FINANCIAL INSTITUTION

DIVERSITY

Self-Assessment

2020 Results

OFFICE OF MINORITY

AND WOMEN INCLUSION

Table of

Contents

20 Standard 4: Practices to 

Promote Transparency of 

Organization Diversity and 

Inclusion 

23 Standard 5: Financial 

Institutions’ Self-Assessment

25

Participating Financial 

Institutions

25 Response Rate

26 Asset Size

28

Conclusion 

29 Resources

30

Appendix

Diversity, Equity and Inclusion 

Policy Sample Template for 

Illustrative Purpose

2

Executive Summary 

3 Workforce Demographics: 

Growing Minority and Gender 

Representation

4 Supplier Diversity, Diverse 

Candidate Outreach, and 

Information Sharing Need

Greater Prioritization 

5

2020 Assessment 

Results 

6 Workforce Demographics

8 Diversity and Inclusion 

Reporting Trends (2016 – 2020)

9 Standard 1: Organizational 

Commitment to Diversity and 

Inclusion

12 Standard 2: Workforce Profile 

and Employment Practices

16 Standard 3: Procurement 

and Business Practices - Supplier 

Diversity
2 | Financial Institution Diversity Self-Assessment 2020 Results

Executive 

Summary 

Since 2016, the FDIC’s Financial Institution Diversity SelfAssessment (FID-SA) program has supported the efforts of 

supervised institutions to create and grow their diversity 

programs, which allow them to build strong relationships 

with their clients and communities, maximize workforce 

representation, and develop and implement inclusion efforts. 

The FDIC developed the diversity self-assessment framework 

based on the Joint Standards for Assessing our Regulated 

Entities’ Diversity Policies and Practices that we established 

with five other federal agencies. 

The FID-SA gathers reliable data that can be used to inform 

management decision making on diversity, equity, and inclusion 

(DEI) goals and strategies, and allows organizations to set 

benchmarks and track and communicate progress. The program 

also allows the FDIC to learn about supervised institutions’ 

diversity programs and challenges, which puts us in a better 

position to provide effective technical assistance.

This report presents the key 2020 Diversity Self-Assessment

results and offers suggestions that may help financial institutions 

build better relationships with their employees, customers, and 

communities. 

For the 2020 reporting period, 148 FDIC-supervised financial 

institutions voluntarily participated in the diversity selfassessment (representing 19 percent of invited institutions). 

Participating financial institutions represent 38 percent of the 

total employees and 39 percent of the total assets ($3.3 billion) 

held by invited FDIC-supervised financial institutions. More than 

half of the participating financial institutions had also submitted 

a self-assessment for the 2019 reporting period.

For the 2020 reporting period, we identified some promising 

trends and areas for improvement where we can provide 

technical assistance.
Financial Institution Diversity Self-Assessment 2020 Results | 3

Workforce Demographics: Growing Minority and 

Gender Representation

Financial institutions’ workforce demographics showed a general upward trend in minority1

 and gender representation across 

all categories between 2019 and 2020. 

Key Results:

◉ Minority representation in the total workforce 

increased from 33 percent to 46 percent. Among 

management roles, minority representation grew 

from 11 percent to 18 percent.

◉ Representation of women in management 

positions increased from 34 percent to 48 percent, 

with a slight increase from 16 percent to 20 

percent at the board level among the responding 

financial institutions.

We attributed improved minority and gender representation 

by participating institutions to the continued upward trend in 

positive responses on questions about leadership support and 

board-level commitment to workforce DEI. 

The strongest DEI programs share the following characteristics: 

leadership commitment, a DEI policy/plan, focus on workforce 

and workplace inclusion, and supplier diversity strategies to 

ensure diverse supplier base for procurement of goods and 

services.

1

 As defined in section 1204(c) of the Financial Institutions Reform, Recovery, and 

Enforcement Act of 1989 (12 USC 1811 note), the term “minority” means any Black 

American, Native American, Hispanic American, or Asian American.
4 | Financial Institution Diversity Self-Assessment 2020 Results

Supplier Diversity, Diverse Candidate Outreach, and 

Information Sharing Need Greater Prioritization 

Overall, since 2016, the assessment results have shown 

an upward trend in financial institutions affirming their 

commitment to DEI and workforce diversity, however work 

remains in several essential areas.

Key Results: 

◉ Many financial institutions have not instituted a 

Supplier Diversity Policy.

◉ Some financial institutions fail to conduct 

outreach to diverse candidates and communities 

that foster diverse applicant pools for 

employment opportunities.

◉ Financial institutions remain reluctant to share 

information on the organization’s diversity 

program and performance with the public. 

The lack of focused strategies in the above areas, will impact 

the overall effectiveness of DEI programs. Despite these weak 

spots, many financial institutions indicated that they have plans 

to adopt DEI practices, have plans to re-evaluate their current 

DEI practices in the future, or recognized that their organization 

needs to do more to improve diversity and inclusion. 
Financial Institution Diversity Self-Assessment 2020 Results | 5

2020 Assessment 

Results 

The results are based on participating financial institutions’ reporting within the Diversity Self-Assessment of FDIC-Regulated 

Financial Institution instrument framework. We developed the 

diversity self-assessment (DSA) form to support FDIC-supervised 

financial institutions’ efforts to assess their diversity policies and 

practices and inform decision-making on building and maintaining a DEI program. By participating in the DSA, financial institutions obtain actionable data that can allow them to:

◉ Build an Inclusive Work Culture,

◉ Demonstrate Commitment to Workforce Diversity and EEO, 

◉ Establish a Supplier Diversity Policy,

◉ Publish Information on DEI Progress, and 

◉ Assess Performance for Continuous Improvement. 

In reporting the results, we aggregated the financial institutions’ 

affirmative responses across the underlying assessment factors 

for each of the five Standards as a measure of demonstrated 

commitment. Financial institutions’ “Yes” responses to the 

relevant assessment factors measure the level of support for 

each of the Standards across all the institutions.2 

In addition to the responses on the assessment factors, the 

assessment collects data on workforce demographics regarding 

the total workforce, management, and board-level diversity. 

2

 The percent result for each standard represents the average across all participating 

financial institutions’ responses on each assessment factor unless otherwise indicated 

in the narrative. 
6 | Financial Institution Diversity Self-Assessment 2020 Results

Workforce Demographics

Workforce demographics are an important indicator of our 

financial institutions’ DEI efforts. This data informs management 

about their current workforce diversity and highlights areas of 

opportunity in the talent pipeline. Further, it helps to identify 

opportunities to expand access to available talent in the labor 

market that can be used for strategies such as succession 

planning.3  

The aggregated workforce demographic results showed 

improved minority and women representation between 2019 

and 2020. We observed that a majority, or 72 percent, of the 

financial institutions that completed an assessment in 2019 

participated in 2020. The reporting showed a significant 

increase in minority representation in the total workforce and 

management. Across financial institutions that participated 

both years, minority workforce representation increased 13 

percentage points, from 33 percent to 46 percent. The increase 

in minority representation at the management level was seven 

percentage points higher, increasing from 11 percent to 18 

percent. During the same period, women representation in 

management increased to 48 percent, up from 34 percent the 

previous year. Despite these workforce diversity improvements, 

financial institutions reported only slight increases in boardlevel representation for minorities and women. Figure 1 shows 

changes in the workforce demographics since the 2019 reporting 

period.4 This improvement in representation aligns with 

improvement in financial institutions certifying commitment to 

DEI and workforce diversity. 

3

 US Government Accountability Office (2021). Financial Services Industry: Using Data

to Promote Greater Diversity and Inclusion, available at https://www.gao.gov/assets/

gao-21-448t.pdf.

4

 For 2020, 92 financial institutions that completed a diversity self-assessment also 

participated in 2019. 
Financial Institution Diversity Self-Assessment 2020 Results | 7

Figure 1: 

Workforce Demographics for Participating 

Financial Institutions in Both 2019 and 2020

BOARD

MANAGEMENT

9%

5%

18%

WORKFORCE

11%

46%

33%

2019 2020

BOARD

MANAGEMENT

20%

16%

48%

WORKFORCE

34%

63%

63%

2019 2020

Women Workforce Demographics

Minority Workforce Demographics
8 | Financial Institution Diversity Self-Assessment 2020 Results

While workforce demographics remain a key metric, in recent 

years, many studies have shown that without inclusion and equity, 

diversity strategies have limited long-term success. Organizations 

must also create a workplace culture that is inclusive, welcoming 

of diverse talent, and have a structure where all employees 

believe they have an equitable opportunity to succeed. 

Diversity and Inclusion Reporting Trends (2016 – 2020)

DEI reporting trends among financial institutions have 

remained steady since 2016. As shown in Figure 2, we continue 

to see an upward trend in financial institutions that reported 

making a commitment to building an inclusive culture and 

diverse workforce reflective of the communities they serve. In 

comparison, we saw little change in the number of financial 

institutions that reported sharing information on their diversity 

efforts’ progress, with slight increases or decreases over the years. 

For 2020, the assessment results continue to show that fewer than 

20 percent of participating financial institutions have a formal 

Supplier Diversity Program in place. 

Figure 2: 

Diversity Self-Assessment Reporting Trends (2016 – 2020)
Financial Institution Diversity Self-Assessment 2020 Results | 9

Standard 1: Organizational Commitment to 

Diversity and Inclusion

Responses to this Standard reflect how the leadership of an 

organization demonstrates its commitment to diversity and 

inclusion. The commitment starts with senior leadership, 

including the board of directors and cascades throughout the 

organization through the adoption of policies, practices, and 

procedures that align with leadership’s vision. Management must 

proactively communicate the importance of DEI and embed DEI 

into employment practices and business operations. 

Key Results:

◉ In 2020, 89 percent of participating institutions 

reported affirming their organizational 

commitment to DEI, representing a five percentage 

point increase from 2019.

◉ Ninety-two percent of participating institutions 

stated their organization had designated a Diversity 

Officer or other official responsible for DEI. 

◉ Many institutions reported that they consider DEI 

as part of their strategic planning, training, and 

employment systems.
10 | Financial Institution Diversity Self-Assessment 2020 Results

Despite a strong overall performance on organizational 

commitment, several financial institutions stated they did not 

have a formal DEI policy or did not provide regular diversity 

reporting to senior leadership or the board of directors. 

Below are the aggregate results for each assessment factor.

Assessment Results: Organizational Committment

1.1. The financial institution includes diversity and inclusion considerations in 

both employment and contracting as an importan part of its strategic plan for 

recruiting, hiring retention, and promotion.

1.2. The financial institution has a diversity and inclusion policy that is approved 

and supported by senior leadership, including senior management and the 

board of directors.

1.3 The financial institution provides regular progress reports to the board and 

senior management.

1.4 The financial institution regularly conducts training and provides educational 

opportunities on equal employment opportunity and on diversity and inclusion.

1.5 The financial institution has a senior level official, preferably with knowledge 

of and experience in diversity and inclusion policies and practices, who oversees 

and directs the financial institution’s diversity and inclusion efforts.

1.6 The financial institution takes proactive steps to promote a diverse pool 

of candidates, including women and minorities, in its hiring, recruiting, 

retention, and promotion, as well as in its selection of board members, senior 

management, and other senior leadership positions. 

93% 7%

80% 20%

81% 19%

89% 11%

92% 8%

97% 3%

 Percentage Yes Percentage No Average: Yes (89%) No (11%)
Financial Institution Diversity Self-Assessment 2020 Results | 11

Most financial institutions (92 percent) stated the organization 

had a Diversity Officer (DO) or designated official responsible 

for DEI. The existence of a DO as a member of the leadership 

team provides subject matter expertise and maintains the 

organization’s focus on DEI programming. While important, 

the DO cannot be solely responsible for sustained culture 

change. The front-line managers who interact with employees 

and customers daily also play a critical role in creating an 

inclusive culture. 

Diversity Policy and Reporting

Despite the overall high ratings for this Standard, we see 

opportunities for financial institutions to continue to enhance 

their programs in two key areas. First, financial institutions need 

to establish a formal DEI policy, and second, they should provide 

regular diversity reporting to senior leadership and the board. 

A formal diversity policy communicates to employees, 

customers, and the general public the organization’s 

commitment to building a more inclusive and diverse culture 

that values the contribution of all employees. We observed that 

80 percent of financial Institutions affirmed the existence of a 

policy. However, financial institutions’ comments most often 

referenced the existence of an equal employment opportunity 

(EEO) policy. An EEO Policy is generally focused on compliance 

and the legal requirements of eliminating discrimination. 

It cannot substitute for a diversity policy, which speaks to 

matters beyond legal compliance. For example, the policy 

should reflect the values of the organization and articulate the 

importance of diversity. An example of a strong diversity policy 

from the Society for Human Resource Management (SHRM) is 

available as an Appendix to this report. Financial institutions 

may use the template as a starting point and modify it to meet 

their needs. 
12 | Financial Institution Diversity Self-Assessment 2020 Results

The second opportunity for improvement is in the area of 

reporting. Leading organizations have a process for regular 

reporting to senior leadership to keep them informed and 

engaged in DEI. The reporting frequency can vary from as 

needed to annually. We observed that most institutions (47 

percent) only reported annually to senior management and 

the board. Depending on the financial institutions’ size and 

structure, more frequent reporting may be warranted. For 

example, an institution may incorporate DEI data with its 

quarterly management reports in order to monitor ongoing 

progress. If there is a designated Diversity Officer, that individual 

may work with senior leaders and managers to determine the 

optimum reporting frequency to inform the decision making 

process. 

Standard 2: Workforce Profile and 

Employment Practices

Responses to this Standard reflect how financial institutions 

promote the fair inclusion of minorities and women in 

their workforce by publicizing employment opportunities, 

creating relationships with minority and women professional 

organizations and educational institutions, creating a culture 

that values the contribution of all employees, and encouraging 

a focus on these objectives when evaluating the performance 

of managers. Financial institutions with successful diversity and 

inclusion programs also regularly evaluate their programs and 

identify areas to be improved. 

Key Results:

◉ In 2020, 85 percent of responding financial 

institutions had adopted policies and practices to 

promote workforce diversity.

◉ There was a noticeable decline in the three 

assessment factors that address outreach 

practices that promote diverse applicant pools for 

both internal and external opportunities.
Financial Institution Diversity Self-Assessment 2020 Results | 13

The assessment results found that the 85 percent mark is an 

increase of four percentage points over 2019. Financial institutions 

demonstrated their commitment by providing equal employment 

opportunities for employees and candidates, using quantitative and 

qualitative metrics to assess efforts, and aligning DEI with business 

strategies on the manager’s performance plans. Below are the 

aggregate results for each assessment factor. 

Assessment Results: Workplace Profile and Employment Practices 

2.1 The financial institution implements policies and practices related to workforce 

diversity and inclusion in a manner that complies with all applicable laws.

2.2 The financial institution ensures equal employment opportunities for all 

employees and applicants for employment and does not engage in unlawful 

employment discrimination based on gender, race, or ethnicity.

2.3 The financial institution has policies and practices that create diverse applicant 

pools for both internal and external opportunities that may include: 

2.3(a) Outreach to minority and women organizations.

2.3(b) Outreach to educational institutions serving significant minority and women 

student populations.

2.3(c) Participation in conferences, workshops, and other events to attract minorities 

and women and to inform them of employment and promotion opportunities.

2.4 The financial institution utilizes both quantitative and qualitative measurements to 

assess its workforce diversity and inclusion efforts. 

2.5 The financial institution holds management at all levels accountable for diversity 

and inclusion efforts, for example, by ensuring that such efforts align with business 

strategies and individual performance plans.

99% 1%

80% 20%

70% 30%

71% 29%

90% 10%

83% 17%

 Percentage Yes Percentage No Average: Yes (85%) No (15%)

99% 1%
14 | Financial Institution Diversity Self-Assessment 2020 Results

Outreach to Minorities and Women

Despite the overall high Standard rating, we observed a decline 

in the financial institutions’ “Yes” responses to the assessment 

factors promoting outreach for employment opportunities. We 

highlighted these areas as opportunities for financial institutions 

to continue growing and developing their diversity programs. 

Further, financial institutions identified some outreach 

challenges they faced attracting minorities and women for 

opportunities, including: 

◉ Lack of outreach policies and practices in place for creating 

diverse applicant pools,

◉ Limited or postponed outreach activities for the year due to 

the COVID-19 pandemic restrictions, 

◉ Limited availability of conferences and workshops in rural 

communities, and

◉ No/limited educational institutions serving minority and 

women student populations in the community. 

The assessment results indicated that financial institutions 

in small rural communities may not have the same access to 

diverse talent as larger financial institutions or institutions in 

metropolitan areas. However, effective outreach can focus on 

areas other than demographic diversity and institutions should 

look for partnership opportunities with organizations that can 

expand their population reach. These partnerships may include 

outreach to churches, veterans, civic, and other groups that 

target historically underserved groups in their communities. 

In addition, maintaining good demographic and socioeconomic 

data on the surrounding communities is important for helping 

financial institutions define diversity and the community needs 

that are within their area of influence. This information can 

inform decisions they make about possible growth opportunities 

and mitigation strategies for addressing gaps when considering 

the available resources needed to support outreach. To make 

efforts more effective, demographic data may be used to identify 

possible organizations, schools, and events that the financial 

institutions can include in their outreach strategy. 
Financial Institution Diversity Self-Assessment 2020 Results | 15

A free resource available for compiling community demographic 

data is the United States Census Bureau’s Advancing Equity with 

Data website. 

In addition, participating financial institutions shared practices 

that may help other institutions promote workforce diversity, 

including:

◉ Strengthening the bank’s relationship with minority or lowand moderate-income communities by providing financial 

literacy training and internship programs (e.g., FDIC Money 

Smart Alliance). 

◉ Hosting mentoring events where college students learn 

about the organization’s diversity program; build relationships with human resources and hiring managers; and receive coaching on interview skills and résumé writing, the 

application process, and effective networking.

◉ Building relationships with majority-minority institutions to 

build a talent pipeline, developing an internship and scholarship program, and participating in on-campus recruiting 

events. 

◉ Forming Employee Resource Groups to assist in developing 

and deepening partnerships in the community.

◉ Hiring minority and women recruiters or firms to help identify diverse talent for vacancies.

◉ Sponsoring a virtual event where bank management discusses the bank’s employment opportunities and goals for developing a diverse talent pipeline for full-time and part-time 

permanent employees. 

◉ Sponsoring women leaders in an emerging leaders program 

for career development.
16 | Financial Institution Diversity Self-Assessment 2020 Results

Standard 3: Procurement and Business Practices - 

Supplier Diversity

Responses to this Standard reflect how organizations 

increasingly understand the competitive advantage of having 

a broad selection of available suppliers to choose from with 

respect to factors such as price, quality, attention to detail, 

and future relationship building. Leading DEI organizations 

understand the benefits of maintaining a diverse vendor pool 

for contracting opportunities. Organizations that expand 

contracting opportunities benefit from increased innovation, 

competition, and cost savings. These organizations maintain 

a formal supplier diversity policy that guides the program’s 

purpose, scope, goals, and strategies and provides metrics for 

monitoring program performance. 

Key Results:

◉ In 2020, 19 percent of participating institutions 

had adopted supplier diversity policies and 

practices.

◉ Thirty-nine percent reported having a Supplier 

Diversity Officer or equivalent designated official. 

◉ Forty-nine percent of FDIC’s largest participating 

supervised financial institutions had adopted 

supplier diversity leading practices.

A key takeaway from the assessment results was the 

importance of having a formal supplier diversity policy. 

Leading DEI organizations establish a policy that defines their 

supplier diversity program’s goals, scope, and strategies for 

promoting opportunities with diverse businesses. We observed 

that financial institutions that did not affirm compliance with 

the Standard often stated they lacked a supplier diversity policy 

that addressed outreach to diverse businesses, procedures 

to track spending with businesses, and participation in 

conferences, workshops, or other events to attract minorityowned and women-owned firms for contracting opportunities.
Financial Institution Diversity Self-Assessment 2020 Results | 17

A few institutions stated they were in the process of hiring a 

Supplier Diversity Officer to lead their program. The lack of 

procedures and a mission for supplier diversity make it difficult 

for financial institutions to maximize DEI efforts and gauge 

progress over time. Below are the aggregate results for each 

assessment factor. 

Assessment Results: Supplier Diversity 

3.1 The financial institution has a supplier diversity policy that provides for a fair 

opportunity for minority-owned and women-owned businesses to compete for 

procurement of business goods and services. 

3.2 The financial institution has methods to evaluate its supplier diversity, 

which may include metrics and analytics related to: 

3.2(a) Annual procurement spending 

3.2(b) Percentage of contract dollars awarded to minority-owned and womenowned businesses by race, ethnicity, and gender.

3.2(c) Percentage of contracts with minority-owned and women-owned 

business subcontractors.

3.3 The financial institution has practices to promote a diverse supplier pool, 

which may include:

3.3(a) Outreach to minority-owned and women-owned contractors and 

representative organizations.

3.3(b) Participation in conferences, workshops, and other events to attract 

minority-owned and women-owned firms and inform them of contracting 

opportunities.

3.3(c) An ongoing process to publicize its procurement opportunities. 

28% 72%

22% 78%

15% 85%

13% 87%

21% 79%

19% 81%

15% 85%

 Percentage Yes Percentage No Average: Yes (19%) No (81%)
18 | Financial Institution Diversity Self-Assessment 2020 Results

We note that financial institutions may struggle with where and 

how to start a supplier diversity program. To assist our financial 

institutions, the FDIC prepared “Guidance to Procurement 

and Business Practices,” which leverages information from 

responding financial institutions to highlight effective supplier 

diversity practices. The guide is available as a resource on the 

Financial Institution Diversity Program website. In addition, 

the FDIC has maintained a Minority and Women Outreach 

Program since the late 1980s. Supervised financial institutions 

are encouraged to visit our website and send questions to the 

mwoboutreach@fdic.gov mailbox to learn more about our 

program and how we got started. 

Large Financial Institutions

Further, analysis of the data by asset size revealed that financial 

institutions with more than $10 billion in assets were more 

likely to have a supplier diversity program. For 2020, 14 (or 9 

percent) of participating institutions had assets over $10 billion. 

The majority of these financial institutions reported they had a 

formal supplier diversity policy and they tracked contract dollars 

spent with minority-owned and women-owned businesses. 

Overall, we observed that, among the largest participating 

financial institutions, 49 percent had adopted leading supplier 

diversity practices. Conversely, among all participating 

institutions, only 19 percent had adopted such practices. Larger 

financial institutions identified the following supplier diversity 

practices: 

◉ Having a formal supplier diversity policy approved by 

management or researching and developing a policy. 

◉ Promoting a diverse supplier pool by having their supplier 

diversity managers serve on national and local supplier 

advocacy organizations’ committees, boards, and leadership 

roles. Also, ensuring procurement teams share open 

opportunities with certified minority- and women-owned 

businesses. 

◉ Advertising (regularly) procurement opportunities to 

supplier diversity advocacy organizations and surrounding 

communities via the institution’s website. 
Financial Institution Diversity Self-Assessment 2020 Results | 19

◉ Partnering with supplier diversity advocacy groups and local 

and regional affiliates to identify and invite diverse businesses to participate in contracting opportunities. For example:

| Financial Services Roundtable for Supplier 

Diversity (FSRSD)

| National LGBT Chamber of Commerce (NGLCC)

| National Minority Supplier Development 

Council (NMSDC)

| US Pan Asian American Chamber of 

Commerce (USPAACC)

| Women’s Business Enterprise National 

Council (WBENC)

◉ Setting a contracting goal with diverse suppliers (e.g., spend 

at least XX percent). 

◉ Reporting contract dollars spent with diverse businesses to 

the Diversity Officer and senior management and publishing 

that information on the institution’s website.

Supplier Diversity Spend

Further, 24 participating financial institutions (16 percent of all 

participating institutions) reported statistics on dollars spent 

with minority-owned and women-owned businesses. These 

financial institutions reported $4.1 billion in total spending: 

$83.4 million went to women-owned businesses and $93.6 

million to minority-owned businesses. 
20 | Financial Institution Diversity Self-Assessment 2020 Results

Figure 3 shows the percent of contract dollars spent by regions 

with diverse businesses. Across all regions, less than 10 percent 

of reported contract dollars went to minority-owned or womenowned businesses. 

Figure 3:

Percent of Total Contract Dollars Spent with Minority-Owned and 

Women-Owned Businesses

85%

94%

98%

91%

98%

91%

8.9%

4.1%

1.3%

5.3%

1.4%

2.7%

6.3%

1.9%

0.8%

4.0%

0.8%

6.4%

20% 40% 60% 80% 100%

Atlanta

Chicago

Dallas

Kansas

City

New York

San

Francisco

Non-Diverse Women-Owned Minority-Owned

If a robust supplier diversity program is not an option for your 

financial institution the organization can still be intentional 

in expanding its pool of available vendors for contracting 

opportunities. Doing so can offer access to new business 

opportunities and competitive pricing. 

Standard 4: Practices to Promote Transparency of 

Organization Diversity and Inclusion 

Responses to this Standard reflect how financial institutions’ 

transparency and publicity are important aspects of assessing 

diversity policies and practices. Financial institutions that are 

transparent about DEI build trust with their employees, 

customers, and, ultimately, with the communities they serve. 

These institutions publish information on their DEI commitment, 

goals, strategies, and progress as a normal course of business. 
Financial Institution Diversity Self-Assessment 2020 Results | 21

This knowledge-sharing increases the attractiveness of the 

organization and can promote greater engagement with 

internal and external stakeholders. In addition, transparency 

builds accountability into the program and promotes 

meaningful change. 

Key Results:

◉ In 2020, 53 percent of participating financial 

institutions had adopted the standard practices 

shown in the below table. 

◉ DEI transparency efforts primarily focus on 

educating managers and employees about their 

organizational priorities and initiatives.

◉ Most participating financial institutions that 

did not publish information cited the lack of an 

existing policy that governs the publication of 

diversity information. 

After a worldwide pandemic and the events impacting minority 

communities across America, people are looking for more 

corporate statements articulating a commitment to DEI. In 

addition to statements, the results of DEI efforts must be 

tangible, visible, ongoing, and supported by strategies 

and actions that demonstrate progress. 

Publish DEI Information

Participating financial institutions varied in the amount of DEI 

information they published. The assessment results showed 

that a little more than half of the financial institutions shared 

some level of DEI information both internally and externally. 

At a minimum, most financial institutions stated they published 

current employment opportunities, high-level workforce 

demographics and development programs, and their DEI 

policy commitment. At the same time, most participating 

financial institutions said that their DEI strategic plan was not 

published externally. 
22 | Financial Institution Diversity Self-Assessment 2020 Results

However, the information was shared with internal management 

and employees. Financial institutions stated there was no 

policy governing the publication of diversity information. One 

way to get started and possibly overcome a concern about 

making information publicly available is to start with publishing 

information on community outreach and engagement activities. 

Through engagement, institutions can seek input from 

communities served on the level of desired information sharing. 

Consistent with prior years, the lowest-rated factor continues 

to be financial institutions publishing “forecasts of potential 

employment and procurement opportunities.” Those who shared 

forecast information were limited to promoting future expansion 

opportunities in the local news and social media platforms.

Assessment Results: Practices to Promote Transparency of DEI

4.1 The financial institution publicizes its diversity and inclusion strategic plan.

4.2 The financial institution publicizes its policy on its commitment to diversity 

and inclusion.

4.3. The financial institution is transparent about its progress toward achieving 

diversity and inclusion in its workforce and procurement activities.

4.4. The financial institution publicizes its opportunities to promote diversity, 

which may include:

4.4(a) Current employment and procurement opportunities. 

4.4(b) Forecasts of potential employment and procurement opportunities. 

4.4(c) The availability and use of mentorship and developmental programs for 

employees and contractors.3.3(c) An ongoing process to publicize its procurement 

opportunities. 

37% 63%

68% 32%

59% 41%

77% 23%

23% 77%

57% 43%

 Percentage Yes Percentage No Average: Yes (53%) No (47%)
Financial Institution Diversity Self-Assessment 2020 Results | 23

In general, responding financial institutions that published DEI 

information post it on their public website or in their annual 

Corporate Social Responsibility Report; Environmental, Social 

and Governance Report; DEI Annual Report; or Annual Report. 

In addition, a few financial institutions noted they also share 

DEI program information via social media posts on LinkedIn, 

Facebook, and Twitter.

Standard 5: Financial Institutions’ Self-Assessment

Leading DEI organizations assess their DEI program performance 

annually. They allocate resources to evaluate diversity and 

inclusion programs to improve performance and disclose the 

results. Our 2020 data identifies areas where strategies and 

initiatives have the intended impact, while also indicating where 

performance challenges still exist. By sharing information 

on performance, financial institutions demonstrate DEI 

commitment to employees, customers, suppliers, and the 

general public.  

Key Results: 

◉ In 2020, 67 percent of financial institutions 

assessed their diversity programs and shared the 

results.

◉ Most reporting financial institutions conducted an 

assessment, but only 32 percent shared the results 

externally. 

We observed a significant decline in the number of financial 

institutions that responded “Yes” to publishing information 

on their assessment results. Publishing information on DEI 

results can help organizations build trusting relationships with 

customers, suppliers, and the public. 
24 | Financial Institution Diversity Self-Assessment 2020 Results

The low number of affirmative responses to the assessment 

factor continued to lower the overall standard rating. The 

assessment results found 67 percent of participating financial 

institutions assessed their diversity programs and shared the 

results, a slight increase over 2019. Below are the aggregate 

results for each assessment factor. 

Assessment Results: Financial Institutions’ Self-Assessment

5.1 The financial institution conducts an assessment of its diversity policies and 

practices annually. 

5.2. The financial institution monitors and evaluates its performance under its 

diversity policies and practices on an ongoing basis.diversity and inclusion in 

its workforce and procurement activities.

5.3. The financial institution publishes information pertaining to its assessment 

of its diversity policies and practices.

Most participating financial institutions indicated that, at a 

minimum, the results are shared internally with management. 

Some participating financial institutions stated they were not 

ready to share DEI program results externally, while others 

considered the information confidential. Despite the reluctance 

to disclose assessment results externally, a few financial 

institutions shared limited information in their Annual Report; 

Corporate Social Responsibility, Diversity and Inclusion Report; 

or Environmental, Social and Governance Report. Studies 

show increasing transparency on diversity is important to 

attracting top talent, especially among millennials who report 

an organization’s diversity performance is important when 

considering companies they want to work for. 

85% 15%

84% 16%

32% 68%

 Percentage Yes Percentage No Average: Yes (67%) No (33%)
Financial Institution Diversity Self-Assessment 2020 Results | 25

Participating 

Financial 

Institutions 

We believe all FDIC-supervised institutions can benefit from 

assessing their diversity practices, and we want to hear from even 

more of our financial institutions. During 2020, participating 

financial institutions continued to represent a small percentage 

of all FDIC-supervised financial institutions. In 2020, there were 

3,230 FDIC-supervised financial institutions.5 The FDIC invited 773 

of these institutions with 100 or more employees to participate in 

the diversity self-assessment, representing 24 percent of all FDICsupervised financial institutions.6

 

For the reporting period, 148 (19 percent) of the 773 financial 

institutions invited voluntarily conducted a self-assessment and 

shared the results with the FDIC. Of the participating financial 

institutions, 14 (or 9 percent) had assets of $10 billion or more. 

5 Source: 2020 FDIC Annual Report at https://www.fdic.gov/about/financial-reports/

reports/2020annualreport/index.html.

6

 These institutions are the primary focus of the Interagency Policy Statement 

Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities 

Regulated by the Agencies.
26 | Financial Institution Diversity Self-Assessment 2020 Results

Response Rate

Figure 4 illustrates the number of invited institutions, 

submissions, and response rates by FDIC region.  The number of 

participating financial institutions by region ranged from a low 

of 16 in the Kansas City Region to a high of 46 in the New York 

Region. 

Figure 4: 

2020 Reporting Period Response Rate by FDIC Region

1

1

U.S. Census data shows that racial and ethnic demographics 

in the country are shifting. 7 Therefore, the customers a 

financial institution serves today may be different in the future. 

Maintaining a workforce that reflects the community served, and 

understanding the needs of the evolving community impacts 

the effectiveness of the services provided and, ultimately, the 

effectiveness of the organization. 

Asset Size

After the 2020 reporting period, OMWI decided to use the 

Modified Quarterly Banking Profile (QBP) Asset Threshold 

to segment participating financial institutions because the 

Community Reinvestment Act (CRA) Asset-Size Threshold 

definitions do not provide sufficient asset granularity. 

7

 FDIC Community Banking Study (December 2020), available at https://www.fdic.gov/

resources/community-banking/cbi-study.html.
Financial Institution Diversity Self-Assessment 2020 Results | 27

As a result, we are transitioning from three to five asset 

categories, which gives us better visibility into the diversity 

practices of our institutions by asset size. 

Participating financial institutions represented 38 percent of the 

total employee population and 39 percent of the total assets 

($3.3 billion) held by invited financial institutions.8 Figure 5 

illustrates the responding financial institutions by asset size. 

Figure 5:

Responding Financial Institutions by Asset Size 

5 3

%Response Rate

5 3

%Response Rate

8

 Interagency Policy Statement Establishing Joint Standards for Assessing the

Diversity Policies and Practices of Entities Regulated by the Agencies targets financial 

institutions with 100 or more employees.
28 | Financial Institution Diversity Self-Assessment 2020 Results

Conclusion 

As in previous years, the Office of Minority and Women Inclusion 

(OMWI) notes that participating financial institutions have 

progressed in some areas but demonstrated limited advancement 

in others. FDIC-supervised financial institutions continue 

to demonstrate strong performance in the organizational 

commitment to building an inclusive culture and workforce 

diversity. However, with respect to supplier diversity, transparency 

with DEI progress, assessment results remained flat with little 

or no change since the first reporting period in 2016. For this 

reason, we focused the report on the areas within each of the five 

standards where a noticeable number of financial institutions 

had not affirmed compliance with one or more assessment 

factors. These areas lower the overall standard rating across all 

participating financial institutions.

Key areas where performance is lacking are: DEI policies, Supplier 

Diversity Officer, and transparency on DEI performance. In those 

instances where the financial institution did not respond “Yes” 

to an assessment factor, several stated their intent to revisit the 

decision or that they were in the process of implementing the 

diversity practice. This report provides some guidance in those 

areas; in addition, OMWI offers technical assistance for institutions 

that want to enhance their programs. 

In the future, we believe our smaller financial institutions can also 

benefit from participating in the DSA. Smaller financial institutions 

can use this report tool to find best practices, guide discussions, 

and define what DEI means in their communities. Management 

can then use data to communicate specifically about their 

diversity challenges and identify opportunities to make changes 

that pay off in the future. For example, conducting outreach and 

building relationships with communities the financial institution 

may have previously overlooked is a good strategy for identifying 

new opportunities.

We encourage our financial institutions to share more information 

on their DEI successes, challenges, and practices in the future 

through the DSA narrative comments, particularly in areas where 

the financial institution does not respond “Yes” to an assessment 

factor. The FDIC may use these narratives to identify opportunities 

to provide technical assistance to our financial institutions. 
Financial Institution Diversity Self-Assessment 2020 Results | 29

Resources

The below list of resources highlights strategies and initiatives in 

which the FDIC is engaged to ensure that we ourselves build and 

maintain an organization that reflects the communities we serve. 

These resources are also provided for illustrative purposes 

to assist FDIC-supervised financial institutions in developing 

diversity programs. 

Organizational Commitment to Diversity and Inclusion

◉ The FDIC Diversity, Equity, and Inclusion Strategic 

Plan (2021 – 2023)

Workforce Profile and Employment

◉ The FDIC Diversity Reports

◉ Guidance relating to Workforce Profile and 

Employment Practices

◉ Connecting Communities to Financial Resources

Procurement and Business Practices – Supplier Diversity

◉ Minority and Women Outreach Program

◉ Doing Business with the FDIC

◉ MWOB Activity Reports

◉ Guidance relating to Procurement and Business 

Practices – Supplier Diversity

Practices to Promote Transparency

◉ See the FDIC Diversity Reports Under Workforce 

Profile and Employment

Diversity Self-Assessment

◉ FID-SA Diversity Self-Assessment Portal 

Diversity Toolkit
30 | Financial Institution Diversity Self-Assessment 2020 Results

Appendix

Diversity, Equity and Inclusion Policy 

Sample Template for Illustrative Purpose

[Company Name] is committed to fostering, cultivating and 

preserving a culture of diversity, equity and inclusion.

Our human capital is the most valuable asset we have. The 

collective sum of the individual differences, life experiences, 

knowledge, inventiveness, innovation, self-expression, unique 

capabilities and talent that our employees invest in their work 

represents a significant part of not only our culture, but our 

reputation and company’s achievement as well.

We embrace and encourage our employees’ differences in 

age, color, disability, ethnicity, family or marital status, gender 

identity or expression, language, national origin, physical 

and mental ability, political affiliation, race, religion, sexual 

orientation, socio-economic status, veteran status, and other 

characteristics that make our employees unique.

[Company Name’s] diversity initiatives are applicable—but 

not limited—to our practices and policies on recruitment and 

selection; compensation and benefits; professional development 

and training; promotions; transfers; social and recreational 

programs; layoffs; terminations; and the ongoing development 

of a work environment built on the premise of gender and 

diversity equity that encourages and enforces:

z Respectful communication and cooperation between all 

employees.

z Teamwork and employee participation, permitting the 

representation of all groups and employee perspectives.

z Work/life balance through flexible work schedules to 

accommodate employees’ varying needs.

z Employer and employee contributions to the communities we serve to promote a greater understanding and 

respect for the diversity.
Financial Institution Diversity Self-Assessment 2020 Results | 31

All employees of [Company Name] have a responsibility to 

treat others with dignity and respect at all times. All employees 

are expected to exhibit conduct that reflects inclusion during 

work, at work functions on or off the work site, and at all other 

company-sponsored and participative events. All employees are 

also required to attend and complete annual diversity awareness 

training to enhance their knowledge to fulfill this responsibility.

Any employee found to have exhibited any inappropriate 

conduct or behavior against others may be subject to 

disciplinary action.

Employees who believe they have been subjected to any kind of 

discrimination that conflicts with the company’s diversity policy 

and initiatives should seek assistance from a supervisor or an HR 

representative.

Source: Society of Human Resource Management. 
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