies required to meet the workforce 

diversity provisions in section 342 of the Dodd-Frank Wall Street Reform 

and Consumer Protection Act (Dodd-Frank Act). These included the 

Departmental Offices of the Department of the Treasury, the Federal 

Deposit Insurance Corporation, the Federal Housing Finance Agency 

(FHFA), the Board of Governors of the Federal Reserve System, the 

National Credit Union Administration, the Office of the Comptroller of the 

Currency, and the Securities and Exchange Commission. The Bureau of 

GAO-06-617. 

6

EEOC collects a variety of data on workforce diversity from federal agencies, including 

information pursuant to a management directive it issued in 2003 that included policy 

guidelines and standards for establishing and maintaining affirmative employment 

programs. This directive does not apply to the Federal Reserve Banks, as they are not 

federal agencies. EEOC MD-715 (2003).
Appendix I: Objectives, Scope, and 

Methodology

Page 66 GAO-13-238 Financial Services Industry

Consumer Financial Protection, commonly known as the Consumer 

Financial Protection Bureau (CFPB), was created in July 2010 and 

assumed responsibility for certain consumer financial protection functions 

in 2011; workforce diversity data for the agency to show trends from 2007 

through 2011 were unavailable.7 Additionally, our trend analysis excluded 

FHFA, as the agency was created in 2008 and did not report on diversity 

employment statistics for 2007, 2008, or 2009. Further, our senior 

management-level trend analysis excluded SEC, as the agency revised 

how it reported officials and managers during the 5-year period. To review 

changes in the representation of minorities and women in the workforces 

of Reserve Banks, we obtained from banks their annual EEO-1 reports 

from 2007 through 2011.8 For agencies and Reserve Banks, we reviewed 

workplace employment data by occupational categories, distributed by 

race/ethnicity and gender.9

 

7

On July 21, 2010, the Consumer Financial Protection Act established CFPB as an 

independent bureau within the Federal Reserve System to be headed by a director. 

Effective July 21, 2011, CFPB assumed responsibility for certain consumer financial 

protection functions formerly the responsibilities of the Board of Governors of the Federal 

Reserve System, the Comptroller of the Currency, the Director of the Office of Thrift 

Supervision, FDIC, the Federal Trade Commission, NCUA, and the Secretary of the 

Department of Housing and Urban Development.

In our analyses, we considered all categories 

other than white as race/ethnic minorities and analyzed trends in diversity 

8

We obtained annual EEO-1 reports from all 12 Reserve Banks, which are located in 

Atlanta, Boston, Chicago, Cleveland, Dallas, Kansas City, Minneapolis, New York, 

Philadelphia, Richmond, San Francisco, and St. Louis.

9

These data are organized in table A3 of each MD-715 report and as part of the 

consolidated employer information reports for Reserve Bank EEO-1 data. For both data 

sets, race and ethnicity categories included Hispanic or Latino, White, Black or African 

American, Asian American, Native Hawaiian or Other Pacific Islander, American Indian or 

Alaskan Native, and Two or More Races. Our analysis included as an Other category: 

Native Hawaiian or Other Pacific Islander, American Indian or Alaskan Native, and Two or 

More Races. 
Appendix I: Objectives, Scope, and 

Methodology

Page 67 GAO-13-238 Financial Services Industry

at both the senior management-level and agency- and bankwide.10

To assess the reliability of MD-715 and EEO-1 data we received from 

agencies and Reserve Banks, we interviewed EEOC officials on both 

types of data as well as agency officials on MD-715 data and Reserve 

Bank officials on EEO-1 data about how the data are collected and 

verified as well as to identify potential data limitations. We found that 

while agencies and banks rely on employees to provide their race and 

ethnicity information, agencies and banks had measures in place to verify 

and correct missing or erroneous data prior to reporting them and officials 

with whom we spoke generally agreed these data were generally 

accurate. Based on our analysis, we concluded that the MD-715 and 

EEO-1 data were sufficiently reliable for our purposes.

We 

analyzed senior management-level and overall diversity trends across all 

agencies and all Reserve Banks, as well as diversity trends for each 

agency when trend information was available.

To assess how federal financial agencies and Reserve Banks are 

implementing workforce diversity practices under section 342 of the 

Dodd-Frank Act, we reviewed agency and bank documentation of efforts 

to respond to the act’s requirements. Sources included annual Office of 

Minority and Women Inclusion (OMWI) reports to Congress by agencies 

and banks, annual agency MD-715 reports, and other documentation 

provided to us by agency and bank OMWI officials. Additionally, we 

gathered testimonial information from agency and Reserve Bank OMWI 

officials on changes in the inclusion of women and minorities in their 

workforces and any changes in the practices used to further workforce 

diversity goals. Through our review of agency and Reserve Bank 

documentation and interviews with OMWI officials, we assessed agency 

 

10We defined senior management-level as employees reported in the most senior job 

category by federal financial agencies and Reserve Banks. For agency MD-715 data, we 

considered senior management-level as officials and managers reported as 

“Executive/Senior Level,” in each agency’s A3 data tables. For Reserve Bank EEO-1 data, 

we considered senior management-level as “Executive/Senior Officials and Managers,” 

reported by each Reserve Bank. Our analysis of agencywide data included all job 

categories reported by each agency: Executive/Senior Level, Mid-level, First-level, and 

Other Officials and Managers, Professionals, Technicians, Sales Workers, Administrative 

Support Workers, Craft Workers, Operatives, Laborers and Helpers, and Service Workers. 

Our analysis of bankwide data included all job categories reported by each Reserve Bank: 

Executive/Senior Officials and Managers, First/Mid Officials and Managers, Professionals, 

Technicians, Sales Workers, Administrative Support Workers, Craft Workers, Operatives, 

Laborers and Helpers, and Service Workers.
Appendix I: Objectives, Scope, and 

Methodology

Page 68 GAO-13-238 Financial Services Industry

and Reserve Bank efforts to measure and report on the progress of their 

diversity practices, as measurement was one of the nine leading diversity 

practices we previously identified.

To determine the extent to which agencies and Reserve Banks are 

implementing the requirements of the Dodd-Frank Act regarding the 

inclusion of women and minorities in contracting, we reviewed 2011 

OMWI reports submitted to Congress and interviewed officials on their 

efforts in this area. We also reviewed OMWI reports to determine the 

dollar amount and percentage of total contracts federal financial agencies 

reported awarding to minority- and women-owned businesses (MWOB), 

and the dollar amount and percentage of total contracts Reserve Banks 

reporting paying MWOBs in 2011. We verified these figures and our 

presentation of the information with each agency and Reserve Bank, and 

we determined that these data were sufficiently reliable for our purposes. 

We interviewed agency officials on their efforts to coordinate with the 

Small Business Administration and other federal agencies to provide 

technical assistance to minority- and women-owned businesses. We 

collected and reviewed agency documentation of procedures developed 

to address the act’s requirements, such as policy manuals, process 

workflows, and technical assistance materials. We also collected and 

reviewed examples of fair inclusion provisions used in agency and 

Reserve Bank contracts as required in section 342 of the Dodd-Frank Act.

We conducted this performance audit from January 2012 to March 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Additional Analysis of the 

Financial Services Industry

Page 69 GAO-13-238 Financial Services Industry

This appendix provides additional detailed analysis of EEOC data on the 

financial services industry by workforce position and industry sector from 

2007 through 2011.

The representation of minorities by gender was below 45 percent across 

all the positions throughout the same 5-year period (see fig. 16). For 

example, in sales positions, the representation of minorities was higher 

among women (about 31 percent) than among men (about 17 percent). 

Similarly, at the professional level, the representation of minority women 

was about 27 percent, compared to about 23 percent for minority men.

Appendix II: Additional Analysis of the 

Financial Services Industry

Analysis by Workforce 

Positions 
Appendix II: Additional Analysis of the 

Financial Services Industry

Page 70 GAO-13-238 Financial Services Industry

Figure 16: Percentage of Minority Women and Minority Men in Various Industry Workforce Positions in the Financial Services 

Industry, 2007-2011

Note: The category “other” includes craft workers, operatives, laborers, and service workers.
Appendix II: Additional Analysis of the 

Financial Services Industry

Page 71 GAO-13-238 Financial Services Industry

Diversity remained about the same across all industry sectors in terms of 

both the representation of women and minorities.1

 

1

These industry sectors under the financial services industry are split according to the 

NAICS. 

From 2007 through 

2011, the representation of women decreased slightly in most industry 

sectors and remained below 50 percent in all sectors (see fig. 17). The 

“insurance carriers and related activities” sector was the only sector that 

showed an increase in the representation of women, from 47.7 percent to 

48.2 percent. In contrast, the representation of minorities increased 

across all sectors. Specifically, from 2007 through 2011 the 

representation of minorities in the “monetary authorities-central bank” 

sector increased from 17 percent to 19.8 percent, and the “funds, trusts, 

and other financial vehicle” sector increased from 16 percent to 18.5 

percent.

Analysis by Industry 

Sectors 
Appendix II: Additional Analysis of the 

Financial Services Industry

Page 72 GAO-13-238 Financial Services Industry

Figure 17: Percentage of Whites/Minorities and Men/Women in Various Sectors of the Financial Services Industry, 2007-2011

Note: Industry sector numbers are defined as follows: Sector 521, Monetary Authorities-Central Bank; 

Sector 522, Credit Intermediation and Related Activities; Sector 523, Securities, Commodity 

Contracts, and Other Financial Investments and Related Activities; Sector 524, Insurance Carriers 

and Related Activities; Sector 525, Funds, Trusts, and Other Financial Vehicles.
Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks

Page 73 GAO-13-238 Financial Services Industry

This appendix provides information accompanying our review of changes 

in overall workforce diversity at federal financial agencies and the 12 

Reserve Banks from 2007 through 2011.1

According to MD-715 data, the representation of minorities in the overall 

workforce of the agencies, in aggregate, changed little from 2007 through 

2011. Percentage point changes in the representation of minorities at 

FDIC, the Federal Reserve Board, NCUA, OCC, SEC, and Treasury 

varied from a 5 percentage point decrease at Treasury to a 3 percentage 

point increase at NCUA. In 2011, the representation of minorities in the 

overall workforce of the agencies and FHFA ranged from 25 percent at 

NCUA to 44 percent at the Federal Reserve Board.

Tables 11 through 14 in 

appendix IV provide data supporting the figures in this appendix.

 

1

The agencies included FDIC, the Federal Reserve Board, NCUA, OCC, SEC, and 

Treasury. FHFA was established in 2008 and started reporting workforce data for 2010, 

and is excluded from our trend analysis. Additionally, CFPB was established in July 2011 

and trend data were not available.

Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks 
Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks

Page 74 GAO-13-238 Financial Services Industry

Figure 18: Percentage of Minorities among All Employees at Seven Federal Financial Agencies, 2007-2011

Note: Figures are rounded to the nearest percent.

For our analysis, we reviewed the numbers of employees the agencies reported according to 

race/ethnicity and gender in table A3 of their MD-715 reports from 2007 through 2011. These data 

are based on information self-reported by employees to each agency and there were some 

differences in reporting across the agencies. In some years, some agencies reported all employees—

permanent and temporary—in their A3 tables while others reported permanent employees only. 
Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks

Page 75 GAO-13-238 Financial Services Industry

a

Our trend analysis for “all agencies” excludes CFPB and FHFA. CFPB assumed responsibility for 

certain consumer financial protection functions in July 2011 and has not yet reported workforce 

information to EEOC. FHFA was established in 2008 and started reporting workforce data for 2010. 

Similarly, we found that the representation of women in the overall 

workforce of the agencies did not change significantly from 2007 through 

2011. Percentage point changes in the representation of women at the

agencies from 2007 through 2011 varied from a 2 percentage point 

decrease at FDIC, the Federal Reserve Board, and Treasury to no 

percentage point change at NCUA and SEC. In 2011, the representation 

of minorities in the overall workforce of the agencies and FHFA ranged 

from 42 percent at FDIC to 48 percent at SEC and Treasury.
Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks

Page 76 GAO-13-238 Financial Services Industry

Figure 19: Percentage of Women among All Employees at Seven Federal Financial Agencies, 2007-2011

Note: Figures are rounded to the nearest percent.
Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks

Page 77 GAO-13-238 Financial Services Industry

For our analysis, we reviewed the numbers of employees the agencies reported according to 

race/ethnicity and gender in table A3 of their MD-715 reports from 2007 through 2011. These data 

are based on information self-reported by employees to each agency and there were some 

differences in reporting across the agencies. In some years, some agencies reported all employees—

permanent and temporary—in their A3 tables while others reported permanent employees only. 

a

Our trend analysis for “all agencies” excludes CFPB and FHFA. CFPB assumed responsibility for 

certain consumer financial protection functions in July 2011 and has not yet reported workforce 

information to EEOC. FHFA was established in 2008 and started reporting workforce data for 2010. 

According to EEO-1 data provided by the Reserve Banks, the 

representation of minorities in the overall workforce of the Reserve Banks 

decreased somewhat from 2007 through 2011. The banks showed 

changes in the representation of minorities from 2007 through 2011, from 

an 8 percentage point decrease at the Reserve Bank of Philadelphia, to a 

2 percentage point increase at the Reserve Banks of Minneapolis and 

New York. The Reserve Bank of Boston showed no percentage point 

change from 2007 through 2011. In 2011, the representation of minorities 

in the overall workforce of the Reserve Banks ranged from 16 percent at 

the Reserve Bank of Kansas City to 53 percent at the Reserve Bank of 

San Francisco.
Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks

Page 78 GAO-13-238 Financial Services Industry

Figure 20: Percentage of Minorities among All Employees at the 12 Reserve Banks, 2007-2011

Note: Figures are rounded to the nearest percent.
Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks

Page 79 GAO-13-238 Financial Services Industry

In addition, we found that from 2007 through 2011, the representation of 

women in the overall workforce of the Reserve Banks also declined 

slightly according to EEO-1 data provided by the Reserve Banks. The 

Reserve Banks showed decreases in the representation of women in the 

overall workforce from 1 percentage point at the Reserve Bank of New 

York to 7 percentage points at the Reserve Bank of Cleveland. The 

representation of women in the overall workforce in 2011 ranged from 40 

percent at the Reserve Banks of Philadelphia and Richmond to 53 

percent at the Reserve Bank of Minneapolis.
Appendix III: Additional Analysis of Overall 

Workforce Diversity at Agencies and Reserve 

Banks

Page 80 GAO-13-238 Financial Services Industry

Figure 21: Percentage of Women among All Employees at the 12 Reserve Banks, 2007-2011

Note: Figures are rounded to the nearest percent.
Appendix IV: Representation of Minorities and 

Women at Federal Financial Agencies and 

Reserve Banks

Page 81 GAO-13-238 Financial Services Industry

We reviewed agency and Reserve Bank reports and found that since the 

financial crisis, senior management-level minority and gender diversity at 

the agencies and Reserve Banks has varied across individual entities.

We also found the representation of minorities and women in the overall 

workforce of the agencies changed little from 2007 through 2011, while 

the representation of minorities and women in the overall workforce of the 

Reserve Banks declined slightly. The following tables provide data 

supporting the senior management-level and total workforce figures in 

this report.

Appendix IV: Representation of Minorities 

and Women at Federal Financial Agencies 

and Reserve Banks
Appendix IV: Representation of Minorities and Women at Federal Financial Agencies 

and Reserve Banks

Page 82 GAO-13-238 Financial Services Industry

Table 7: Percentage of Minorities among Senior Management-Level Employees at Seven Federal Financial Agencies, 2007-2011

Senior management-level federal financial agency employees (number and percent)

Race/ethnicity Year FDIC Federal Reserve FHFAa NCUA OCC SECb Treasury

All 2011 301 100% 343 100% 51 100% 134 100% 251 100% 125 100% 312 100%

2010 284 100 307 100 29 100 109 100 204 100 - - 279 100

2009 258 100 301 100 - - 101 100 201 100 - - 276 100

2008 234 100 289 100 - - 123 100 252 100 - - 219 100

2007 203 100 253 100 - - 118 100 229 100 - - 175 100

White 2011 250 83 277 81 39 76 118 88 207 82 111 89 259 83

2010 237 83 246 80 21 72 95 87 164 80 - - 238 85

2009 218 84 247 82 - - 90 89 164 82 - - 236 86

2008 199 85 237 82 - - 108 88 207 82 - - 188 86

2007 171 84 207 82 - - 104 88 190 83 - - 150 86

Total minority 2011 51 17 66 19 12 24 16 12 44 18 14 11 53 17

2010 47 17 61 20 8 28 14 13 40 20 - - 41 15

2009 40 16 54 18 - - 11 11 37 18 - - 40 14

2008 35 15 52 18 - - 15 12 45 18 - - 31 14

2007 32 16 46 18 - - 14 12 39 17 - - 25 14

Black or African 

American 

2011 31 10 35 10 8 16 5 4 23 9 3 2 29 9 

2010 27 10 33 11 7 24 5 5 23 11 - - 21 8 

2009 24 9 31 10 - - 4 4 23 11 - - 22 8 

2008 24 10 29 10 - - 7 6 29 12 - - 19 9 

2007 23 11 27 11 - - 7 6 29 13 - - 17 10

Hispanic 2011 9 3 7 2 4 8 6 4 12 5 6 5 12 4 

2010 9 3 7 2 1 3 5 5 10 5 - - 11 4 
Appendix IV: Representation of Minorities and Women at Federal Financial Agencies 

and Reserve Banks

Page 83 GAO-13-238 Financial Services Industry

Senior management-level federal financial agency employees (number and percent)

Race/ethnicity Year FDIC Federal Reserve FHFAa NCUA OCC SECb Treasury

2009 7 3 5 2 - - 5 5 6 3 - - 12 4 

2008 5 2 4 1 - - 5 4 9 4 - - 8 4 

2007 4 2 3 1 - - 4 3 6 3 - - 5 3 

Asian 2011 9 3 20 6 0 0 3 2 9 4 3 2 10 3 

2010 9 3 17 6 0 0 2 2 6 3 - - 8 3 

2009 7 3 13 4 - - 1 1 7 3 - - 6 2 

2008 5 2 14 5 - - 2 2 5 2 - - 4 2 

2007 1 0 11 4 - - 2 2 2 1 - - 3 2 

Other 2011 2 1 4 1 0 0 2 1 0 0 2 2 2 1 

2010 2 1 4 1 0 0 2 2 1 0 - - 1 0 

2009 2 1 5 2 - - 1 1 1 0 - - 0 0 

2008 1 0 5 2 - - 1 1 2 1 - - 0 0 

2007 4 2 5 2 - - 1 1 2 1 - - 0 0 

Source: GAO analysis of agency reports.

Notes: Percentages are rounded to the nearest percent.

For our analysis, we reviewed the numbers of employees the agencies reported according to race/ethnicity and gender in table A3 of their MD715 reports from 2007 through 2011. These data are based on information self-reported by employees to each agency and there were some 

differences in reporting across the agencies. In some years, some agencies reported all employees—permanent and temporary—in their A3 

tables while others reported permanent employees only. We considered employees reported by agencies in the category “Executive/Senior 

Level” as senior management-level employees. Though the MD-715 report guidelines instruct agencies to identify employees Grades 15 and 

above who have supervisory responsibility in this category, agencies have discretion to include employees who have significant policymaking 

responsibilities but do not supervise employees. As a result, the composition of the “Executive/Senior Level” category may vary among the 

different agencies and does not necessarily involve the same set of managers at each agency.

a

FHFA was established in 2008 and started reporting workforce data for 2010. 

b

SEC revised how it reported officials and managers between 2007 and 2011. While our analysis includes 2011 management-level data for 

SEC, we excluded previous years from our trend analysis.
Appendix IV: Representation of Minorities and Women at Federal Financial Agencies 

and Reserve Banks

Page 84 GAO-13-238 Financial Services Industry

Table 8: Percentage of Minorities among Senior Management-Level Employees at the 12 Reserve Banks, 2007-2011

Senior management-level Reserve Bank employees (number and percent)

Race/

ethnicity Year Atlanta Boston Chicago Cleveland Dallas

Kansas 

City Minneapolis

New 

York Philadelphia Richmond

San 

Francisco St. Louis

All 2011 13 100% 13 100% 9 100% 13 100% 9 100% 12 100% 9 100% 59 100% 11 100% 22 100% 13 100% 11 100%

2010 86 100 11 100 9 100 12 100 10 100 14 100 8 100 74 100 10 100 23 100 23 100 9 100

2009 82 100 12 100 11 100 12 100 10 100 12 100 8 100 71 100 13 100 20 100 26 100 37 100

2008 80 100 12 100 11 100 13 100 10 100 11 100 9 100 65 100 12 100 19 100 26 100 34 100

2007 75 100 12 100 11 100 12 100 10 100 12 100 7 100 55 100 11 100 19 100 26 100 30 100

White 2011 10 77 11 85 8 89 13 100 8 89 11 92 5 56 52 88 10 91 19 86 10 77 10 91

2010 72 84 11 100 8 89 12 100 9 90 13 93 5 63 66 89 9 90 20 87 20 87 9 100

2009 68 83 12 100 10 91 12 100 9 90 12 100 7 88 62 87 11 85 19 95 23 88 33 89

2008 66 83 12 100 10 91 13 100 9 90 11 100 8 89 55 85 10 83 17 89 23 88 31 91

2007 62 83 12 100 10 91 12 100 9 90 12 100 6 86 46 84 10 91 18 95 24 92 29 97

Total 

minority

2011 3 23 2 15 1 11 0 0 1 11 1 8 4 44 7 12 1 9 3 14 3 23 1 9 

2010 14 16 0 0 1 11 0 0 1 10 1 7 3 38 8 11 1 10 3 13 3 13 0 0 

2009 14 17 0 0 1 9 0 0 1 10 0 0 1 13 9 13 2 15 1 5 3 12 4 11

2008 14 18 0 0 1 9 0 0 1 10 0 0 1 11 10 15 2 17 2 11 3 12 3 9 

2007 13 17 0 0 1 9 0 0 1 10 0 0 1 14 9 16 1 9 1 5 2 8 1 3 

Black or 

African 

American

2011 2 15 2 15 1 11 0 0 1 11 0 0 2 22 4 7 0 0 1 5 1 8 1 9 

2010 11 13 0 0 1 11 0 0 1 10 0 0 1 13 3 4 1 10 1 4 2 9 0 0 

2009 11 13 0 0 1 9 0 0 1 10 0 0 1 13 4 6 1 8 0 0 2 8 2 5 

2008 10 13 0 0 1 9 0 0 1 10 0 0 1 11 4 6 1 8 1 5 2 8 2 6 

2007 9 12 0 0 1 9 0 0 1 10 0 0 1 14 4 7 1 9 1 5 2 8 1 3 

Hispanic 2011 0 0 0 0 0 0 0 0 0 0 1 8 0 0 1 2 0 0 2 9 1 8 0 0 
Appendix IV: Representation of Minorities and Women at Federal Financial Agencies 

and Reserve Banks

Page 85 GAO-13-238 Financial Services Industry

Senior management-level Reserve Bank employees (number and percent)

Race/

ethnicity Year Atlanta Boston Chicago Cleveland Dallas

Kansas 

City Minneapolis

New 

York Philadelphia Richmond

San 

Francisco St. Louis

2010 3 3 0 0 0 0 0 0 0 0 1 7 0 0 2 3 0 0 2 9 0 0 0 0 

2009 3 4 0 0 0 0 0 0 0 0 0 0 0 0 2 3 0 0 1 5 0 0 1 3 

2008 4 5 0 0 0 0 0 0 0 0 0 0 0 0 3 5 0 0 1 5 0 0 1 3 

2007 4 5 0 0 0 0 0 0 0 0 0 0 0 0 3 5 0 0 0 0 0 0 0 0 

Asian 2011 0 0 0 0 0 0 0 0 0 0 0 0 1 11 2 3 1 9 0 0 1 8 0 0 

2010 0 0 0 0 0 0 0 0 0 0 0 0 1 13 3 4 0 0 0 0 1 4 0 0 

2009 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 4 1 8 0 0 1 4 1 3 

2008 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 5 1 8 0 0 1 4 0 0 

2007 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 4 0 0 0 0 0 0 0 0 

Other 2011 1 8 0 0 0 0 0 0 0 0 0 0 1 11 0 0 0 0 0 0 0 0 0 0 

2010 0 0 0 0 0 0 0 0 0 0 0 0 1 13 0 0 0 0 0 0 0 0 0 0 

2009 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

2008 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

2007 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

Source: GAO analysis of EEO-1 reports provided by Reserve Banks. 

Notes: Percentages are rounded to the nearest percent.

For our analysis of the representation of minorities and women at the senior management level for Reserve Banks, we reviewed the numbers of 

employees the banks reported as “Executive/Senior Level Officials and Managers” from 2007 through 2011. While EEOC provides instructions 

on reporting job categories based on the skill levels, knowledge, and responsibilities involved in occupations identified within each job category, 

employers have discretion to decide which positions they report as Executive/Senior Level Officials and Managers versus those at lower levels 

of management. Therefore, comparisons of a given management level between the Reserve Banks do not necessarily involve the same set of 

managers at each bank. For example, the Reserve Bank of Atlanta revised how it reported officials and managers for 2011. From 2007 through 

2010, the bank reported all officers as Executive/Senior Level Officials and Managers, and for 2011, the bank reported as Executive/Senior 

Level Officials and Managers those employees that have strategic roles and/or report to the Reserve Bank’s President. According to Reserve 

Bank officials, recent efforts have been made to align reporting of officials and managers across the Federal Reserve System.
Appendix IV: Representation of Minorities and 

Women at Federal Financial Agencies and 

Reserve Banks

Page 86 GAO-13-238 Financial Services Industry

Table 9: Percentage of Women among Senior Management-Level Employees at Seven Federal Financial Agencies, 2007-2011

Senior management-level federal financial agency employees (number and percent)

Gender Year FDIC

Federal 

Reserve FHFAa NCUA OCC SECb Treasury

All 2011 301 100% 343 100% 51 100% 134 100% 251 100% 125 100% 312 100%

2010 284 100 307 100 29 100 109 100 204 100 - - 279 100

2009 257 100 301 100 - - 101 100 201 100 - - 176 100

2008 234 100 289 100 - - 123 100 252 100 - - 219 100

2007 203 100 253 100 - - 118 100 229 100 - - 175 100

Men 2011 209 69 201 59 27 53 87 65 171 68 85 68 192 62

2010 197 69 185 60 14 48 77 71 137 67 - - 178 64

2009 187 72 184 61 - - 72 71 130 65 - - 176 64

2008 165 71 180 62 - - 84 68 161 64 - - 143 65

2007 147 72 155 61 - - 82 69 145 63 - - 115 66

Women 2011 92 31 142 41 24 47 47 35 80 32 40 32 120 38

2010 87 31 122 40 15 52 32 29 67 33 - - 101 36

2009 71 28 117 39 - - 29 29 71 35 - - 100 36

2008 69 29 109 38 - - 39 32 91 36 - - 76 35

2007 56 28 98 39 - - 36 31 84 37 - - 60 34

Source: GAO analysis of agency reports.

Notes: Percentages are rounded to the nearest percent.

For our analysis, we reviewed the numbers of employees the agencies reported according to 

race/ethnicity and gender in table A3 of their MD-715 reports from 2007 through 2011. These data 

are based on information self-reported by employees to each agency and there were some 

differences in reporting across the agencies. In some years, some agencies reported all employees—

permanent and temporary—in their A3 tables while others reported permanent employees only. We 

considered employees reported by agencies in the category “Executive/Senior Level” as senior 

management-level employees. Though the MD-715 report guidelines instruct agencies to identify 

employees Grades 15 and above who have supervisory responsibility in this category, agencies have 

discretion to include employees who have significant policymaking responsibilities but do not 

supervise employees. As a result, the composition of the “Executive/Senior Level” category may vary 

among the different agencies and does not necessarily involve the same set of managers at each 

agency.

a

FHFA was established in 2008 and started reporting workforce data for 2010. 

b

SEC revised how it reported officials and managers between 2007 and 2011. While our analysis 

includes 2011 management-level data for SEC, we excluded previous years from our trend analysis.
Appendix IV: Representation of Minorities and Women at Federal Financial 

Agencies and Reserve Banks

Page 87 GAO-13-238 Financial Services Industry

Table 10: Percentage of Women among Senior Management-Level Employees at the 12 Reserve Banks, 2007-2011

Senior management-level federal financial agency employees (number and percent)

Race/

ethnicity Year Atlanta Boston Chicago Cleveland Dallas

Kansas 

City Minneapolis New York Philadelphia Richmond

San 

Francisco St. Louis

All 2011 13 100% 13 100% 9 100% 13 100% 9 100% 12 100% 9 100% 59 100% 11 100% 22 100% 13 100% 11 100%

2010 86 100 11 100 9 100 12 100 10 100 14 100 8 100 74 100 10 100 23 100 23 100 9 100

2009 82 100 12 100 11 100 12 100 10 100 12 100 8 100 71 100 13 100 20 100 26 100 37 100

2008 80 100 12 100 11 100 13 100 10 100 11 100 9 100 65 100 12 100 19 100 26 100 34 100

2007 75 100 12 100 11 100 12 100 10 100 12 100 7 100 55 100 11 100 19 100 26 100 30 100

Men 2011 7 54 11 85 5 56 9 69 6 67 5 42 6 67 34 58 6 55 15 68 9 69 7 64

2010 53 62 9 82 5 56 9 75 7 70 9 64 6 75 48 65 5 50 16 70 16 70 6 67

2009 49 60 9 75 6 55 8 67 7 70 8 67 6 75 46 65 9 69 13 65 17 65 26 70

2008 49 61 9 75 6 55 9 69 7 70 8 73 7 78 43 66 8 67 14 74 17 65 22 65

2007 48 64 9 75 6 55 8 67 7 70 8 67 6 86 39 71 7 64 15 79 17 65 20 67

Women 2011 6 46 2 15 4 44 4 31 3 33 7 58 3 33 25 42 5 45 7 32 4 31 4 36

2010 33 38 2 18 4 44 3 25 3 30 5 36 2 25 26 35 5 50 7 30 7 30 3 33

2009 33 40 3 25 5 45 4 33 3 30 4 33 2 25 25 35 4 31 7 35 9 35 11 30

2008 31 39 3 25 5 45 4 31 3 30 3 27 2 22 22 34 4 33 5 26 9 35 12 35

2007 27 36 3 25 5 45 4 33 3 30 4 33 1 14 16 29 4 36 4 21 9 35 10 33

Source: GAO analysis of EEO-1 reports provided by Reserve Banks.

Notes: Percentages are rounded to the nearest percent.

For our analysis of the representation of minorities and women at the senior management level for Reserve Banks, we reviewed the 

numbers of employees the banks reported as “Executive/Senior Level Officials and Managers” from 2007 through 2011. While EEOC 

provides instructions on reporting job categories based on the skill levels, knowledge, and responsibilities involved in occupations identified 

within each job category, employers have discretion to decide which positions they report as Executive/Senior Level Officials and Managers 

versus those at lower levels of management. Therefore, comparisons of a given management level between the Reserve Banks do not 

necessarily involve the same set of managers at each bank. For example, the Reserve Bank of Atlanta revised how it reported officials and 

managers for 2011. From 2007 through 2010, the bank reported all officers as Executive/Senior Level Officials and Managers, and for 2011, 
Appendix IV: Representation of Minorities and Women at Federal Financial 

Agencies and Reserve Banks 

Page 88 GAO-13-238 Financial Services Industry

the bank reported as Executive/Senior Level Officials and Managers those employees that have strategic roles and/or report to the Reserve 

Bank’s President. According to Reserve Bank officials, recent efforts have been made to align reporting of officials and managers across the 

Federal Reserve System.
Appendix IV: Representation of Minorities and Women at Federal Financial 

Agencies and Reserve Banks

Page 89 GAO-13-238 Financial Services Industry

Table 11: Percentage of Minorities among All Employees at Seven Federal Financial Agencies, 2007-2011

Federal financial agency employees (number and percent)

Race/ethnicity Year FDIC Federal Reserve FHFAa NCUA OCC SEC Treasury

All 2011 8,398 100% 2,274 100% 494 100% 1,159 100% 3,560 100% 3,812 100% 1,586 100%

2010 8,316 100 2,137 100 406 100 1,095 100 3,054 100 3,897 100 1,599 100

2009 6,530 100 2,143 100 - - 1,024 100 3,117 100 3,720 100 1,529 100

2008 5,028 100 2,028 100 - - 934 100 3,039 100 3,653 100 1,295 100

2007 4,428 100 1,945 100 - - 929 100 3,000 100 3,154 100 1,223 100

White 2011 6,152 73 1,276 56 335 38 871 75 2,503 70 2,616 69 1,087 69

2010 6,107 73 1,196 56 270 67 833 76 2,145 70 2,664 68 1,080 68

2009 4,800 74 1,187 55 - - 769 75 2,185 70 2,516 68 1,041 68

2008 3,655 73 1,115 55 - - 722 78 2,161 72 2,204 70 772 63

2007 3,261 74 1,066 55 - - 722 78 2,161 72 2,204 7 772 63

Total minority 2011 2,246 27 998 44 159 32 288 25 1,057 30 1,196 31 499 31

2010 2,209 27 941 44 136 33 262 24 909 30 1,233 32 519 32

2009 1,730 26 956 45 - - 255 25 932 30 1,204 32 488 32

2008 1,373 27 913 45 - - 216 23 887 29 1,168 32 464 36

2007 1,167 26 879 45 - - 207 22 839 28 950 30 451 37

Black or 

African 

American 

2011 1,385 16 591 26 95 19 157 14 577 16 632 17 356 22

2010 1,353 16 582 27 90 22 141 13 508 17 682 18 372 23

2009 1,109 17 612 29 - - 153 15 534 17 679 18 362 24

2008 944 19 604 30 - - 133 14 517 17 668 18 352 27

2007 799 18 589 30 - - 126 14 501 17 523 17 344 28

Hispanic 2011 359 4 94 4 17 3 48 4 201 6 182 5 46 3 

2010 364 4 81 4 12 3 47 4 181 6 133 3 49 3 
Appendix IV: Representation of Minorities and Women at Federal Financial 

Agencies and Reserve Banks

Page 90 GAO-13-238 Financial Services Industry

Federal financial agency employees (number and percent)

Race/ethnicity Year FDIC Federal Reserve FHFAa NCUA OCC SEC Treasury

2009 261 4 75 3 - - 43 4 181 6 144 4 54 4 

2008 198 4 70 3 - - 35 4 168 6 137 4 47 4 

2007 181 4 68 3 - - 34 4 157 5 129 4 50 4 

Asian 2011 374 4 271 12 46 9 56 5 212 6 354 9 80 5 

2010 372 4 238 11 33 8 52 5 169 6 352 9 79 5 

2009 283 4 231 11 - - 37 4 163 5 319 9 60 4 

2008 199 4 204 10 - - 36 4 158 5 312 9 53 4 

2007 25 1 187 10 - - 33 4 145 5 266 8 49 4 

Other 2011 128 2 42 2 1 0 27 2 67 2 28 1 17 1 

2010 120 1 40 2 1 0 22 2 51 2 66 2 19 1 

2009 77 1 38 2 - - 22 2 54 2 62 2 12 1 

2008 32 1 35 2 - - 12 1 44 1 51 1 12 1 

2007 162 4 35 2 - - 14 2 36 1 32 1 8 1 

Source: GAO analysis of agency reports.

Notes: Percentages are rounded to the nearest percent.

For our analysis, we reviewed the numbers of employees the agencies reported according to race/ethnicity and gender in table A3 of their 

MD-715 reports from 2007 through 2011. These data are based on information self-reported by employees to each agency and there were 

some differences in reporting across the agencies. In some years, some agencies reported all employees—permanent and temporary—in 

their A3 tables while others reported permanent employees only. 

a

FHFA was established in 2008 and started reporting workforce data for 2010.
Appendix IV: Representation of Minorities and Women at Federal Financial 

Agencies and Reserve Banks

Page 91 GAO-13-238 Financial Services Industry

Table 12: Percentage of Minorities among All Employees at the 12 Reserve Banks, 2007-2011

Reserve Bank employees (number and percent)

Race/

ethnicity Year Atlanta Boston Chicago Cleveland Dallas

Kansas

City Minneapolis

New 

York Philadelphia Richmond

San 

Francisco St. Louis

All 2011 1,594 100% 875 100% 1,431 100% 1,094 100% 1,098 100% 1,225 100% 1,011 100% 2,955 100% 839 100% 2,444 100% 1,495 100% 955 100%

2010 1,623 100 858 100 1,353 100 1,276 100 1,110 100 1,292 100 1,004 100 2,999 100 840 100 2,356 100 1,514 100 944 100

2009 1,728 100 868 100 1,379 100 1,340 100 1,168 100 1,220 100 1,051 100 2,940 100 914 100 2,421 100 1,632 100 932 100

2008 1,886 100 884 100 1,415 100 1,511 100 1,225 100 1,277 100 1,172 100 2,791 100 1,016 100 2,534 100 1,700 100 987 100

2007 2,017 100 978 100 1,532 100 1,568 100 1,269 100 1,357 100 1,278 100 2,860 100 1,092 100 2,733 100 1,779 100 1,089 100

White 2011 839 53 607 69 889 62 878 80 551 50 1,026 84 830 82 1,617 55 539 64 1,721 70 701 47 691 72

2010 839 52 607 71 845 62 1,017 80 555 50 1,082 84 830 83 1,626 54 534 64 1,672 71 703 46 679 72

2009 864 50 611 70 850 62 1,063 79 561 48 1,018 83 879 84 1,596 54 562 61 1,719 71 758 46 674 72

2008 899 48 614 69 866 61 1,168 77 572 47 1,050 82 980 84 1,522 55 581 57 1,753 69 768 45 694 70

2007 949 47 676 69 933 61 1,213 77 590 46 1,096 81 1,071 84 1,630 57 613 56 1,823 67 774 44 740 68

Total 

minority

2011 755 47 268 31 542 38 216 20 547 50 199 16 181 18 1,338 45 300 36 723 30 794 53 264 28

2010 784 48 251 29 508 38 259 20 555 50 210 16 174 17 1,373 46 306 36 684 29 811 54 265 28

2009 864 50 257 30 529 38 277 21 607 52 202 17 172 16 1,344 46 352 39 702 29 874 54 258 28

2008 987 52 270 31 549 39 343 23 653 53 227 18 192 16 1,269 45 435 43 781 31 932 55 293 30

2007 1068 53 302 31 599 39 355 23 679 54 261 19 207 16 1,230 43 479 44 910 33 1,005 56 349 32

Black or 

African 

American

2011 525 33 108 12 279 19 167 15 238 22 93 8 79 8 494 17 184 22 509 21 101 7 209 22

2010 557 34 106 12 275 20 208 16 229 21 107 8 81 8 523 17 198 24 503 21 116 8 215 23

2009 634 37 107 12 310 22 228 17 269 23 109 9 82 8 530 18 248 27 533 22 140 9 216 23

2008 758 40 117 13 334 24 290 19 326 27 120 9 102 9 539 19 330 32 603 24 160 9 254 26

2007 830 41 132 13 391 26 308 20 354 28 146 11 118 9 560 20 372 34 713 26 178 10 315 29

Hispanic 2011 147 9 45 5 132 9 12 1 235 21 57 5 24 2 301 10 31 4 65 3 179 12 19 2 
Appendix IV: Representation of Minorities and Women at Federal Financial 

Agencies and Reserve Banks

Page 92 GAO-13-238 Financial Services Industry

Reserve Bank employees (number and percent)

Race/

ethnicity Year Atlanta Boston Chicago Cleveland Dallas

Kansas

City Minneapolis

New 

York Philadelphia Richmond

San 

Francisco St. Louis

2010 148 9 41 5 114 8 13 1 247 22 59 5 21 2 301 10 28 3 58 2 177 12 19 2 

2009 152 9 44 5 112 8 13 1 260 22 51 4 20 2 290 10 28 3 56 2 205 13 15 2 

2008 148 8 47 5 102 7 16 1 265 22 62 5 20 2 278 10 28 3 59 2 224 13 15 2 

2007 153 8 52 5 96 6 14 1 266 21 67 5 20 2 280 10 29 3 63 2 251 14 9 1 

Asian 2011 69 4 112 13 119 8 29 3 67 6 41 3 71 7 523 18 80 10 129 5 490 33 33 3 

2010 68 4 104 12 109 8 31 2 73 7 40 3 66 7 532 18 75 9 103 4 493 33 29 3 

2009 68 4 105 12 95 7 29 2 70 6 38 3 64 6 508 17 73 8 96 4 502 31 25 3 

2008 72 4 106 12 101 7 28 2 54 4 41 3 65 6 439 16 75 7 103 4 516 30 22 2 

2007 78 4 117 12 104 7 26 2 53 4 43 3 64 5 389 14 75 7 113 4 547 31 23 2 

Other 2011 14 1 3 0 12 1 8 1 7 1 8 1 7 1 20 1 5 1 20 1 24 2 3 0 

2010 11 1 0 0 10 1 7 1 6 1 4 0 6 1 17 1 5 1 20 1 25 2 2 0 

2009 10 1 1 0 12 1 7 1 8 1 4 0 6 1 16 1 3 0 17 1 27 2 2 0 

2008 9 0 0 0 12 1 9 1 8 1 4 0 5 0 13 0 2 0 16 1 32 2 2 0 

2007 7 0 1 0 8 1 7 0 6 0 5 0 5 0 1 0 3 0 21 1 29 2 2 0 

Source: GAO analysis of EEO-1 reports provided by Reserve Banks.

Note: Percentages are rounded to the nearest percent.
Appendix IV: Representation of Minorities and Women at Federal Financial 

Agencies and Reserve Banks

Page 93 GAO-13-238 Financial Services Industry

Table 13: Percentage of Women among All Employees at Seven Federal Financial Agencies, 2007-2011

Federal financial agency employees (number and percent)

Gender Year FDIC

Federal 

Reserve FHFAa NCUA OCC SEC Treasury

All 2011 8,398 100% 2,274 100% 494 100% 1,159 100% 3,560 100% 3,812 100% 1,586 100%

2010 8,316 100 2,137 100 406 100 1,095 100 3,054 100 3,897 100 1,599 100

2009 6,530 100 2,143 100 - - 1,024 100 3,117 100 3,720 100 1,529 100

2008 5,028 100 2,028 100 - - 934 100 3,039 100 3,653 100 1,295 100

2007 4,428 100 1,945 100 - - 929 100 3,000 100 3,154 100 1,223 100

Men 2011 4,846 58 1,238 54 277 56 640 55 1,917 54 1,984 52 822 52

2010 4,852 58 1,138 53 219 54 589 54 1,587 52 2,024 52 827 52

2009 3,735 57 1,140 53 - - 555 54 1,617 52 1,924 52 798 52

2008 2,809 56 1,080 53 - - 515 55 1,584 52 1,882 52 657 51

2007 2,462 56 1,022 53 - - 509 55 1,583 53 1,655 52 613 50

Women 2011 3,552 42 1,036 46 217 44 519 45 1,643 46 1,828 48 764 48

2010 3,464 42 999 47 187 46 506 46 1,467 48 1,873 48 772 48

2009 2,795 43 1,003 47 - - 469 46 1,500 48 1,796 48 731 48

2008 2,219 44 948 47 - - 419 45 1,455 48 1,771 48 638 49

2007 1,966 44 923 47 - - 420 45 1,417 47 1,499 48 610 50

Source: GAO analysis of agency reports.

Note: Percentages are rounded to the nearest percent.

For our analysis, we reviewed the numbers of employees the agencies reported according to race/ethnicity and gender in table A3 of their 

MD-715 reports from 2007 through 2011. These data are based on information self-reported by employees to each agency and there were 

some differences in reporting across the agencies. In some years, some agencies reported all employees—permanent and temporary—in 

their A3 tables while others reported permanent employees only. 

a

FHFA was established in 2008 and started reporting workforce data for 2010.
Appendix IV: Representation of Minorities and Women at Federal Financial 

Agencies and Reserve Banks

Page 94 GAO-13-238 Financial Services Industry

Table 14: Percentage of Women among All Employees at the 12 Reserve Banks, 2007-2011

Reserve Bank employees (number and percent)

Race/

Ethnicity Year Atlanta Boston Chicago Cleveland Dallas Kansas City Minneapolis New York Philadelphia Richmond

San 

Francisco St. Louis

All 2011 1,594 100% 875 100% 1,431 100% 1,094 100% 1,098 100% 1,225 100% 1,011 100% 2,955 100% 869 100% 2,444 100% 1,495 100% 955 100%

2010 1,623 100 858 100 1,353 100 1,276 100 1,110 100 1,292 100 1,004 100 2,999 100 840 100 2,356 100 1,514 100 944 100

2009 1,728 100 868 100 1,379 100 1,340 100 1,168 100 1,220 100 1,051 100 2,940 100 914 100 2,421 100 1,632 100 932 100

2008 1,886 100 884 100 1,415 100 1,511 100 1,225 100 1,277 100 1,172 100 2,791 100 1016 100 2,534 100 1,700 100 987 100

2007 2,017 100 978 100 1,532 100 1,568 100 1,269 100 1,357 100 1,278 100 2,860 100 1092 100 2,733 100 1,779 100 1,089 100

Men 2011 853 54 475 54 775 54 594 54 631 57 650 53 473 47 1,587 54 503 60 1,460 60 889 59 517 54

2010 856 53 469 55 728 54 648 51 640 58 677 52 468 47 1,621 54 498 59 1,396 59 905 60 510 54

2009 913 53 471 54 729 53 678 51 669 57 617 51 474 45 1,600 54 432 58 1,410 58 950 58 499 54

2008 964 51 477 54 707 50 727 48 685 56 626 49 497 42 1,506 54 567 56 1,420 56 959 56 526 53

2007 1,008 50 491 50 745 49 741 47 689 54 647 48 521 41 1,512 53 603 55 1,505 55 992 56 556 51

Women 2011 741 46 400 46 656 46 500 46 467 43 575 47 538 53 1,368 46 336 40 984 40 606 41 438 46

2010 767 47 389 45 625 46 628 49 470 42 615 48 536 53 1,378 46 342 41 960 41 609 40 434 46

2009 815 47 397 46 650 47 662 49 499 43 603 49 577 55 1,340 46 382 42 1,011 42 682 42 433 46

2008 922 49 407 46 708 50 784 52 540 44 651 51 675 58 1,285 46 449 44 1,114 44 741 44 461 47

2007 1,009 50 487 50 787 51 827 53 580 46 710 52 757 59 1,348 47 489 45 1,228 45 787 44 533 49

Source: GAO analysis of EEO-1 reports provided by Reserve Banks.

Note: Percentages are rounded to the nearest percent.
Appendix V: Comments from the Consumer 

Financial Protection Bureau

Page 95 GAO-13-238 Financial Services Industry

Appendix V: Comments from the Consumer 

Financial Protection Bureau
Appendix V: Comments from the Consumer 

Financial Protection Bureau

Page 96 GAO-13-238 Financial Services Industry
Appendix VI: Comments from the Federal 

Reserve Banks

Page 97 GAO-13-238 Financial Services Industry

Appendix VI: Comments from the Federal 

Reserve Banks
Appendix VI: Comments from the Federal 

Reserve Banks

Page 98 GAO-13-238 Financial Services Industry
Appendix VII: Comments from the Federal 

Reserve Board

Page 99 GAO-13-238 Financial Services Industry

Appendix VII: Comments from the Federal 

Reserve Board 
Appendix VII: Comments from the Federal 

Reserve Board

Page 100 GAO-13-238 Financial Services Industry
Page 101 GAO-13-238 Financial Services Industry

Appendix VIII: Comments from the Federal 

Deposit Insurance Corporation
Appendix VIII: Comments from the Federal 

Deposit Insurance Corporation

Page 102 GAO-13-238 Financial Services Industry
Appendix IX: Comments from the Federal 

Housing Finance Agency

Page 103 GAO-13-238 Financial Services Industry

Appendix IX: Comments from the Federal 

Housing Finance Agency
Appendix X: Comments from the National 

Credit Union Administration

Page 104 GAO-13-238 Financial Services Industry

Appendix X: Comments from the National 

Credit Union Administration
Appendix XI: Comments from the Comptroller 

of the Currency

Page 105 GAO-13-238 Financial Services Industry

Appendix XI: Comments from the 

Comptroller of the Currency
Appendix XII: Comments from the Securities 

and Exchange Commission

Page 106 GAO-13-238 Financial Services Industry

Appendix XII: Comments from the Securities 

and Exchange Commission
Appendix XII: Comments from the Securities 

and Exchange Commission

Page 107 GAO-13-238 Financial Services Industry
Appendix XIII: Comments from the Treasury 

Department

Page 108 GAO-13-238 Financial Services Industry

Appendix XIII: Comments from the Treasury

Department
Appendix XIV: GAO Contact and Staff 

Acknowledgments

Page 109 GAO-13-238 Financial Services Industry

Daniel Garcia-Diaz, (202) 512-8678 or garciadiazd@GAO.gov

In addition to the individual named above, Kay Kuhlman, Assistant 

Director; Heather Chartier; Brendan Kretzschmar; Alma Laris; Ruben 

Montes de Oca; Cheryl Peterson; Jennifer Schwartz; Jena Sinkfield; 

Andrew Stavisky; and Julie Trinder made major contributions to this 

report.

Appendix XIV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(250656)
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