2019

Section 342

Dodd-Frank Wall Street Reform 

and Consumer Protection Act

REPORT TO CONGRESS

FEDERAL DEPOSIT INSURANCE CORPORATION 

Office of Minority and Women Inclusion

Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress i

Table of Contents

INTRODUCTION .............................................................................................. 1

FDIC CONTRACTING: 

Inclusion of Minority- and Women-Owned Businesses (MWOBs)............ 5

EMPLOYMENT AT THE FDIC:

Fair Inclusion of Minorities and Women......................................................23

OTHER ACTIVITIES ........................................................................................35

CONCLUSION.................................................................................................57

APPENDICES...................................................................................................59
ii Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 1

INTRODUCTION

Under the provisions of the Dodd-Frank Wall Street Reform and Consumer 

Protection Act (DFA), Section 342, the Federal Deposit Insurance Corporation 

(FDIC), Office of Minority and Women Inclusion (OMWI) is required to submit 

to Congress an annual report regarding the actions taken by the agency toward 

contracting with qualified minority- and women-owned businesses and hiring 

qualified minority and women employees. 

The FDIC is pleased to submit this 2019 Report to Congress. The report describes the 

FDIC’s activities relating to the inclusion of minorities and women in contracting and 

hiring for the year, and other relevant information, including the agency’s financial 

institutions diversity and contractors’ workforces fair inclusion programs and activities 

supporting financial access, economic inclusion, and financial literacy. Consistent 

with the provisions of Section 342 of the DFA, the FDIC continues to enhance its longstanding commitment to promote diversity and inclusion in employment opportunities 

and all business areas of the FDIC. This report outlines both accomplishments and 

challenges in contracting and hiring as the agency works to ensure that these efforts 

are reflected in its operations.
2 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

INTRODUCTION

Commitment to Diversity and Inclusion

The mission of the FDIC is to preserve and promote public confidence in the 

U.S. financial system by insuring deposits, examining and supervising financial 

institutions for safety and soundness and consumer protection, making large and 

complex financial institutions resolvable, and managing receiverships. OMWI is 

an important component in these efforts and supports the FDIC’s mission through 

the pursuit of equal employment opportunity, affirmative employment initiatives, 

diversity and inclusion, and outreach efforts to ensure the fair inclusion and 

utilization of minority- and women-owned businesses, law firms, and investors in 

contracting and investment opportunities. OMWI works closely with other FDIC 

organizations, divisions, and offices to carry out these important responsibilities and 

realize program accomplishments. 

When the FDIC Board of Directors established OMWI in 2011, the Board also 

established the FDIC Diversity and Inclusion Executive Advisory Council (EAC), to 

promote the Chairman’s goal of a culture of diversity and inclusion. The EAC is chaired 

by the FDIC Deputy to the Chairman and Chief Operating Officer and membership 

includes the OMWI Director, FDIC division and office directors, and other key FDIC 

senior staff. The EAC assists and advises decision-makers throughout the FDIC, 

working with OMWI, in connection with all diversity and inclusion efforts. 

The Chairman’s Diversity Advisory Council (CDAC), consists of FDIC employees that 

serve as a means for employees to communicate to management on broad-based 

diversity concerns and issues. The CDAC consists of regional and area councils. The 

chair of each regional council serves on the Executive CDAC. The Executive CDAC 

advises the FDIC Chairman through the OMWI Director on diversity and inclusion 

issues and concerns raised by employees. This structure provides FDIC leadership 

with a bottom up perspective on diversity and inclusion and promotes employee 

engagement. The issues with proposed recommendations are presented to the EAC 

and then distributed to the divisions and offices for review. Following this review 

process OMWI collaborates with the EAC on proposed actions to address each of the 

recommendations. Through the CDAC FDIC leverages the differences and strengths 

of all employees to create a more inclusive work environment. 

The FDIC’s ability to fulfill its mission is due in large-part to the commitment and 

dedication of the FDIC workforce. While there has been an uptick in retirements 

the FDIC continued its commitment to diversity and inclusion for recruiting and 

retaining the most qualified, talented, and motivated employees in the labor market. 

During 2019, FDIC implemented structural changes to the entry level-examiner hiring 

program to further strengthen the ability to attract, retain, and advance a diverse 

pool of candidates. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 3

INTRODUCTION

Also in 2019, the FDIC continued to award a high percentage of contract work to 

minority- and women-owned businesses, law firms, and diverse attorneys despite the 

downward trend in contracting activity. This successful outreach to majority-minority 

professional and trade organizations was conducted to expand the pipeline of qualified 

vendor sources. In addition, the FDIC continued to monitor and report on procurement 

strategies and MWOB contracting initiatives at regular EAC meetings attended by 

senior managers from FDIC divisions and offices. 

Further, the FDIC continued to promote the economic inclusion of minority-majority 

communities through initiatives aimed at providing greater transparency to the public 

on performance, and reducing unnecessary regulatory burdens for community banks. 

The FDIC leadership is engaged in efforts to promote increased focus on low- andmoderate income communities through expanded engagement through Community 

Reinvestment Act technical assistance and Minority Depository Institutions so they 

are in a better position to serve their communities. Also, the FDIC continued outreach 

efforts to promote the safe adoption of additional products and services to bring 

underserved communities more fully into the banking mainstream. 

2019 Diversity and Inclusion Initiatives

The FDIC is committed to continually providing all employees with a work environment 

that promotes excellence and acknowledges and honors the diversity of its employees. 

In 2019 the FDIC initiated the process to update its Diversity and Inclusion Strategic 

Plan (D&I Strategic Plan). The updated plan will cover a three-year period from 2020 

through 2022. It includes embedding diversity and inclusion into the agency’s policies, 

practices, and procedures, aligning with business goals, and increasing management 

accountability at all levels. As in the past, the EAC will oversee the implementation of 

the plan and ensure that the FDIC’s commitment to diversity and inclusion remains a 

top priority. 

Annually, each FDIC division and major office assesses available workforce data and 

produce plans with strategies intended to further their diversity progress and address 

any issues. These plans are consolidated into an FDIC Plan to promote diversity and 

inclusion through increased engagement with divisions and major offices. During 

2019, OMWI met with each FDIC division to review diversity and inclusion statistics 

and discuss methods to accomplish planned actions moving forward.
4 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

INTRODUCTION

In recognition of the FDIC’s 2019 diversity and inclusion accomplishments, the 

following initiatives are highlighted:

§ The FDIC and National Treasury Employees Union (NTEU) reached an agreement 

regarding a new Compensation Agreement, which includes six weeks of paid 

parental leave for the birth, adoption, or foster care of a child. The CDAC played a 

critical role in bringing this issue to light for FDIC management during its briefing to 

the FDIC Chairman and EAC members in 2018. 

§ The FDIC continued to support and encourage the formation of Employee Resource 

Groups (ERGs). The ERGs are networks of employees with similar interests, 

shared characteristics or life experiences, whose goals and objectives facilitate the 

creation and maintenance of a work environment that recognizes, appreciates, and 

encourages the utilization of the talents, skills, and perspectives of all employees in 

the achievement of the FDIC’s mission.

§ The FDIC monitored completions of Diversity 101 online training implemented in 

2018, and as of the end of 2019 achieved a completion rate of over 50 percent. The 

OMWI Director recorded a video message posted on the intranet and “Lunch and 

Learn” sessions were held to encourage training completion. 

§ FDIC enhanced its commitment to diversity and inclusion (D&I) through engaging 

external D&I consulting support and training services. 

§ A few FDIC Divisions began utilizing D&I vendor’s services to train their managers 

and supervisors on unconscious bias and micro-inequities.

§ The biennial CDAC Training Conference was held in Arlington, Virginia, and 

participants included CDAC members from headquarters, regional, and area offices. 

The D&I training topics included emotional intelligence, unconscious biases and 

micro-inequities, and engaging everyone in diversity and inclusion. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 5

FDIC CONTRACTING: 

Inclusion of Minority- and Women-Owned 

Businesses (MWOBs)

The FDIC places a high priority on achieving diversity in all business activities 

including contracting. OMWI is an integral part of the contractor solicitation, education, 

and evaluation process through conducting outreach and market research to identify 

qualified MWOBs for contracting opportunities with the FDIC. Through partnerships 

with trade organizations, OMWI has expanded its pipeline to identify MWOB firms for 

requirements. For 2019, FDIC awarded 152 contracts to MWOB firms with a total value 

of $173.5 million or 31.3 percent of all new awards.

During 2019, the FDIC implemented new contracting initiatives and conducted 

focused outreach which improved MWOB participation in its contracting activities. 

As a result of the FDIC’s outreach engagement, the corporation continued to award 

a high percentage of contracts to MWOB firms. Despite, challenges faced by the 

FDIC in increasing the utilization and growth rates for MWOB contractors because 

new contract awards have been declining since the height of the financial crisis and 

non-financial goods and services contracts for recurring needs represent a larger 

percentage of FDIC contracts. The FDIC will continue to analyze future contracting 

needs to determine where MWOB opportunities may exist and if new procurement 
6 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

strategies can be used to maximize MWOB participation. The following sections 

provide detailed information on the 2019 contracting activities and successes; 

contracting initiatives, programs, and outreach; and challenges the FDIC faces in 

increasing MWOB participation in its contracting activities.

Contracting Activities and Successes

1 See www.fdic.gov/about/diversity/mwop/index.html.

2 See www.fdic.gov/about/diversity/sbrp/

FDIC Procurement Policies

The FDIC’s contracts are typically awarded through a competitive, best-value 

solicitation process that involves consideration of both the offeror’s technical and price 

proposals. The solicitations describe what offerors must include in their proposals 

and the proposal evaluation criteria specific to the good or service being procured. 

Proposals are evaluated and rated by a panel of FDIC subject matter experts and may 

include an OMWI representative. Awards are made to the offeror that provides the 

best value to the FDIC.

For any contract over $100,000, OMWI review is required to identify competitive 

minority- and women-owned businesses to include in contract solicitations. As part 

of this process, OMWI uses the FDIC’s Contractor Resource List (CRL) that includes 

registered MWOBs. The CRL is the principal database for vendors interested in doing 

business with the FDIC. OMWI also identifies qualified MWOBs through outreach, the 

System for Award Management, and the Minority Business Development Agency. This 

process helps ensure that a diverse pool of contractors is solicited and considered for 

each major contract.

The FDIC’s website1 provides extensive information, announcements, and technical 

assistance for minority- and women-owned businesses, law firms, and investors 

seeking to do business with the FDIC. The FDIC also has a small business resource 

page that contains about 40 learning modules2 and is a technical assistance aid and 

self-assessment for businesses interested in competing for contract opportunities.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 7

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

Contract Payments with MWOBs

The FDIC paid $466.6 million to contractors in 2019 under 1,162 contracts, of which 

$98.3 million (21.1 percent) was paid to MWOBs under 287 contracts. [See Figure 1.] 

By comparison, the FDIC paid $429.6 million to contractors under 1,299 contacts in 

2018; $414.0 million to contractors under 1,537 contracts in 2017; $415.2 million to 

contractors under 1,786 contracts in 2016; and $507.2 million to contractors under 

2,029 contracts in 2015. The 2019 total payments (i.e., spend) to contractors included 

payments for contracts awarded in 2019 and payments for active contracts awarded 

prior to 2019.

Figure 1 Contracting Payments (in millions)

2015 2016 2017 2018 2019

Total $507.2 $415.2 $414.0 $429.6 $466.6

100.0% 100.0% 100.0% 100.0% 100.0%

MWOB $142.5 $111.5 $109.6 $98.0 $98.3

28.1% 26.8% 26.5% 22.8% 21.1%

Minority Owned (MO) $89.3 $56.0 $54.6 $49.5 $54.0

17.6% 13.5% 13.2% 11.5% 11.6%

Women Owned (WO) $83.2 $66.8 $66.9 $59.5 $52.0

16.4% 16.1% 16.2% 13.9% 11.2%

Overlap (Both MO & WO) $30.0 $11.3 $11.9 $11.1 $7.7

5.9% 2.8% 2.9% 2.6% 1.7%

Asian American $39.9 $33.5 $30.1 $28.8 $31.5

7.9% 8.1% 7.2% 6.7% 6.8%

Black American $13.3 $11.5 $14.2 $9.5 $6.2

2.6% 2.8% 3.4% 2.2% 1.3%

Hispanic American $25.1 $10.3 $9.5 $ 8.4 $12.0

5.0% 2.5% 2.3% 2.0% 2.6%

Native American

$0.1 $0.1 $0.2 $2.2 $3.9

0.0% 0.0% 0.1% .05% 0.8%

For purposes of contract payment information, the FDIC considers an active contract 

one in which payments were made or credits applied in the same year. In 2019, 

minority-owned firms were paid $54.0 million of the total dollars paid to MWOB 

contractors (11.6 percent). Women-owned firms were paid $52.0 million of the total 

dollars paid to contractors (11.2 percent). These two categories – minorities and 

women – are not mutually exclusive since $7.7 million (1.7 percent) was paid in 2019 

to businesses classified as both minority-owned and women-owned. The FDIC paid 

MWOBs $98.0 million (22.8 percent) of the total paid to all contractors in 2018 under 

299 contracts; $109.6 million (26.5 percent) of the total paid to all contractors in 2017 
8 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

under 354 contracts; $111.5 million (26.8 percent) of the total paid to all contractors 

in 2016 under 461 contracts; and $142.5 million (28.1 percent) of the total paid to all 

contractors. 

In 2019, the FDIC awarded 152 contracts to MWOBs out of a total of 518 issued (29.3 

percent). [See Figure 2.] By comparison, the FDIC awarded 166 contracts (29.4%) to 

MWOBs out of a total of 565 issued in 2018; 210 contracts (28.5 percent) to MWOBs out 

of a total of 737 issued in 2017; 287 contracts (24.3 percent) to MWOBs out of a total of 

1,181 issued in 2016; and 346 contracts (29.9 percent) to MWOBs out of a total of 1,159 

issued in 2015.

Figure 2 Contracting Actions

2015 2016 2017 2018 2019

Total

1159 1181 737 565 518

100.0% 100.0% 100.0% 100% 100.0%

MWOB

346 287 210 166 152

29.9% 24.3% 28.5% 29.4% 29.3%

Minority Owned (MO) 148 142 100 87 68

12.8% 12.0% 13.6% 15.4% 13.1%

Women Owned (WO) 243 187 151 119 112

21.0% 15.8% 20.5% 21.1% 21.6%

Overlap (Both MO & WO) 45 42 41 40 28

3.9% 3.5% 5.6% 7.1% 5.4%

Asian American

56 62 63 54 33

4.8% 5.2% 8.6% 9.6% 6.4%

Black American

35 24 22 11 15

3.0% 2.0% 3.0% 1.9% 2.9%

Hispanic American

39 48 4 11 9

3.4% 4.1% 0.5% 1.9% 1.7%

Native American

1 2 7 6 5

0.1% 0.2% 1.0% 1.1% 1.0%

Other

17 6 4 5 6

1.5% 0.5% 0.5% 0.9% 1.1%

As of December 31, 2019, the FDIC had 256 (22.3 percent) active contracts with MWOBs 

out of a total of 1,150 active contracts. The active contracts to MWOB firms by category 

were as follows: Asian American (68), Black American (24), Hispanic American (20), 

Native American (8), and Women (180). These include contracts awarded to firms that 

were both minority-owned and women-owned.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 9

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

Contract Awards to MWOBs

The FDIC awarded contracts with a combined value of $554.0 million in 2019, of 

which $173.5 million (31.3 percent) were awarded to MWOBs. By comparison, the 

FDIC awarded contracts with a combined value of $499.5 million in 2018, with $122.5 

million (24.5 percent) awarded to MWOBs; $523.7 million in 2017, with $96.7 million 

(18.5 percent) awarded to MWOBs; awarded contracts with a combined value of $508.8 

million in 2016, with $93.9 million (18.5 percent) awarded to MWOBs; and awarded 

contracts with a combined value of $858.4 million in 2015, with $211.6 million (24.7 

percent) awarded to MWOBs. [See Figure 3.]

Figure 3 Total Contract Dollar Awards

2015 2016 2017 2018 2019

Total $858.4 $508.8 $523.7 $499.5 $554.0

100.0% 100.0% 100.0% 100.0% 100.0%

MWOB $211.6 $93.9 $96.7 $122.5 $173.5

24.7% 18.5% 18.5% 24.5% 31.3%

Minority Owned (MO) $145.2 $56.5 $66.7 $45.8 $106.0

16.9% 11.1% 12.7% 9.2% 19.1%

Women Owned (WO) $104.2 $47.4 $46.2 $83.0 $75.8

12.1% 9.3% 8.8% 16.6% 13.7%

Overlap (Both MO & WO) $37.8 $10.0 $16.2 $6.3 $8.3

4.3% 1.9% 3.0% 1.3% 1.5%

Asian American $51.8 $25.0 $31.2 $33.9 $83.1

6.0% 4.9% 6.0% 6.8% 15.0%

Black American $30.7 $9.4 $32.7 $1.9 $5.8

3.6% 1.9% 6.2% 0.4% 1.0%

Hispanic American $43.2 $20.6 $1.6 $7.0 $13.3

5.0% 4.0% 0.3% 1.4% 2.4%

Native American $- $0.1 $0.9 $2.9 $3.5

0.0% 0.0% 0.2% 0.6% 0.6%

Other

$19.5 $1.4 $0.3 $0.1 $0.3

2.3% 0.3% 0.0% 0.0% 0.1%

The FDIC’s five-year trend from 2015 – 2019 of contract awards and payments can be 

found at Appendix A.
10 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

Contract Awards by North American Industry Classification 

System

The North American Industry Classification System (NAICS) was developed by 

the Office of Management and Budget (OMB) and is the standard used by federal 

statistical agencies in classifying business establishments for the purpose of 

collecting, analyzing, and publishing statistical data related to the U.S. business 

economy. The FDIC awarded contracts in 2019 under 68 different NAICS codes. Figure 

4 depicts the FDIC’s 2019 contracts categorized for the top ten NAICS codes and 

percentage of the total award value ($554.0 million). 

Figure 4 FDIC 2019 Contracts by Top Ten NAICS Codes Figure 4 FDIC 2019 Contracts by Top Ten NAICS Codes

Software Publishers

511210 

10%

 

Other Computer 

Related Services

541519 

14%

Computer Systems 

Design Services 

541512

21%

Custom Computer

 Programming Services

541511

6%

Commercial Banking

522110 

8%

Facilities Support Services

561210 

5%

Electronic Computer 

Manufacturing

334111 

5%

Adminstrative Management

and General Management 

Consulting Services

541611 

10%

Security Guards and 

Patrol Services

561612 

18%

Internet Publishing and 

Broadcasting and 

Web Search Portals 

519130

3%

In 2019, these awards consisted of the following: 21 percent for computer systems 

design services; 18 percent for security guards and patrol services; 14 percent for 

other computer related services; 10 percent for administrative management and 

general management consulting services; and 10 percent for software publishers. 

The remaining 27 percent – each eight percent or under – was awarded in the areas 

of commercial banking (eight percent); custom computer programming services (six 

percent); facilities support services (five percent); electronic computer manufacturing 

(five percent); and internet publishing and broadcasting and web search portals (three 

percent). Collectively, 32.9 percent of the top ten NAICS code contracts were awarded 

to MWOBs. [See Figure 5.]
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 11

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

Figure 5 2019 Contract Awards by Top 10 NAICS

Non-MWOB

67.1% 

MWOB

32.9% 

The 2019 FDIC contract awards associated with the top ten NAICS codes can be found 

in Appendix B.

Legal Contracting Diversity 

The Legal Division’s legal contracting program endeavors to maximize the 

participation of both minority- and women-owned law firms (MWOLFs) and minority 

and women partners and associates employed at majority owned firms (Diverse 

Attorneys) in legal contracting. This approach is consistent with the provisions of 

Section 342 of the DFA that encourages diversity and inclusion at all levels. FDIC legal 

matters provide important learning and professional client development opportunities 

to MWOLFs and Diverse Attorneys that can be quite meaningful to career 

advancement. In 2019, FDIC paid $10.8 million to MWOLF firms and Diverse Attorneys 

combined, out of a total of $31.7 million dollars paid to outside counsel. As a result, 

the Legal Division has an aggregate 34.0 percent diversity and inclusion participation 

rate in legal contracting for the year 2019. [See Figure 6.] This number represents 

a significant increase from 2018, in which there was a 26.5 percent aggregate 

participation rate, despite the decline in overall outside counsel spending. 
12 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

Figure 6 2019 Participation Rate of MWOLFs and Diverse Attorneys 

 (in Millions) 

$20.9 

66.0% 

$10.8

34.0% 

MWOLFs and Diverse Attorneys Non-MWOLFs

Referrals to Minority and Women Owned Law Firms 

Referrals to law firms are typically made on a competitive basis. Price, expertise, 

capacity, and diverse status are among the criteria considered in making the 

selections. The FDIC made 62 referrals to outside counsel in 2019, of which 20 (32.3 

percent) were to MWOLFs, compared to a total of 104 referrals, of which 29 (28 

percent) were to MWOLFs in 2018. Referrals to MWOLFs in 2019, by category, were as 

follows: Black American – 1 (1.6 percent), Hispanic American – 12 (19.4percent), Native 

American – 1 (1.6 percent), and Women – 6 (9.7 percent) [See Figure 7.]

Figure 7 2019 Number of Referrals to MWOLFs by Category

Non-MWOLF 39

62.9%

Black 1

1.6%

Hispanic 12

19.4%

Native American 1

1.6%

Women 6

9.7%

Non-Reported 3

4.8%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 13

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

Bank resolution activities are a major source of outside counsel work, and that 

activity continued a downward trend in 2019. The decrease in bank resolution activity 

is consistent with the overall decline in FDIC fees spent on outside counsel since 

the near peak levels in 2014. [See Figure 8.] In 2019, the FDIC paid $31.7 million to 

outside counsel, as compared to $48.0 million in 2018. The FDIC paid $3.4 million to 

MWOLFs in 2019, which represents 10.7 percent of the total fees paid to all law firms. 

Notwithstanding the overall decline in bank resolution activities, the 2019 percentage of 

fees paid to MWOLFs is above that of 2018, during which the FDIC paid a total of $3.7 

million to MWOLFs, which was 7.7 percent of the total paid to all law firms that year. 

Figure 8 Historical Trend: Payments to Law Firms (in Millions)

$3.4

$28.3 

2019

$31.7

$3.4 $-

 $20.0

 $40.0

 $60.0

 $80.0

 $100.0

 $120.0

 $140.0

MWOLFs Non-MWOLFs

$11.7 $11.1 $3.7 

 $86.7 

 $65.7 

 $55.0 

 $44.3 

2015 2016 2017 2018

$98.4 

$61.5 

$48.0

$76.8

$6.5 $3.7 

Despite the corresponding decline in the absolute number of referrals to all outside 

counsel in 2019 (from 104 in 2018 to 62 in 2019), there was an increase in the 

percentage of referrals to MWOLF firms in 2019 over 2018 (32.3 percent versus 28 

percent in 2018). FDIC maintains a long-term commitment to increasing the level of 

referrals and fees paid to MWOLFs and Diverse Attorneys in 2020 and beyond. The 

Legal Division remains alert to changing circumstances, as well as diversity and 

inclusion leading practices and periodically recalibrates its outreach efforts to account 

for the same.

Referrals to Diverse Attorneys 

Section 342 of the DFA encourages the FDIC to develop and implement standards and 

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

of minorities and women in contracting at all levels. Another benefit of FDIC’s diversity 

and inclusion efforts in legal contracting is the training and professional development 

opportunities afforded minority and women partners and associates who work on 
14 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

FDIC legal matters that are referred to majority owned law firms. The employment and 

training of individual Diverse Attorneys contributes significantly toward enhancing 

diversity and inclusion in the legal profession by providing opportunities for drafting 

legal documents, entering court appearances, and developing client relationships, all of 

which further the partnership potential of Diverse Attorneys. 

In 2019, Diverse Attorneys at majority- owned law firms billed $7.4 million on FDIC 

legal matters or 23.3 percent of total payments to outside counsel. [See Figure 9.] 

Despite the Legal Division’s diminishing annual expenditures on outside counsel 

services, FDIC referrals to outside counsel offer a consistently high level of learning 

and professional development opportunities to both MWOLFs and Diverse Attorneys. 

The Legal Division will continue to promote this participation and monitor these fees in 

addition to those fees paid to MWOLF firms.

Figure 9 2019 Fees Billed by Diverse Attorneys at Majority Law Firms 

 (in Millions) 

$7.4

23.3% 

$24.3

76.7%

Diverse Attorneys Non-Diverse Attorneys

Outreach to MWOLFs and Diverse Attorneys

The cornerstone of the Legal Division diversity and inclusion outreach is the FDIC’s 

partnerships with minority bar associations and specialized stakeholder organizations. 

In 2019, the FDIC Legal Division participated in seven minority bar association 

conferences and three stakeholder events in support of maximizing the participation 

of MWOLFs and Diverse Attorneys in FDIC legal contracting. The Legal Division 

divided its stakeholder event participation into 1) events concentrating on outreach to 

MWOLFs; 2) events focusing on outreach to Diverse Attorneys who work at majority 

owned law firms; and 3) events geared to the recruitment of individual diverse 

attorneys to join the FDIC workforce.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 15

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

The Legal Division recognizes the value of integrating FDIC in-house attorneys in 

its legal contracting diversity and inclusion program activities. Therefore, the Legal 

Division makes a conscious effort to include FDIC attorneys in external outreach 

events such as bar association conferences and stakeholder meetings in order to 

make its outreach encounters more meaningful. In 2019, the National Association 

of Minority and Women Owned Law Firms (NAMWOLF) again formally recognized 

the FDIC as a principal member of, and major contributor to, its Inclusion Initiative, 

a collaborative program among law departments of major corporations designed to 

increase the participation of MWOLF firms in legal contracting. The FDIC participates 

in the Inclusion Initiative along with major corporations. The Legal Division and OMWI 

participated in and sponsored NAMWOLF’s National Conference.

The Legal Division’s objective is to promote diversity and inclusion in its legal 

contracting opportunities by producing measurable results. In 2019 the Legal 

Division continued to work closely with in-house attorneys in areas that account for 

a substantial dollar amount of legal referrals and posed the greatest opportunities 

for MWOLF and Diverse Attorney participation. The Legal Division held a Diversity 

and Inclusion in Legal Contracting Outreach Workshop in the FDIC Dallas Regional 

Office for in-house FDIC attorneys, who assign work to outside counsel. The program 

included a review of the prior year’s diversity statistics, planned projects, questions 

and answers, and the solicitation of ideas from the attorneys for improving the 

selection and retention of outside counsel.

The Legal Division evaluated and approved three new MWOLF applications in 2019. 

Firms from various geographic areas were added to the FDIC List of Counsel Available 

in order to be eligible to receive legal contracting work. In addition to the outreach 

efforts noted above, the Legal Division continues to provide technical assistance to 

other related government agencies on developing diversity and inclusion outreach 

programs that mirror FDIC’s program. 

Legal Division Diversity and Inclusion Assessments

Pursuant to Section 342 of the DFA, which requires an assessment of legal contractors’ 

internal workforce diversity practices, the Legal Division refined and continued to 

implement a system of compliance reviews of the top billing law firms (both majorityowned and MWOLFs). This program provides the Legal Division with an additional 

means to address diversity and inclusion and provides opportunities for minority and 

women attorneys seeking to provide services. These on-site assessment visits are 

designed to engage firms in discussions about diversity leading practices, staffing 

concepts, metrics and the Legal Division’s diversity and inclusion program. The 

assessment results continue to show progress toward increase diversity and inclusion. 

In addition to collecting baseline diversity metrics, the FDIC’s Legal Division remains 

abreast of innovative diversity strategies, new opportunities for inclusion, pursuant to 
16 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

this program. Further, the Legal Division obtained commitments with various firms to 

increase diverse staffing on FDIC legal matters. 

As a result of the assessments, the FDIC Legal Division enjoys open dialogue and 

transparency with external law firms on their diversity and inclusion practices. 

One noteworthy practice firms routinely engage in is supporting diversity pipeline 

programs such as the Leadership Council on Legal Diversity to strengthen the number 

of diverse law students entering the legal profession. Another noteworthy practice 

is firms are establishing scholarship programs geared toward assisting diverse law 

students pay for school. In addition, FDIC has noted diverse associates have entered 

the law firm partnership ranks as a result of having worked on FDIC legal matters. 

Contracting Initiatives, Programs and Outreach

The FDIC awarded 518 new contracts with a combined value of $554.0 million in 

2019. The number of new contracts awarded in 2019 represents the fewest number of 

awarded contracts by the FDIC since 2008. The total contract award dollars in 2019 of 

$554.0 million represents the fourth consecutive year the FDIC has awarded less than 

$600 million in new contracts. The FDIC awarded an average of 1,762 contracts with 

a combined average value of $1.9 billion on an annual basis from 2009-2012 during 

the height of the financial crisis when 440 banks failed during this period. As stated 

in prior reports, the FDIC annual contract awards have fallen dramatically since the 

height of the financial crisis due to a significant reduction in annual bank failures. 

During the financial crisis, contracts related to services required to resolve failed banks 

represented up to 85 percent of all FDIC contract dollars awarded in a given year. In 

2019, only 15.6 percent of FDIC total contract dollars awarded supported the FDIC’s 

Division of Resolutions and Receiverships (DRR) in their mission to resolve failed 

banks. Despite reduced contract awards in 2019, 29.3 percent of all new contracts and 

31.3 percent of all new contract dollars were awarded to MWOBs.

With fewer bank failure related contracts, FDIC continues to focus on identifying 

contracting opportunities for MWOBs in non-financial goods and services 

requirements. For example, contracts were awarded to MWOBs in the following areas: 

Information Technology (IT) consulting, software development and maintenance 

services; audit and risk management services; IT hardware, software and maintenance; 

training services; facilities management services; emergency preparedness services; 

construction management services; translation services; diversity consulting and 

training services.

Since 2015, the FDIC has continued its strategy to re-bid the financial services 

contracts as they expire to ensure contractor resources are in place when needs arise 

and to maintain a constant state of readiness. Although, there were only four bank 

failures in 2019, the FDIC continued to include MWOBs in the procurement process for 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 17

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

these contract opportunities that arose. Several of the contracts used to perform failed 

bank resolution services expired in 2019.

MWOB contractors were instrumental to the FDIC’s success during the financial crisis. 

As a result, the FDIC focused on ensuring MWOB participation in the re-competition of 

these expiring contracts, as well as contracts for financial services that previously were 

not required. MWOB firms were awarded new contracts in 2019 for real estate services 

and accounting services that will be used to support future bank failures. Additional 

existing failed bank resolution contracts will expire in 2020 and beyond. The FDIC will 

continue to identify opportunities to include MWOBs in the re-competition of these 

mission critical services. In addition, the FDIC continued to award task orders to MWOBs 

under existing contracts in 2019 to support 2019 bank failures, planning for future bank 

failures and for services to resolve bank failures from prior years.

In 2019, the FDIC also strategically used the 8(a) set-aside program to award seven 

contracts with a combined value of $15.4 million to 8(a) MWOBs. Three of these 

contracts were for critical IT business intelligence services and amounted to $9.3 

million. The other four contracts involved IT support services and proofreading of 

translated material. 

The FDIC has also focused on soliciting MWOB firms as prime contractors that were 

once subcontractors to larger firms under FDIC contracts once they have gained 

valuable experience as a subcontractor. Throughout the last several years this 

strategy has resulted in many former MWOB subcontractors becoming FDIC prime 

contractors providing critical facilities management services, IT services and bank 

closing related services. 

The FDIC continued to discuss procurement strategies and MWOB contracting 

initiatives at regular EAC meetings attended by senior managers from FDIC divisions 

and offices. The FDIC also continued to implement the recommendation to hold 

pre-proposal conferences to ensure businesses understand the FDIC’s requirements 

before a solicitation is issued and to give smaller businesses opportunities to find 

partners and develop teams before submitting bids.

Information Technology Contracting

The FDIC recognized in 2012 that the declining number of bank failures would result in 

a significant shift in new contract award opportunities from bank resolution contracts 

to contracts for daily operations (e.g., IT software development and maintenance, 

facilities management, etc.). The FDIC conducted focused market research in 2012 

to ensure significant MWOB participation in the then upcoming $546.8 million 

competitive Basic Ordering Agreement (BOA) for the second generation Information 

Technology Application Services (ITAS II) contract which was awarded in 2013. In 
18 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

2016, additional firms were competitively added to the ITAS II BOA. Currently, seven 

of the 14 firms (50 percent) under the ITAS II BOA are MWOBs. Only one in four firms 

(25 percent) under the prior ITAS I BOA was an MWOB. The assignment of work to 

contractors under the ITAS II BOA is accomplished through the award of task orders 

that are competed among the contractors awarded the BOA. Nine of the 23 task orders 

awarded under ITAS II in 2019 were awarded to MWOBs with a combined value of 

$56.8 million. This represented 39.1 percent of the total task orders awarded and 42.0 

percent of the $135.3 million in total task order dollars awarded. The services provided 

under the task orders awarded to MWOBs in 2019 were for mission critical services to 

develop, maintain and enhance the FDIC’s IT systems.

ITAS II is not the only contract that supports the FDIC’s IT program. During 2019, FDIC 

made the strategic decision to develop certain identified mission critical new systems 

on a common platform. A $15.5 million contract was awarded to an MWOB firm to 

establish the new common platform and an $18.0 million contract was awarded to the 

same MWOB firm to build one of the mission critical systems on the new common 

platform. Other IT contracts awarded to MWOB firms in 2019 included a $12.7 million 

contract for audit and risk management support services; three contracts totaling 

$7.9 million for business intelligence services; and a $1.9 million contract for IT 

lifecycle consulting services. Lastly, FDIC continues to recognize that IT hardware and 

software can often be provided by resellers certified by the manufacturer or by MWOB 

manufacturers. As a result, the FDIC continued with the strategic decision to solicit 

MWOBs for hardware and software purchases when possible. This strategy resulted in 

89 contract awards to MWOBs with a combined value of $19.1 million.

Facilities Management and Security Services

Significant awards to MWOBs in facilities management and security services included 

contracts valued at $1.9 million for emergency preparedness services; $1.8 million for 

elevator maintenance services; and $690,092 for construction management services.

In addition, the FDIC continued to provide opportunities to MWOBs for both new and 

replacement furniture. In total, three contracts with a combined value of $678,927 were 

awarded to MWOBs to provide furniture for FDIC locations nationwide.

Bank Resolution Contracts

There were only four bank failures in 2019, but there are still many active failed bank 

receiverships from prior year bank failures. The FDIC continued to award contracts 

and task orders to MWOBs to provide required services to resolve 2019 bank failures, 

required services for active receiverships and planning services for future bank 

failures. In 2019, 30 contracts and task orders with a combined value of $30.4 million 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 19

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

were awarded to MWOBs to provide the required financial services to support FDIC’s 

bank failure processes. Contracts awarded to MWOBs included, but were not limited 

to: accounting services; receivership assistance services; business and IT development 

support services; data and media disposition; owned real estate; temporary staffing 

services; appraisal services; imaging and indexing services; asset sales; asset 

valuation services; environmental services; tax services and furniture, fixtures and 

equipment auctions.

Other Significant MWOB Contract Awards

Recognizing the need to expand MWOB contract awards beyond services for bank 

resolutions, information technology, and facilities management, the FDIC looked 

for MWOB opportunities in other program areas. The FDIC’s Corporate University 

awarded four contracts with a combined value of $302,480 to MWOB firms to provide 

learning and curriculum development services. The FDIC’s Division of Depositor and 

Consumer Protection awarded a contract valued at $110,000 to an MWOB firm to 

provide translation services. The Office of Inspector General awarded two contracts 

with a combined value of $4.1 million to MWOB firms for IT support services and 

a culture change study. The Office of Minority and Women Inclusion awarded four 

contracts with a combined value of $94,559 for diversity services.

Outreach to MWOBs

In 2019, the FDIC participated in a combined total of 18 business expos, 6 one-onone matchmaking sessions, and 4 panel presentations. The FDIC and other OMWI 

agencies presented as panelists during various procurement events including the 

National 8(a) Small Business Conference and the Annual Government Procurement 

Conference, educating attendees about doing business with the agencies. 

Additionally, the FDIC’s Division of Administration, Acquisition Services Branch, 

attended eight MWOB procurement events. At the various outreach events, the 

FDIC staff provided information and responded to inquiries regarding the FDIC’s 

business opportunities for minorities and women. In addition to targeting MWOBs, 

Minority and Women Owned Investors, and MWOLFs, these efforts also targeted 

veteran-owned and small disadvantaged businesses. Vendors were also provided 

with the FDIC’s general contracting procedures and encouraged to register through 

the FDIC’s CRL.

On December 5, 2019, the FDIC and the other OMWI agencies partnered with the 

Minority Business Development Agency and the Northern Virginia Procurement 

Technical Assistance Center to host the “Connections That Count” technical assistance 

event. The event was held at George Mason University, in Arlington, Virginia. Opening 

remarks were provided by FDIC’s Deputy to the Chairman and Chief Operating Officer 

and the FDIC OMWI Director. Technical assistance events are designed to provide 
20 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

information, resources, and tools to MWOBs in order to build and expand federal 

contracting opportunities. Event highlights included sessions on how to create 

winning teaming arrangements and former small businesses sharing tools of success 

for growing business. The featured presenters’ topics were Strategies for Successful 

Teaming, Blueprint for Growth, and Harvesting Low Hanging Fruit in the Federal 

Sector. Networking time was allotted for attendees to promote their firms’ technical 

services to the OMWI Agencies and the Resource Partners. Overall vendor feedback on 

the event was positive, narrative comments indicated attendees thought the session 

topics provided valuable insights on the government procurement vehicles; and 

leading practices to enhance their teaming approach. There were 138 attendees at this 

event. 

FDIC Asset Sales

In its role as receiver, the FDIC Division of Resolution and Receivership manages and 

sells retained bank assets acquired from failed financial institutions. The assets are 

sold and proceeds used to pay out depositors and replenish the deposit insurance 

fund. To promote MWOB participation in FDIC asset sales DRR in collaboration 

with OMWI host asset purchaser events. These events are marketed extensively to 

minority- and women-owned investors and companies to raise the awareness and 

provide information on how to purchase owned real estate (ORE) through DRR’s 

Owned Assets Marketplace and Auctions Program, as well as other loans and ORE 

assets from the FDIC, through cash loan sales and structured transactions. These 

events are generally held in association with failed bank activity. There were no events 

held in 2019, as there were few bank failures, and the Assuming Institutions which 

purchased the failed bank franchises also bought nearly all of the assets.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 21

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

Challenges

As noted earlier, the FDIC’s annual number of new contracts awarded and total 

contract dollars awarded continues to be significantly lower than during the height of 

the financial crisis due to the significant reduction in the number of bank failures. From 

2009 to 2012, the FDIC’s annual contract awards ranged between $1 billion and $2.6 

billion. During this timeframe, up to 85 percent of all contract dollars awarded annually 

supported bank failure activity. The FDIC has had great success in awarding contracts 

to MWOBs for bank failure activity as evidenced by the fact that 28.1 percent of the $9.1 

billion in contracts awarded in this area since 2007 have been to MWOBs.

In 2019, total FDIC contract dollars awarded were $554.0 million, which represented 

the fourth consecutive year the total value of new contracts awarded was less than 

$600 million and the 518 contracts awarded were the fewest contracts awarded since 

2008. With only four bank failures, only 15.6 percent of contract dollars awarded 

supported bank failure activity. Non-financial goods and services contracts for 

supporting daily operations are continuing to represent a larger percentage of the 

FDIC’s annual contracts.

The FDIC recognized several years ago that with a declining need for financial services 

contracts, the FDIC would need to explore MWOB opportunities in other areas. One 

of the major areas the FDIC has focused on has been contracts for IT goods and 

services. The majority of the FDIC’s contract dollars awarded (57 percent) in 2019 were 

for IT goods and services. As a result of the creative ITAS II BOA strategy previously 

discussed, a focused approach on hardware/software purchases and strategies 

developed for new contracts awarded in 2019, the FDIC awarded 35.8 percent of all IT 

contracts and 44.5 percent of all IT contract dollars to MWOBs in 2019.

Despite the FDIC’s MWOB success in IT contracts and financial services contracts, 

there are a few areas the FDIC has had limited success. The FDIC has several 

large contracts for employee benefits (dental, life and vision insurance) and the 

management of the FDIC’s student residence center and cafeterias. The FDIC has 

conducted expanded and targeted market research and explored new procurement 

strategies in these areas, but so far, the FDIC has had limited success with these 

requirements. Unfortunately, these contracts often make up a disproportionate 

share of the ceiling value of FDIC contracts. In addition, due to the FDIC’s corporate 

structure with over 80 offices nationwide, some contracts are issued on a nationwide 

basis to cover all FDIC locations. While smaller firms that are not national in scope 

are capable of providing some of these services on a local basis, in many cases there 

are significant administrative advantages to having fewer contractors provide these 

services to ensure consistent implementation of FDIC programs throughout the FDIC’s 

80 plus offices nationwide.
22 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

FDIC CONTRACTING: Inclusion of Minority- and Women-Owned Businesses (MWOBs)

Despite the decline in contract dollars awarded since the financial crisis and the 

challenges described above, the FDIC through its aggressive outreach program 

continues to educate and equip MWOBs with the tools they need to compete for 

contracting opportunities and to have success. These programs resulted in 29 percent 

of the FDIC’s contracts being awarded to MWOBs and an increase in total contract 

dollars awarded to MWOBs from 24.5 percent in 2018 to 31.3 percent in 2019. The 

FDIC will continue to assess and analyze future contracting needs to determine where 

MWOB opportunities may exist or if new methods of service delivery are feasible.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 23

EMPLOYMENT AT THE FDIC:

Fair Inclusion of Minorities and Women

The FDIC is committed to creating and maintaining a workforce representative of 

all segments of society. The FDIC’s Diversity and Inclusion Strategic Plan outlines a 

course for promoting workforce diversity by recruiting from a diverse, qualified group 

of potential applicants, and cultivating workplace inclusion through collaboration, 

flexibility, and fairness. In 2005 the FDIC launched the Corporate Employee Program 

(CEP) program to recruit and train entry-level examiners. The examiner occupational 

category represents the largest segment of the FDIC workforce and serves as the 

primary feeder pool for management and senior leadership positions in the agency. 

During 2019 the CEP program was restructured to further strengthen the agency’s 

ability to attract, retain, and advance a diverse and more inclusive workplace.

The FDIC began the process in 2019 of updating its Diversity and Inclusion Strategic 

Plan for the coming years. The next plan will cover 2020 – 2022. This plan incorporates 

the FDIC’s currently separate Disability Employment Program Strategic Plan so we 

now have a unified plan. The strategic plan will continue to identify agency strategies 

to promote increased diversity through the FDIC’s recruiting, hiring, and inclusion 

practices. The Plan will also continue to ensure the sustainability of the FDIC’s diversity 

and inclusion efforts by educating leaders with the ability to manage diversity, monitor 
24 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

results, and refine approaches on the basis of actionable data. Specific strategies in the 

plan will enhance diversity and inclusion at the FDIC through analytics and reporting, 

training and education, internal and external partnerships, leadership engagement, 

and accountability. OMWI staff spends considerable time conducting data analysis 

related to diversity and inclusion workforce metrics. This data analytics work is a part 

of its affirmative employment program and also in response to requests from the EAC 

and division and office inquires. The FDIC maintains a diversity and inclusion metrics 

dashboard which allows for OMWI and agency senior leadership to monitor and report 

on workforce diversity progress at the division or agency level. 

The following sections provide information on current FDIC diversity levels, initiatives 

to advance diversity and inclusion, as well as challenges the FDIC faces in its efforts to 

promote greater diversity in hiring and employment. 

Diversity in Employment and Hiring 

As of December 31, 2019, minorities accounted for 30.4 percent (1,768) of the 

FDIC’s total workforce (permanent and non-permanent) of 5,821 employees, and 

women accounted for 44.9 percent (2,613). [See Figure 10.] More specifically, the 

representation percentages in the total workforce for various minority groups at the 

end of December 2019 were as follows: 1.7 percent for people of two or more races, 

0.6 percent American Indian or Alaska Native (AIAN), 6.4 percent Asian American, 17.4 

percent Black American, and 4.2 percent Hispanic American.

Figure 10 Diversity in Total – (Permanent and Non-Permanent) Employment 

as of 12/31/2019

Minority Non-Minority Total

Number 1,768 4,053 5,821

Percent 30.4% 69.6% 100.0%

Men Women Total

Number 3,208 2,613 5,821

Percent 55.1% 44.9% 100%

2 or More AIAN Asian Black Hispanic White Total

Number 101 35 374 1,011 247 4,053 5,821

Percent 1.7% 0.6% 6.4% 17.4% 4.2% 69.6% 100.0%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 25

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

The racial, ethnic, and gender diversity of the FDIC’s workforce overall has improved 

since the passage of Section 342 of the DFA. Minorities accounted for 26.2 percent of 

the FDIC’s permanent workforce as of July 31, 2010, and 30.4 percent as of December 31, 

2019. The percentage of women in the FDIC’s permanent workforce was 43.6 percent as 

of July 31, 2010, and 44.9 percent as of December 31, 2019. [See Appendix C.]

As of December 31, 2019, minorities accounted for 16.7 percent (23) of the FDIC’s total 

Executive Manager (EM) workforce of 138 employees, and women accounted for 37.7 

percent (52). [See Figure 11.]

Figure 11 Diversity in Total (Permanent and Non-Permanent) Employment – 

Executive Manager Workforce as of 12/31/2019

Minority Non-Minority Total

Number 23 115 138

Percent 16.7% 83.3% 100.0%

Men Women Total

Number 86 52 138

Percent 62.3% 37.7% 100%

2 or More AIAN Asian Black Hispanic White Total

Number 0 1 3 17 2 115 138

Percent 0.0% 0.7% 2.2% 12.3% 1.4% 83.3% 100.0%

The racial, ethnic, and gender diversity of the EM workforce overall has increased since 

the passage of Section 342 of the DFA. The percentage of women in the FDIC’s EM 

workforce was 25.0 percent as of July 31, 2010, and 37.7 percent as of December 31, 

2019. Appendix C depicts the FDIC’s five-year trends for the total, permanent, and EM 

workforce for 2015 through 2019.

Initiatives to Promote Diversity in Employment

The FDIC promotes its commitment to a diverse workforce through a wide variety of 

methods aimed at attracting, recruiting, hiring, and retaining high-performing individuals 

who reflect the diversity of our society. The FDIC’s largest occupational group is bank 

examiners. The recruitment of entry-level examiners as Financial Institution Specialists 

(FIS), had been conducted primarily through the CEP. 
26 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

After a thorough study of processes for recruiting, hiring, and training examiners, in 

2019 the FDIC implemented structural changes to the CEP, creating a new entry-level 

examiner hiring program to support examiners and supervisory efforts and to ensure 

future readiness. This included the creation of an executive level taskforce to evaluate 

and strengthen the agency’s ability to attract, retain, and advance a diverse pool of 

candidates, facilitating a strong, diverse, and more inclusive workplace.

OMWI tracked and informed FDIC leadership about the representation and 

attrition rates for CEP participants based on race, ethnicity, and gender. Reports on 

participation rates were prepared following incoming classes of CEP hires, and each 

report included the total participants from the inception of the program, FISs currently 

onboard, and attrition information. OMWI will track hiring, attrition, and other aspects 

of the employment lifecycle for participants of the new entry-level examiner hiring 

program to evaluate impacts on diversity and inclusion.

The FDIC has engaged in a proactive recruitment effort using recruitment strategies 

that have improved the representation of several, racial, ethnic, and gender groups 

in the examiner workforce since the inception of the CEP. The overall percentage of 

women in the examiner workforce increased from 33.5 percent as of December 31, 

2004, to 39.2 percent as of December 31, 2019. In addition, the percentages of Black 

American men and women, Hispanic American women, Asian American men and 

women, American Indian or Alaska Native men and women, and White women in the 

overall examiner workforce all have increased since the beginning of the CEP. However, 

despite the positive progress in those areas, the representation rates of Hispanic 

American men and women, Asian American men and women, Black American women, 

and women of two or more races in the FDIC’s examiner workforce remain below the 

Civilian Labor Force (CLF) benchmark for the occupational series.

Since the inception of the CEP, overall hiring rates have been at or above the 

percentages in the CLF for men and women of two or more races, American Indian 

or Alaska Native men and women, and Black American men and women, but lower 

than the CLF for Asian American men and women, Hispanic American men and 

women, and White women. [See Figure 12.] The overall minority hiring rate since the 

inception of the CEP has been 27.5 percent; and the overall hiring rate for women has 

been 39.3 percent.

Figure 12 CEP Hires Since Inception

2 or More AIAN Asian Black Hispanic White Total

Women Men Women Men Women Men Women Men Women Men Women Men

CEP 21 23 5 12 44 67 192 125 39 53 528 1,000 2,109

% 1.0 % 1.1% 0.2% 0.6% 2.1% 3.2% 9.1% 5.9% 1.8% 2.5% 25.0% 47.4% 100.0%

CLF 1.0% 0.6% 0.2% 0.1% 3.7% 3.5% 8.4% 3.4% 3.7% 3.1% 28.3% 44.1% 100.0%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 27

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

During 2019, CEP hiring rates were above the CLF percentages for men and women 

of two or more races, American Indian or Alaska Native men and women, Asian 

American men, Black American men, Hispanic American men, and White women, and 

were below the CLF for Asian American women, Black American women, Hispanic 

American women, and White men. While the hiring rate for White men was below 

the CLF, historically White men have been above the CLF for CEP and continue to 

be represented above the CLF within the examiner workforce. [See Figures 13 and 

Appendix D] The overall hiring rate in 2019 for minorities and women was positive.

Figure 13 CEP Hires in 2019 (Classes 68-73)

2 or More AIAN Asian Black Hispanic White Total

Women Men Women Men Women Men Women Men Women Men Women Men

CEP 4 2 1 1 3 8 10 8 2 8 52 63 162

% 2.5% 1.2% 0.6% 0.6% 1.9% 4.9% 6.2% 4.9% 1.2% 4.9% 32.1% 38.9% 100.0%

CLF 1.0% 0.6% 0.2% 0.1% 3.7% 3.5% 8.4% 3.4% 3.7% 3.1% 28.3% 44.1% 100.0%

As a significant component of the recruitment strategy for entry-level examiners, 

FDIC recruiters participated in job fairs aimed at targeted professional audiences and 

maintained ongoing relationships with a wide range of colleges and universities. 

This includes 115 institutions designated as Hispanic Serving Institutions, Historically 

Black Colleges and Universities (HBCUs), and other minority-serving institutions, 

tribal colleges and universities, and institutions with significant student populations of 

women, and minorities.

With regard to targeting professional audiences, in 2019, FDIC recruiters attended 19 

national diversity outreach events and seven regional outreach events to increase 

awareness of the FDIC as an employer of choice to professionals. The FDIC also met 

with key leaders in Hispanic American, Black American, Asian American, women’s, and 

veterans’ organizations as well as organizations representing people with disabilities 

to create awareness of FDIC careers and identify opportunities to expand outreach to 

their members. For example, the FDIC participated in the National Association of Black 

Accountants (NABA) 2019 National Convention & Expo and the Hispanic Association of 

Colleges and Universities (HACU) 33rd Annual Conference. 
28 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

With respect to recruiting students (both traditional and non-traditional), FDIC 

corporate recruiters participated in 285 college career fairs, 11 information sessions, 

and other recruitment-related campus activities throughout the United States to 

brand the FDIC and attract qualified candidates. Recruitment efforts during 2019 also 

included the following:

§ Hosted developmental workshops for students and entry-level professionals at 

events for professional affinity groups: 

Personal Branding (2019 Thurgood Marshall College Fund (TMCF) Leadership 

Institute & Recruitment Fair)

Vision, Leadership + Value: Build a Platform with your Voice at the Center HACU 

33rd Annual Conference; 

Managing IT Risk in a Changing Environment (Association of Latino Leaders for 

America (ALPFA) 2019 Convention);

 Leadership Networking: Cultivating Authentic Connections to Accelerate Your 

Career (Prospanica 2019 Annual Conference & Exposition); and

Personal Branding (2019 ALPFA Northeast Regional Symposium in Boston)

§ Conducted informational interviews and provided application assistance at the 

following: ALPFA, HACU, Prospanica, and TMCF.

§ Conducted federal resume review at Prospanica.

To assist in increasing participation rates for underrepresented groups in the 

non-examiner occupations, the FDIC’s recruitment strategy includes outreach to 

prospective applicants for entry-level positions in these occupations throughout the 

agency. These efforts led to increased level of minority representation within the 

economist occupation at FDIC, which continues. The FDIC’s Division of Insurance and 

Receiverships (DIR), where the majority of the FDIC’s economists reside, continued 

its partnership with Delaware State University to improve the diversity pipeline 

of applicants for Economic Research Assistants and intern positions. In 2019, DIR 

expanded outreach efforts to two other HBCUs, Howard University and Morgan 

State University. 

DIR continues to use an alumni log for Economists, Economic Analysts, and 

Economic Research Assistants to cultivate and strengthen diversity outreach for 

entry-level positions through alumni relationships with universities and colleges. The 

log has served as a reference tool for DIR recruiters when attending outreach events 

and career fairs at universities across the U.S. The FDIC also conducted outreach to 

minority and women professional economist organizations to gain access to listservs 

or distribution networks that might expand FDIC’s pipeline to qualified Economic 

Research Assistants and interns. Additionally, the division plans to participate in the 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 29

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

American Economic Association Summer Fellowship Program, which targets women 

and minorities with PhDs.

In 2019, the FDIC and NTEU reached a new compensation agreement that included 

a Pilot Student Loan Repayment Program, which will assist in recruitment and 

retention efforts. 

Diversity and Inclusion Analytics Dashboard

The FDIC’s workforce analytics dashboard provides actionable data to senior 

leadership on the FDIC workforce by gender and minority status, and by division 

and office, region, race, ethnicity, occupation, grade level, and employment type 

(permanent and non-permanent). This information supports the evaluation of diversity 

and inclusion efforts at all levels of the organization. Trends measure progress and 

facilitate the development of strategies or the adjustment of plans where needed. 

In 2019, each division used information from the dashboard to help drive diversity 

and inclusion strategic plans at the division level. The FDIC will continue to identify 

additional enhancements to the dashboard that will permit senior leaders to continue 

understanding and advancing diversity and inclusion within their organizations. 

Inclusion Initiatives

The FDIC continues to engage in initiatives to support inclusion and retention efforts 

within the corporation, and the FDIC’s Diversity and Inclusion Education Series is 

an integral component of building workforce inclusion. Annually, OMWI hosts 10 

corporate-wide observances as part of its education series. The education series raises 

cultural awareness and fosters an environment of cultural intelligence, providing a safe 

space to share histories and experiences.

In 2019, the FDIC continued to leverage the Chairman’s Diversity Advisory Councils 

(CDACs) to integrate diversity and inclusion efforts throughout the agency. The CDACs 

were established to assist the OMWI to break down barriers, increase awareness of 

cultural differences, and promote inclusion and collaboration among all employees. 

The CDACs are comprised of six regional and a headquarter council, with a maximum 

of nine members per council and, to the extent possible, reflects the general 

composition of the FDIC’s diverse labor force (i.e., different grade levels, positions, and 

bargaining and non-bargaining status).

The CDACs’ mission is to provide advice to the FDIC’s Chairman, through the OMWI 

Director, on any diversity-related issues and concerns. Its objective is to recommend 

changes in corporate policies and procedures that would foster the FDIC’s diversity 
30 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

and inclusion goals and strategies. One of the issues the CDACs raised in 2018 was 

paid parental leave. The FDIC’s new compensation agreement with the NTEU in 2019, 

included six weeks of paid parental leave for the birth, adoption, or foster care of a 

child. 

The councils also assisted and worked with OMWI to sponsor programs that address 

cultural diversity and promote initiatives that acknowledge and recognize the benefits 

of the diverse heritages and cultures that exist throughout the corporation. The CDACs 

held a combined total of 81 events on a variety of diversity and inclusion topics, 

including but not limited to: nationally recognized observance months, “Generational 

Diversity in the Workplace”, “Supporting Transgender Rights”, disability awareness, 

unconscious bias, and inclusiveness.

The FDIC’s Chairman and senior management have strongly supported the CDACs’ 

initiatives. The programs and activities sponsored by the CDACs have brought 

employees together to demonstrate how diverse backgrounds bond individuals to 

strengthen the FDIC’s mission and goals, and have taken place nationwide at various 

FDIC offices. 

The FDIC also continues to engage with its nine ERGs. ERGs are FDIC-recognized 

networks of FDIC employees with common goals, interests, or life experiences. 

The FDIC started the ERG Program to foster and encourage equality of opportunity, 

respect, and fair treatment for all. ERGs are vital to the FDIC’s ability to create and 

maintain a culture and environment that recognizes, appreciates, encourages, and 

utilizes the talents, skills, and perspectives of all employees in order to achieve the 

FDIC’s mission.

OMWI staff regularly meets with the ERGs to discuss programs and issues. Among 

other initiatives, in 2019, the ERGs partnered with the Washington CDAC to host an 

ERG Open House to provide employees an opportunity to meet ERG representatives 

and learn more about the nine ERGs recognized by the FDIC. 

In 2020, the FDIC plans to participate in the Marion S. Barry Summer Youth 

Employment Program in partnership with the Office of the Comptroller of the Currency 

(OCC) and the District of Columbia (DC) Employment Office. Interns will be exposed 

to various work experiences and participate in numerous enrichment activities. In 

accordance with the Dodd-Frank Act, the FDIC, joining with the OCC, can provide 

promising opportunities for high school students, thereby improving their chances of 

future success. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 31

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

Challenges

A key challenge for the FDIC in promoting diversity at all levels of its workforce 

continues to be the representation of minorities and women in its bank examiner 

workforce. The examiner occupation represents the largest occupational group at 

the FDIC and accounts for 46.6 percent (2,715) of the FDIC total workforce (5,821). 

Individuals who began their FDIC careers as entry-level examiners tend to occupy a 

significant percentage of executive and managerial leadership positions at the agency, 

as well as other non-examiner positions in the FDIC. Thus, representation rates within 

the examiner workforce are key elements to achieving satisfactory representation 

rates within the broader FDIC workforce.

The FDIC’s Financial Management Scholars Program (FMS), has assisted in the 

diversity of the examiner ranks. The FMS program is an 11-week paid summer 

internship program for highly-qualified college students. At the end of the program, 

qualified FMS interns receive post-graduation employment offers with the FDIC. The 

FMS program continues to hire, in aggregate, above the CLF for women since the 

inception of the program in 2011. Participation for minorities in the FMS program over 

the life of program remained below the CLF but continues a steady increase.

Despite the overall success of the CEP in increasing the percentage of minorities and 

women in the examiner workforce, those percentages still remain below the CLF for 

certain groups such as for Asian American men and women, Hispanic American men 

and women, and Black American women, and women of two or more races. The FDIC 

continually works to ensure that recruiting sources, hiring decisions, interviewing 

processes, training activities, retention efforts, and advancement pools reflect a 

purposeful and intentional effort to leverage the power of diversity to maintain a high 

performing examination workforce. A key challenge for the FDIC in promoting diversity 

at all levels of its workforce continues to be the ability to attract, retain, and advance 

minorities and women in its bank examiner workforce. 

From 2005 until 2019, the FDIC hired entry level examiners as FIS through the CEP. 

With increased retirements anticipated in the near future, and gaps in the succession 

pipeline, the FDIC must identify and prepare future leaders now to fulfill roles in the 

years to come, while concurrently seizing the opportunity to continue to mold the 

diversity of the FDIC. The FDIC also recognizes that maintaining an inclusive work 

environment is critical for minimizing attrition and maintaining diversity.

In 2019, the FDIC closely reviewed current processes, historical and current data, 

business and staffing needs, time and resource challenges, and costs for hiring entry 

level examiners. The FDIC created an executive level taskforce, which includes the 

OMWI Director, to strengthen its ability to attract, retain, and advance a diverse pool 

of examiner candidates. The taskforce conducted a high level review of available 

data from OMWI, identified key challenges and made several recommendations 
32 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

to mature the diversity and inclusion model for the examination workforce. It is 

anticipated that these recommendations will result in several actions being taken 

during 2020 and beyond.

OMWI supports the taskforce by providing actionable data to help build a results 

driven diversity and inclusion strategy. Also, OMWI will also track hiring, attrition, 

and other aspects of the employment lifecycle for participants of the new entry-level 

examiner hiring program to evaluate impacts on diversity and inclusion. [See Figure 

14.] The first group of examiners under this new program are scheduled to onboard in 

early 2020.

Figure 14 CEP Attrition Rates

Total 2 or More AIAN Asian Black Hispanic White

Women Men Women Men Women Men Women Men Women Men Women Men

Hires 2,109 21 23 5 12 44 67 192 125 39 53 528 1,000

Involuntary

Departures 41 0 0 0 0 1 1 8 9 1 2 4 15

Involuntary

Attrition

Rate+

(%)

1.9% 0.0% 0.0% 0.0% 0.0% 2.3% 1.5% 4.2% 7.2% 2.6% 3.8% 0.8% 1.5%

Subtotal 2,068 21 23 5 12 43 66 184 116 38 51 524 985

Voluntary

Departures 744 5 2 1 5 17 31 71 57 14 16 178 347

Voluntary

Attrition

Rate *

(%)

36.0% 23.8% 8.7% 20.0% 41.7% 39.5% 47.0% 38.6% 49.1% 36.8% 31.4% 34.0% 35.2%

Number

Retained 1,324 16 21 4 7 26 35 113 59 24 35 346 638

+ “Involuntary Attrition Rate” is the Involuntary Departures divided by the total hired.

* “Voluntary Attrition Rate” is the Voluntary Departures divided by the subtotal. 

In the non-examiner occupations of economists, financial administration, accountant 

and auditors, attorneys, and general business and industry, the FDIC continues to face 

the challenges in attracting and recruiting minorities and women, primarily due to low 

labor force representation rates for minority groups and women in these occupations. 

[See Appendix D.]

Despite these challenges, representation of minorities within the economist 

occupation remains above the relevant CLF, with Hispanic American men, Black 

American women, and Asian American men and women having higher participation 

rates than the benchmark. Black American men fall below the CLF. Hispanic American 

women, American Indian or Alaska Native men and women, and men of two or more 

races are absent. Overall, women fall below the CLF within the economist occupation, 

with Hispanic American women and White women showing the greatest differences 

from the benchmark. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 33

EMPLOYMENT AT THE FDIC: Fair Inclusion of Minorities and Women

In the financial administration and program occupation, minorities overall are above 

the relevant CLF. However, Hispanic Americans fall below the CLF. American Indian 

or Alaska Native men and women of two or more races are absent in this occupation. 

Additionally, women overall, particularly White and Hispanic American women fall 

below the CLF.

For the accountant/auditor occupations, Hispanic American men, American Indian 

or Alaska Native men and women are absent. Compared to 2018, there has been 

improvement in the representation of Hispanic American women and women of two 

or more races. White women and Asian American men have a low representation 

compared to the relevant CLF for the accountant and auditor occupation. In aggregate, 

minorities continue to remain above the CLF benchmark for this occupation while 

women are below.

In the attorney occupation, minorities in aggregate are above the CLF. However, 

some groups of minorities have participation rates slightly below the relevant CLF 

in the attorney occupation, including Hispanic American men and women and Asian 

American men. Women overall are above the CLF, while men overall are below. 

Women of two or more races are absent in this occupation.

Women overall, including those in all racial/ethics groups, fall below the CLF in the 

general business and industry occupation. All groups of men are above relevant CLF 

for this occupation.

In 2019, the FDIC continued monitoring race, ethnicity, gender, and grade levels by 

FDIC divisions and offices. OMWI met with various agency divisions and offices to 

discuss representation and strategies for expanding outreach and recruitment more 

broadly to increase minority and women representation within major occupations 

and at senior levels within the FDIC. In the coming year, OMWI will continue to engage 

with agency divisions and offices to assist in advancing diversity and inclusion, in 

alignment with strategies and action items outlined in the FDIC Diversity and Inclusion 

Strategic Plan.
34 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

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Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 35

OTHER ACTIVITIES

The information in this section discusses FDIC activities that pertain to other relevant 

programs and successes that support provisions of Section 342 of the DFA. The FDIC 

demonstrates commitment to business diversity by assessing the diversity policies 

and practices of regulated financial institutions; verifying contractors’ commitment to 

workforce diversity; and promoting the economic inclusion and development for lowand moderate income communities. 

OMWI administers both the Financial Institution Diversity and Contractors’ Workforces 

Fair Inclusion programs. The programs promote diversity and inclusion practices and 

procedures among FDIC–regulated financial institutions and contractors. The annual 

self-assessment submitted by FDIC-regulated financial institutions identify diversity 

and inclusion practices that financial institutions have implemented. Interagency 

Policy Statement Establishing Joint Standards for Assessing the Diversity Policies 

and Practices of Entities Regulated by the Agencies, the Standards offer guidance and 

a framework for assessing diversity practices, examining leadership commitment, 

reporting on workforce metrics, and taking affirmative actions to improve workforce 

and supplier diversity. The assessments have enabled OMWI to identify industry 

trends and exemplary practices financial institutions have implemented. 
36 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Also, the FDIC provides technical assistance and outreach to low-and moderate 

income communities. The Community Affairs Program, through partnerships with 

banks, government entities, and community organizations promotes access to 

affordable credit and deposit services in these historically underserved communities. 

The FDIC efforts encourage responsible options for affordable mortgage credit; 

promote affordable insured transactions and savings accounts; strengthen access 

to financial services for small businesses; increase consumer access to sustainable 

credit; and support financial education and literacy. In addition, the preservation and 

promotion of minority depository institutions (MDI) remains a long-standing and high 

priority for the FDIC. In 2019, the FDIC expanded engagement with MDIs and continued 

to promote and support MDI and Community Development Financial Institution (CDFI 

bank) industry-led strategies to better serve their communities.

Financial Institutions Diversity

Section 342 of the DFA requires FDIC to report on the data received from their 

respective regulated institutions annually to Congress. The FDIC conducts analysis 

of the self-assessment information and highlights exemplary diversity and inclusion 

practices for the purpose of assisting financial institutions benchmark and strengthen 

diversity programs. A report on the self-assessments analysis is posted on the FDIC’s 

website and shared with financial institutions in order to leverage industry trends and 

leading practices in diversity and inclusion. Since the first reporting period in 2016, 365 

financial institutions have reported on diversity practices. 

In early 2017, the FDIC obtained approval from the Office of Management and Budget 

(OMB) to collect assessment information from regulated entities to assist and 

strengthen diversity programs in financial institutions through a self-assessment 

instrument. The instrument provides the framework for regulated financial institutions 

to assess and strengthen diversity policies and practices, and covers the following 

areas derived from the Policy Statement:

§ Organizational Commitment to Diversity and Inclusion

§ Workforce Profile and Employment Practices

§ Procurement and Business Practices – Supplier Diversity 

§ Practices to Promote Transparency of Organizational Diversity and Inclusion 

§ Entity’s Self-Assessment 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 37

OTHER ACTIVITIES

The FDIC-regulated financial institutions began voluntarily submitting diversity selfassessments to the FDIC’s OMWI for the 2016 reporting period. The results of the 2016 

analysis established the baseline for subsequent reporting periods. The completed 

analysis is posted on both internal and external web-site3.

.

In January 2019, the FDIC’s OMWI Director distributed a letter to the Presidents 

and Chief Executive Officers of 784 FDIC-regulated financial institutions identified 

as having 100 or more employees. The letter informed these institutions about the 

process for conducting and voluntarily submitting their diversity information to 

the FDIC. The OMWI Director issued a reminder letter in March 2019, to financial 

institutions to encourage participation, and extended the submission deadline to 

April 2019. The FDIC received diversity self-assessments from 133 (16.9 percent) of its 

regulated financial institutions. 

There was an increase from the 2016 reporting period (95 financial institutions) to the 

2017 reporting period (137 financial institutions). There was a slight decrease for the 

2018 reporting period to 133 from 137 financial institution submissions; however, the 

percentage of self-assessments received increased in 2018. 

The chart below illustrates a comparison of responding FDIC-regulated financial 

institutions for the 2016 to 2018 reporting periods. 

Comparative of Responding Financial Institutions

Reporting 

Period

# Financial 

Institutions 

(Invited)

# SelfAssessments 

Received

% SelfAssessments 

Received

# Acknowledged 

Non-Respondents

# Minority 

Depository 

Institutions

2016 805 95 11.81 2 10

2017 820 137 16.71 3 8

2018 784 133 16.96 3 7

The FDIC completed an analysis of the financial industry’s diversity policies and 

practices for the 2018 reporting period and a comparative analysis against the 2016 

and 2017 reporting periods, for the purpose of monitoring progress and trends of 

diversity and inclusion in employment and contracting activities. The analysis further 

provided the opportunity to identify exemplary diversity policies and practices. 

Overall, OMWI has observed that the reporting results have remained consistent 

over the last two reporting periods, for 2017 and 2018. The FDIC is exploring ways to 

increase its outreach efforts to further encourage and guide its regulated financial 

institutions to implement policies and practices, and share their completed selfassessments to further raise awareness aiming to improve levels of diversity and 

inclusion throughout the financial industry. 

3 See https://www.fdic.gov/about/diversity/dibanking.html
38 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Workforce Profile

The Standards encourage organizations to promote the fair inclusion of minorities 

and women in their workforce. The FDIC- regulated financial institutions reported on 

the diversity in their workforce, management, and board members. The aggregated 

numbers are provided below. Workforce diversity is greatest in the total workforce, 

less diverse in management and even less in Board members. For example, financial 

institutions reported having 68 percent of women in their workforce; however, only 14 

percent of women are board members. 

Diversity Data for Workforce Profile 2018 Results

Section III. Diversity Data

4. Workforce

Diversity 

Data

Total Women 

(#)

Women 

(%)

Men (#) Men (%) Minorities 

(#)

Minorities 

(%)

(#) NonMinorities(%) NonMinorities

Workforce 416,995 245,751 68% 170,772 28% 153,119 18% 225,342 74%

Management 20,056 9,098 41% 10,904 53% 6,075 11% 13,737 80%

Board 

Members 1,367 228 14% 2,964 74% 299 8% 1,173 80%

Procurement-Supplier Diversity

Similarly, the Standards promote active outreach to minority and women-owned 

businesses in the procurement process. The results reported from the financial 

institutions for their procurement supplier diversity practices continue to be underreported, and are not sufficient to aggregate results to draw any conclusions or trends 

for the third reporting period. The majority of financial institutions do not have the 

systems in place to adequately track the diversity in their procurement spending 

practices. The aggregated results of the diversity data for procurement correlate to 

the low percentages reported under, Procurement and Business Practices - Supplier 

Diversity.

OMWI Outreach to FDIC-Regulated Financial Institutions

The FDIC’s OMWI prepared a video that is available on the FDIC YouTube Channel, 

where the OMWI Director describes the Financial Institution Diversity Program 

and encourages FDIC-regulated financial institutions with 100 or more employees 

to conduct the annual self-assessment of their diversity policies and practices as 

outlined in the Policy Statement.

Additionally, the OMWIs from six financial regulatory agencies held the second, 

“Financial Regulatory Agencies’ Diversity and Inclusion Summit” at the Federal 

Reserve Bank of Chicago on Thursday, October 24, 2019, that included: the FDIC, FRB, 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 39

OTHER ACTIVITIES

OCC, the Consumer Financial Protection Bureau (CFPB), the National Credit Union 

Administration (NCUA), and the U.S. Securities and Exchange Commission.

The goal of the Summit was to bring together organizations in the financial industry 

that included entities regulated by the OMWI agencies in order to highlight industry 

leading practices involving diversity and inclusion in employment and procurement 

practices. Speakers from various segments of the financial industry discussed 

practices they have successfully implemented within their organizations to advance 

diversity and promote inclusion in the workplace, and to increase opportunities 

for diverse suppliers. The Summit also featured a panel discussion with the OMWI 

Directors from FDIC, OCC, NCUA, and FRB to share highlights on the results of selfassessments agencies received under Section 342 of the DFA.

The OMWI Directors hope these industry outreach events will encourage participants 

from financial institutions to complete and submit their diversity self-assessments 

to their respective regulatory OMWI agency. The completed self-assessments 

contribute to the reports the agencies prepare, providing trends on diversity and 

inclusion in the financial industry.

On November 20, 2019, the FDIC’s OMWI participated with the Federal Reserve and 

the OCC in a webinar hosted by the American Bankers Association (ABA) about the 

joint standards for assessing diversity and inclusion policies and practices, titled 

“Diversity: What Bankers Need to Know about the Diversity Self-Assessment.” The 

webinar was developed for institutions of all sizes to learn about leading practices 

and gain a useful understanding about the agencies’ collection and reporting of the 

voluntary submissions of diversity self-assessments received. The webinar, and all 

relevant material can be accessed from ABA’s web page: https://www.aba.com/

training-events/online-training/diversity-joint-standards.

Each of these outreach efforts focus on the value of conducting voluntary selfassessments and annually submitting assessment results to OMWI Directors as 

well as making diversity information transparent to the public that will continue 

to advance the visibility and adoption of diversity and inclusion practices in the 

financial industry. 
40 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Exemplary Practices

The FDIC has identified exemplary practices that financial institutions implemented 

as part of their workforce diversity and inclusion practices. These practices could be 

considered by other financial institutions. For example, the 2018 self-assessments 

demonstrated that financial institutions are: 

1. Creating programs targeting women and minorities in their financial institutions for 

promotion and increased leadership skills. These programs have demonstrated an 

increase in the institutions’ hiring of women and minorities due to the increase of 

their women and minority representation in management positions.

2. Creating requirements within their procurement practices to ensure a percentage 

of minorities and women are included on solicitations.

3. Incorporating diversity and inclusion scorecards to the management’s dashboard.

4. Embedding diversity and inclusion segments into the institutions’ leadership and 

management training.

5. Creating programs for the employees to provide hands-on training to students 

providing opportunities of part-time and full-time employment. 

6. Adding information about supplier diversity approach to minority and women in 

corporate manuals for vendor management.

7. Incorporating diversity and inclusion goals into annual corporate goals. 

8. Adding diversity and inclusion behavioral evaluations for employees and 

management to performance management systems.

Trend Analysis of Self-Assessment Results – Reporting Period 

2016 to 2018 

Aggregated Assessment of FDIC-Regulated Financial Institutions 

Policies and Practices - Breakdown by Standard

The Standards provide a framework for assessing the diversity policies and practices 

of FDIC-regulated financial institutions. The OMWI agencies developed the framework 

based on industry leading practices identified in roundtable discussions and feedback 

provided by financial institutions in response the Federal Register Notice that 

requested input on the proposed Standards. In responding to the self-assessment 

each financial institution takes into account their individual entity’s size and other 

characteristics. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 41

OTHER ACTIVITIES

The sections that follow describe each of the five standards and includes a table that 

shows each of the questions and the percent of financial institutions that provided an 

affirmative response in each year. 

Subsection 1: Organizational Commitment to Diversity and Inclusion

Leadership commitment to diversity and inclusion comes from the organization’s 

governing body (e.g., C-suite, board of directors, and management). The Standard 

addresses how financial institutions promote diversity and inclusion in employment, 

contracting, and the corporate culture. This subsection reflects a one percent increase 

from 2017 to 2018; but overall, the responses indicated the financial institutions 

embrace the Standards in this subsection (six percent increase from 2016 to 2018). The 

highest increased response (five percent) was in reference to whether the financial 

institution regularly conducts training and provides educational opportunities on equal 

employment opportunity and on diversity and inclusion.

Organizational Commitment to Diversity and Inclusion 2016 to 2018 Results

Section II. Assessment of the Financial Institution’s Diversity Policies and Practices

1. Organizational Commitment to Diversity and Inclusion 2016 2017 2018

1.1 The financial institution includes diversity and inclusion 

considerations in both employment and contracting as an 

important part of its strategic plan for recruiting, hiring, 

retention, and promotion.

83% 91% 92%

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.

81% 85% 88%

1.3 The financial institution provides regular progress reports 

to the board and senior management. 75% 80% 77%

1.4 The financial institution regularly conducts training and 

provides educational opportunities on equal employment 

opportunity and on diversity and inclusion.

82% 82% 87%

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.

84% 90% 89%

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.

85% 91% 95%

Section II.1 Average: 82% 87% 88%
42 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Subsection 2: Workforce Profile and Employment Practices 

The workforce profile and employment practice had the highest average change from 

2016 to 2018 (eight percent increase). These numbers indicated the financial institutions 

embraced the Standards in this subsection with continual average increase. Areas 

of strength are reflected in responses to questions 2.1 and 2.2, which have reported 

consistently high over the past three reporting years that relate to the implementation 

of policies and practices that comply with applicable laws, and ensuring equal 

employment opportunities. The highest overall positive change from 2016 to 2018 (12 

percent) referred to participation in conferences, workshops, and other events to attract 

minorities and inform them of employment and promotion opportunities.

Workforce Profile and Employment Practices 2016 to 2018 Results

Section II. Assessment of the Financial Institution’s Diversity Policies and Practices

2. Workforce Profile and Employment Practices 2016 2017 2018

2.1 The financial institution implements policies and practices 

related to workforce diversity and inclusion in a manner that 

complies with all applicable laws.

94% 95% 98%

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.

96% 96% 97%

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.

74% 80% 80%

2.3(b) Outreach to educational institutions serving significant 

minority and women student populations. 66% 73% 73%

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

to attract minorities and women and to inform them of 

employment and promotion opportunities.

61% 70% 73%

2.4 The financial institution utilizes both quantitative and 

qualitative measurements to assess its workforce diversity 

and inclusion efforts. These efforts may be reflected, 

for example, in applicant tracking, hiring, promotions, 

separations (voluntary and involuntary), career development, 

and retention across all levels and occupations of the financial 

institution, including the executive and managerial ranks.

79% 87% 89%

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.

69% 82% 83%

Section II.2 Average: 77% 83% 85%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 43

OTHER ACTIVITIES

Subsection 3: Procurement and Business Practices - Supplier 

Diversity

Procurement and Business Practices - Supplier Diversity is on a slight downward trend 

with a decrease of one percent from 2017 to 2018, and a six percent decrease from 

2016 to 2018. Over the last three reporting periods, there has been a six percent (2016- 

24 to 2018- 19) decrease in response to the supplier diversity data. Overall, responses 

to Subsection 3, Procurement and Business Practices have consistently demonstrated 

that supplier diversity is an area of challenge; responding financial institutions 

continue to report low levels of engagement, with the lowest percentage awarding to 

minority or women-owned businesses or subcontractors. 

Procurement and Business Practices – Supplier Diversity 2016 to 2018 Results

Section II. Assessment of the Financial Institution’s Diversity Policies and Practices

3. Procurement and Business Practices - Supplier Diversity 2016 2017 2018

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. This includes contracts of 

all types, including contracts for the issuance or guarantee 

of any debt, equity, or security, the sale of assets, the 

management of the financial institution’s assets, and 

the development of the financial institution’s equity 

investments.

41% 31% 30%

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.

23% 20% 19%

3.2(b) Percentage of contract dollars awarded to minority-owned 

and women-owned businesses by race, ethnicity, and 

gender.

16% 14% 11%

3.2(c) Percentage of contracts with minority-owned and womenowned business subcontractors. 15% 13% 12%

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.

31% 21% 21%

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

to attract minority-owned and women-owned firms and 

inform them of contracting opportunities.

20% 18% 14%

3.3(c) An ongoing process to publicize its procurement 

opportunities. 23% 15% 16%

Section II.3 Average: 24% 19% 18%
44 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Subsection 4: Practice to Promote Transparency of 

Organizational Diversity and Inclusion

The practice to promote transparency of organizational diversity and inclusion had 

slight increase from 2017 to 2018 by one percent in overall average. The highest 

positive change (four percent) referred to a financial institution publicizing its policy 

on its commitment to diversity and inclusion. There were slight or no change for other 

questions regarding transparency of organizational diversity and inclusion.

Practice to Promote Transparency of Organizational Diversity and Inclusion 2016 to 

2018 Results

Section II. Assessment of the Financial Institution’s Diversity Policies and Practices

4. Practice to Promote Transparency of Organizational 

Diversity and Inclusion 2016 2017 2018

4.1 The financial institution publicizes its diversity and 

inclusion strategic plan. 33% 31% 32%

4.2 The financial institution publicizes its policy on its 

commitment to diversity and inclusion. 64% 71% 75%

4.3. The financial institution is transparent about its progress 

toward achieving diversity and inclusion in its workforce 

and procurement activities, which may include the financial 

institution’s current workforce and supplier demographic 

profiles.

57% 58% 57%

4.4. The financial institution publicizes its opportunities to 

promote diversity, which may include:

4.4(a) Current employment and procurement opportunities.

76% 80% 78%

4.4(b) Forecasts of potential employment and procurement 

opportunities. 23% 23% 24%

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

programs for employees and contractors. 54% 54% 56%

Section II.4 Average: 51% 53% 54%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 45

OTHER ACTIVITIES

Subsection 5: Financial Institutions’ Self-Assessment

There were no changes to the subsection, the average for financial institutions 

performing their annual self-assessment from 2016 to 2018. Financial institutions 

are still reluctant to publish information pertaining to assessments of their diversity 

policies and practices, and results remain low at 29 percent. Financial institutions 

conducting an assessment of its diversity policies and practices annually increased by 

four percent. 

Financial Institutions’ Self-Assessment 2016 to 2018 Results

Section II. Assessment of the Financial Institution’s Diversity Policies and Practices

5. Financial Institutions’ Self-Assessment 2016 2017 2018

5.1 The financial institution conducts an assessment of its 

diversity policies and practices annually. 86% 86% 91%

5.2. The financial institution monitors and evaluates its 

performance under its diversity policies and practices on 

an ongoing basis.

83% 87% 86%

5.3. The financial institution publishes information pertaining to 

its assessment of its diversity policies and practices. 28% 29% 29%

Section II.5 Average: 66% 68% 68%

Since 2016, the FDIC has been encouraging its regulated financial institutions to 

share their diversity and inclusion policies and practices by voluntarily completing 

and submitting their Financial Institution Diversity Self-Assessment. Each year the 

number of participating financial institutions with 100 or more employees that conduct 

a Diversity Self-Assessment increases slightly, with 2018 submissions totaling 16.9 

percent. And, although the FDIC is pleased with the 16.9 percent response rate, greater 

participation is necessary in order for the data to be meaningful for the financial 

services industry as a whole. 

The FDIC is looking to increase its outreach efforts to further encourage and guide its 

regulated financial institutions to implement policies and practices, and share their 

completed self-assessments to further raise awareness to improve levels of diversity 

and inclusion throughout the financial industry as a whole.
46 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Contractors’ Workforces Fair Inclusion

Section 342(c) of the DFA requires that OMWI ensure, to the maximum extent 

possible, the fair inclusion of minorities, women, and minority- and women-owned 

businesses in all business activities of the agency, including procurement.

The FDIC’s commitment to diversity and inclusion extends to the contractors’ 

workforces. It is important that contractors providing goods and services to the FDIC 

divisions and offices engage in employment policies and practices that promote 

diversity and inclusion in their workforce. Contractors seeking to do business with 

the FDIC, must commit to equal opportunity in employment and contracting; and 

make a good faith effort to ensure the fair inclusion of minorities and women in its 

workforce. The fair inclusion standard is incorporated into the FDIC procurement 

policy from solicitation through contract execution. To verify their commitment, upon 

written request, contractors must provide evidence of their affirmative employment 

actions to include minorities and women in their workforce. 

The FDIC review procedures, Contractors’ Workforces Review Process (CWRP) 

assess contractor’s commitment to workforce diversity and inclusion. The CWRP 

establish the procedures to carry out the annual assessment of contractors’ 

good faith efforts. The CWRP monitors compliance with the DFA fair inclusion 

requirements; verify good faith efforts to promote workforce diversity; and provide 

technical assistance to amicably resolve outstanding issues. In 2018 OMWI further 

refined and updated the CWRP based on lessons learned to increase program 

efficiency and effectiveness. 

Since 2016, the FDIC has completed 235 reviews assessing the good faith efforts of 

contractors to promote diversity in employment. This represents 52 percent of the 

average number of active FDIC contractors (448) with awards valued over $100,000. 

Since the number of active contractors does not remain static from year-to-year 

due to the expiration and award of new contracts. In 2019, the FDIC continued 

implementing the CWRP selecting 75 contractors for review.

Good Faith Effort

Good faith efforts are defined as actions contractors undertake to identify, and, if 

present, remove barriers to employment or expansion of employment opportunities 

for minorities and women. These actions may include but are not limited to the 

contractor’s plan to ensure that minorities and women have appropriate opportunities 

to enter and advance within its workforce, including outreach efforts. The FDIC 

contractors, in many cases, are subject to the recordkeeping and reporting 

requirements of the Office of Federal Contract Compliance Programs (OFCCP); 

specifically, they are required to maintain a written affirmative action plan under 

regulations implementing Executive Order 11246. The plan details actions to promote 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 47

OTHER ACTIVITIES

diversity in employment and overcome identified barriers to minority and gender 

equitable employment. 

The FDIC requests support documentation from contractors that demonstrate good 

faith efforts to include minorities and women in the workforce. Contractors may 

provide a copy of their plan that outlines good faith efforts; demographic data; and 

other documentation that highlights their outreach, recruitment and or retention 

efforts to promote workforce diversity and inclusion. As background, the FDIC reviews 

OFCCP compliance investigation results and other available online information on the 

contractors’ diversity and inclusion practices. 

2019 Contractors’ Workforces Review

For 2019, 75 contractors currently doing business with the FDIC were selected to 

provide information on their good faith efforts to ensure the fair inclusion of minorities 

and women in their workforce. The contractors represented approximately 16.7 

percent of active contractors for the year. For three contractors, compliance data was 

found in the OFCCP Compliance Evaluation and Complaint Investigation database. 

However, the information did not correspond to the establishment that support the 

FDIC contract. The selected contractors covered a wide range of sectors as defined 

by the NAICS Codes. The size of the contractors ranged from small companies (30.7 

percent) that employed less than 50 people up to large corporations that employ 

thousands.

Selected contractors were asked to provide a copy of their plan that outlines their good 

faith efforts to include minorities and women in the workforce; demographic data; 

and other support documentation that demonstrated their commitment. Seventy-four 

percent leveraged existing information prepared to comply with Federal EEO and 

Affirmative Action (AA) requirements. For those contractors not subject to mandatory 

EEO or AA recordkeeping and reporting requirements, the FDIC met with them to 

discuss other readily available information such as, outreach activities, diversity 

training, partnerships with minority majority professional and trade organizations, 

etc. All information submitted was reviewed to determine whether the contractor 

efforts demonstrated: leadership commitment to diversity and inclusion; availability of 

plan to ensure minorities and women have opportunities to enter and advance in the 

workforce; alignment of workforce demographics with the labor market; outreach to 

broadly communicate opportunities; and efforts to create an inclusive workforce. The 

FDIC followed up as needed to obtain clarification on good faith effort activities. 

At the conclusion of the review, it was determined the contractors reviewed had made, 

were making, or had a plan in place to make good faith efforts to include minorities 

and women in their workforce.
48 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Community and Small Business Development 

The FDIC Community Affairs program promotes public confidence in the nation’s 

financial system and economic inclusion for rural, minority, low- and moderateincome communities. In 2019, the FDIC continued to implement strategies to 

encourage responsible options for affordable mortgage credit; promote affordable 

insured transactions and savings accounts; strengthen access to financial services 

for small businesses; increase consumer access to sustainable credit; and support 

financial education and literacy. These strategies are supported and sustained through 

collaborative networks and partnerships between the FDIC, banks, and community 

organizations. The purpose is to promote access to banking services and products for 

the unbanked and underbanked. 

As of December 31, 2019, the FDIC provided technical assistance to banks and 

community organizations through more than 230 outreach events. These events were 

designed to increase shared knowledge and support collaboration between financial 

institutions and other community, housing, and small business development resources 

to improve knowledge about the Community Reinvestment Act (CRA). 

The FDIC sponsored outreach events with the Federal Reserve Banks and OCC 

covering basic and advanced CRA training for banks. The agencies offered CRA basics 

for community-based organizations, as well as seminars on establishing effective 

bank and community collaborations. In addition, the FDIC focused on encouraging 

community development initiatives in rural and urban communities. This work 

included workshops to highlight housing needs and programs, economic development 

programs, and community development financial institution collaborations, including 

those serving Native American communities. The FDIC Community Affairs Branch 

and Small Business Administration Office of Entrepreneurial Development signed a 

Memorandum of Understanding in April of 2019 to continue efforts focused on Small 

Business. As of December 31, 2019, the FDIC sponsored 69 Small Business events and 

activities with over 1,500 attendees. 

Partnerships for Access to Mainstream Banking 

The FDIC supported community development and economic inclusion partnerships at 

the local level by providing technical assistance and information resources throughout 

the country, with a focus on unbanked and underbanked households and low- and 

moderate-income communities. Community Affairs staff support economic inclusion 

through work with the Alliances for Economic Inclusion (AEI), Bank On initiatives, other 

coalitions originated by local and state governments, and in collaboration with federal 

partners and non-profit organizations. The FDIC also partnered with other financial 

regulatory agencies to provide information and technical assistance on community 

development to banks and community leaders across the country. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 49

OTHER ACTIVITIES

In the 12 AEI communities and in other areas, the FDIC helped working groups of 

bankers and community leaders develop responses to the financial capability and 

services needs in their communities. To integrate financial capability into community 

services more effectively, the FDIC supported:

§ seminars and training sessions for community service providers and asset-building 

organizations, 

§ workshops for financial coaches and counselors, 

§ promotion of savings opportunities for low-and moderate-income communities, 

§ initiatives to expand access to savings accounts for all ages, 

§ outreach to bring larger numbers of people to expanded tax preparation assistance 

sites, and 

§ education for business owners to help them become bankable. 

The FDIC conducted three events in Spanish in Los Angeles and San Jose, California 

and Reno, Nevada to inform and educate banks, and engage local stakeholders to 

support community efforts to improve financial resiliency of the Spanish-speaking 

community. The FDIC provided how-to guidance in establishing an in-school bank 

branch at a Native American Asset Building Conference in Niagara Falls, New York. 

In 2019, Community Affairs staff provided technical assistance to 35 Bank On 

coalitions to promote banking access. The FDIC convened 20 outreach events 

engaging 515 representatives from banks, local governments and community 

organizations to help advance strategies to expand access to safe and affordable 

deposit accounts and engage unbanked and underbanked consumers. The FDIC 

provided technical assistance to bankers, coalition leaders, and others interested 

in understanding opportunities for banking services designed to meet the needs of 

the unbanked and underbanked. 

As of December 31, 2019, the FDIC sponsored more than 54 events that provided 

opportunities for partners to collaborate on increasing access to bank accounts 

and credit services, opportunities to build savings and improve credit histories, 

and initiatives to significantly strengthen the financial capability of community 

service providers who directly serve consumers with low or moderate incomes and 

small businesses. For example, as a result of an FDIC-hosted bankers roundtable in 

Washington, DC, youth in the Marion Barry Summer Youth Employment Program 

received short push messages via cellphone with information about opening bank 

accounts. 
50 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Promoting Financial Access and Financial Literacy

Effective financial education helps people gain the skills and confidence necessary 

to establish and sustain a banking relationship, achieve financial goals, and improve 

financial well-being. Through Money Smart, the FDIC offers non-copyrighted, highquality, free financial education resources for banks, community organizations, and 

other stakeholders to train people of all ages and small businesses. First launched 

in 2001, regular updates ensure that Money Smart benefits from user feedback and 

current instructional leading practices. The FDIC helps organizations effectively use 

the curriculum, including through the Money Smart Alliance that facilitates quarterly 

webinars for the more than 1,400 member organizations. 

Money Smart Achievements

We released an enhanced Money Smart for Young People curriculum in December, 

providing updated tools to engage educators, parents, and young people in the 

learning process about money. The updated curriculum benefits from insights that 

we received from 26 educators who taught 83 sessions using Money Smart for 

Young People as part of a special project in 2018. In addition, as part of our ongoing 

collaboration with the CFPB, the curriculum helps educators identify opportunities 

to use some of the CFPB’s Building Blocks Activities, which the Bureau developed 

through research to help promote lifelong learning and financial skills development.

The CFPB and the FDIC also released an updated Spanish-language version of the 

Money Smart for Older Adults curriculum. Its goal is to raise awareness among older 

adults and their caregivers on how to prevent elder financial exploitation. Money 

Smart for Older Adults also encourages advance planning and informed financial 

decision-making. The updates provide new information and resources to help older 

adults and their caregivers recognize and prevent fraud, scams, and other types of 

financial exploitation. More than one million copies of the curriculum have been 

ordered in English or Spanish since its original release in 2013. 

Recognizing the impact of Money Smart for Older Adults, the American Society on 

Aging honored the curriculum with the 2019 Gloria Cavanaugh Award for Excellence 

in Training and Education. The award is presented to an individual or program that 

has demonstrated continued excellence in training and education in the field of 

aging. One non-profit in Texas that regularly uses Money Smart for Older Adults

provided feedback from dozens of participants that offered comments such as 

“This course was a lifesaver for me,” “no other place that I know of to get all this 

information,” “the information helped to initiate conversations with friends who may 

be unaware of steps to take care for themselves,” and “the information opened my 

eyes to things I was not aware of.”

The FDIC expanded the reach of the updated Money Smart for Adults, which was 

released in late 2018, through several enhancements responsive to requests by users. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 51

OTHER ACTIVITIES

Updated curriculum was released in Chinese, Korean, Spanish, and Vietnamese. 

The Financial Industry Regulatory Authority (FINRA) also reviewed the curriculum 

and confirmed its consistency with FINRA standards, a step we pursued in response 

to feedback to make it easier for FINRA-regulated entities to conduct educational 

workshops with the curriculum. 

A self-paced online learning game, How Money Smart Are You? is set for release in 

2020. Using a gameshow format, the new product will allow people to build their 

financial skills and knowledge at their own pace, with an option to receive certificates 

of completion. The website for the new game will also include a financial glossary, 

frequently asked questions, and fillable tools to augment the financial knowledge. 

Insights from users in our target audience of adults with low to moderate incomes 

have helped us improve the product, as we conducted field testing of draft games in 

Bethesda, Maryland; Columbus, Ohio; Atlanta, Georgia; Phoenix, Arizona; and at the 

World Institute on Disability in Berkeley, California. 

Money Smart for Small Business is a product developed jointly by the FDIC and the US 

Small Business Administration (SBA). For several months, the SBA and FDIC worked 

with other federal agencies; entrepreneurs; small business training, counseling and 

lending organizations including financial institutions to update its Banking Services 

and Credit Building modules. The purpose of the revision was to address important 

information gaps identified by entrepreneurs and organizations serving small 

businesses and provide practical tools to enhance the learning experience such as 

adding a case study featured in both modules, checklists, a more attractive graphic 

design, and other useful features.

Financial Education Outreach

More than 4,000 prospective trainers were trained on how to use Money Smart,

including representatives of banks, volunteer income tax assistance program sites, 

nonprofit program managers, and others. For example, the FDIC collaborated with a 

national bank to deliver two Money Smart webinar training sessions for more than 

300 bank employees on Money Smart for Adults so that they can effectively use it 

throughout the communities they serve. 

The FDIC leads the Money Smart Alliance to scale promising practices through 

periodic webinars and facilitating collaboration between members. More than 327 

organizations joined the Alliance during 2019, bringing the total number of members 

to 1,409. One example of how Alliance members use Money Smart include the 

University of Wyoming Extension’s use of Money Smart for Adults with its Master 

Money Manager Coach initiative to help financially at-risk individuals improve their 

financial situation across Wyoming. Another example involves a community bank in 

Pennsylvania collaborating with a non-profit organization to provide Money Smart for 
52 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

Adults training to non-violent offenders finishing jail sentences. This program offers 

to connect the participants with appropriate basic banking services to assist with their 

reintegration into society. 

The FDIC also builds the capacity of organizations to use Money Smart through Money 

Smart News, a publication for financial educators to provide updates and ideas for 

implementation. For example, the publication highlighted Bank On South Alabama, 

a group of financial institutions, community groups, and government entities, that 

promote greater bank account access. Partnering financial institutions and their 

employees volunteer to help nonprofits bring the Money Smart program to their 

clients in shelters, substance abuse centers, and other locations. As an example, once 

a week for five weeks, bankers taught Money Smart to students participating in a 

summer youth program. These sessions help people who might not otherwise have 

had an opportunity to engage with a bank to learn about finances and how to open 

a bank account. Another Money Smart News article highlighted one bank’s advice 

for other trainers based on its experience having conducted 1,000 Money Smart 

workshops during the previous year.

Money Smart News also highlighted the 75 banks in the Youth Banking Network 

and continued to share ideas and approaches on how to better connect financial 

education to savings accounts for school-aged children. This diverse set of banks 

includes those with assets from just over $50 million to over $350 billion, with a mix of 

banks operating in rural, suburban, and urban areas. The banks are at various stages, 

ranging from those building an internal business case for pursuing a youth savings 

collaboration to banks with well-established programs that are seeking to expand 

them in scope or quality. One bank in the Network shared that its financial education 

efforts have resulted in about $130 million of new deposits for the bank from adults 

and youth. 

The FDIC staff encourages financial education to be used as a tool for other work. 

For example, the FDIC and the CFPB cohosted the Building Collaboration between 

Financial Institutions and Law Enforcement to Prevent and Address Elder Financial 

Abuse webinar on July 25, drawing more than 4,300 registrations. Money Smart for 

Older Adults was described as a tool to foster local collaboration and education during 

the presentation, and feedback after the session from banks confirmed examples 

of its use. Moreover, the FDIC participated in a twitter event hosted by the Federal 

Emergency Management Agency during financial capability month. The chat had more 

than 36 million potential impressions.

The Money Smart website was also redesigned to improve the user experience, 

including through new videos. The Money Smart related webpages had more than 

250,000 views during the year. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 53

OTHER ACTIVITIES

Minority Depository Institution Activities

The preservation and promotion of MDI remains a long-standing and high priority 

for the FDIC. In 2019, the FDIC expanded engagement with MDIs and continued to 

promote and support MDI and CDFI banks with industry-led strategies to better serve 

their communities. These strategies include increasing collaboration between MDIs 

and other financial institutions; partnering to share costs, raise capital, or pool loans; 

and making innovative use of available federal programs. The FDIC supports these 

efforts through research, outreach, and engagement to better understand MDI issues, 

as well as by providing technical assistance and education and training for MDI and 

CDFI banks. 

During 2019, the FDIC published a research study, Minority Depository Institutions: 

Structure, Performance, and Social Impact that explores changes in FDIC-insured 

MDIs, their role in the financial services industry, and their impact on the communities 

they serve. The study showed that MDI financial performance improved significantly 

over the past five years; MDIs consolidated significantly, but more gradually than 

community banks overall; and MDIs are important service providers to low- or 

moderate-income and minority communities.

The FDIC established a new MDI Subcommittee of the Advisory Committee on 

Community Banking (CBAC) which held its inaugural meeting in December 2019. The 

OMWI Director attended this meeting. The subcommittee provides an opportunity for 

minority bankers to discuss key issues and share feedback directly with FDIC Board 

members and senior management. 

In addition, the FDIC added additional MDI bankers to the CBAC membership to further 

bring MDI perspectives and issues to the table.

Throughout 2019, the FDIC hosted three roundtables with large banks and MDI 

bankers to foster collaboration in support of the continued vibrancy of MDIs and 

their communities. During the roundtables, executives from 29 large banks and 24 

MDIs discussed potential partnerships including financial support, lending activities, 

or service activities including technical assistance. Each roundtable outlined how 

both MDIs and other institutions may realize business and regulatory benefits by 

developing partnerships, drawing upon the FDIC’s Resource Guide for Collaboration 

with Minority Depository Institutions published in December 2017. In addition, 

the FDIC clarified how relationships with MDIs receive consideration under the 

Community Reinvestment Act. The FDIC is following up to monitor the outcomes of 

the roundtables and highlight successful partnerships at future roundtables.

One of the FDIC’s statutory goals is to preserve the minority character in failed bank 

acquisitions. In 2019, the FDIC hosted three workshops and two webinars with MDI 

bankers to discuss the failed bank bidding process and special marketing procedures 
54 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

for MDIs. In addition, the FDIC implemented a new marketing procedure that provides 

a two-week window exclusively for MDIs. During this window, the FDIC contacts all 

qualified MDIs on the bid list to ensure they received an invitation to bid, and provides 

full access to the data room if an MDI is interested. The FDIC also describes in detail 

the failing bank transaction and offers to provide technical assistance on the bidding 

process. Following the two-week period, the FDIC invites all other qualified bidders to 

the failing bank project. 

One MDI failed in 2019, and the acquirer was another MDI. In fact, FDIC’s research 

shows that over a 17-year period, most of the assets of merged and failed MDIs have 

been acquired by other MDIs. Of the nearly $23 billion in failed-bank assets during 

this period, 86 percent were acquired by another minority bank. In June 2019, the 

FDIC hosted the interagency MDI and CDFI bank conference, Focus on the Future: 

Prospering in a Changing Industry, in collaboration with the OCC and FRB. The 

conference featured a dialogue with federal leadership, who provided updates on 

programs and policies that can help MDI and CDFI banks achieve their goals. Minority 

bank CEOs discussed strategies for their customers, employees and communities in 

order to succeed in today’s marketplace. Experts discussed innovation, collaboration, 

supervision, and FDIC research. Interactive workshops addressed topics such as 

cybersecurity and threat monitoring tools and resources, understanding MDIs and 

their markets, succession management, federal programs supporting MDIs, the 

benefits of participating in the CDFI Fund’s programs, and preserving the minority 

character in failing bank transactions.

The FDIC also continuously pursued efforts to improve communication and interaction 

with MDIs and to respond to the concerns of minority bankers in 2019. The agency 

maintains active outreach with MDI trade groups and offers to arrange annual 

meetings between FDIC regional management and each MDI’s board of directors to 

discuss issues of interest. The FDIC routinely contacts MDIs to offer return visits and 

technical assistance following the conclusion of FDIC safety and soundness, consumer 

compliance, CRA, and specialty examinations to help bank management understand 

and implement examination recommendations. These return visits, normally 

conducted within 90 to 120 days after the examination, are intended to provide useful 

recommendations or feedback for improving operations, not to identify new issues.

Through its public website (www.fdic.gov), the FDIC invites inquiries and provides 

contact information for any MDI to request technical assistance at any time. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 55

OTHER ACTIVITIES

In 2019, the FDIC provided 134 individual technical assistance sessions on nearly 50 

risk management, consumer compliance, and resolution topics, including: 

§ Accounting, 

§ Bank Secrecy Act and Anti-Money Laundering,

§ Community Reinvestment Act, 

§ Compliance management,

§ Funding and liquidity, 

§ Information technology risk management and cybersecurity,

§ Internal audit, and

§ Failed bank acquisition.

The FDIC also held outreach, training, and educational programs for MDIs through 

conference calls and regional banker roundtables. In 2019, topics of discussion for 

these sessions included many of those listed above, as well as collaboration and 

partnerships, the current expected credit loss accounting methodology, IT vendor 

management, cybersecurity, innovation, Bank Secrecy Act, CDFI Fund Programs, and 

emerging technology. 
56 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

OTHER ACTIVITIES

PAGE 

INTENTIONALLY 

LEFT BLANK
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 57

CONCLUSION

During 2019, OMWI continued to make progress in enhancing the diversity of the 

FDIC’s workforce and business practices.

The racial, ethnic, and gender diversity of the workforce continues a steady increase 

since the passage of Section 342 of the DFA. Both the percentages for minorities (30.4 

percent) and women (44.8 percent) in the FDIC’s permanent workforce have increased 

since the passage of Section 342 of the DFA. The FDIC continues to face challenges in 

attracting and retaining minorities and women in its bank examiner workforce, which 

is the principal feeder group for a significant percentage of executive and managerial 

leadership positions at the agency. While there has been gradual progress, the FDIC 

will continue to implement strategies to garner greater improvements in this area.

With regard to increasing MWOB participation, the FDIC focused on opportunities 

for MWOBs in its non-financial recurring services and continued to implement new 

procurement strategies that restructured large contracts into smaller contracts 

to increase MWOB participation and contract awards. The FDIC maintained an 

aggressive vendor outreach and education program participating in business expos 

and technical assistance events which resulted in 135 new MWOBs being added to 

the CRL. Despite the decrease in bank resolution activities, which has been the major 

source for contracting opportunities, the FDIC has been successful at identifying new 

opportunities for MWOBs.
58 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

CONCLUSION

The FDIC remained fully engaged and continues to implement the Financial Institution 

Diversity program to meet the requirements of Section 342 of the DFA by encouraging 

its regulated financial institutions to assess their diversity policies and practices. 

Further, the FDIC’s OMWI continued its implementation of the Contractors’ Workforces 

Fair Inclusion program to assess whether its contractors have made good faith efforts 

to include minorities and women in their workforce.

In every respect, the FDIC’s accomplishments during 2019 are in concert with the 

requirements of Section 342 of the DFA. The FDIC will continue to develop strategies 

and to capitalize on opportunities to further meet DFA requirements. Specifically, the 

FDIC will continue to examine requirements for goods and services in the procurement 

and contracting arena to optimize opportunities to increase MWOB participation, as 

annual contract awards continue to decline significantly due to the reduction in the 

number of financial institution failures; and will continue to recruit, hire, and retain the 

most talented and diverse workforce to sustain its mission.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 59

APPENDICES
60 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

APPENDICES

Appendix A

FDIC Contracting Awards to MWOBs, Five–Year Trend 

(in millions)

2015 2016 2017 2018 2019

Total Awards $858.4 $508.8 $523.7 $499.5 $554.0

100.0% 100.0% 100.0% 100% 100.0%

Minority- Owned or

Women- Owned

Business Totals

$211.6 $93.9 $96.7 $122.5 $173.5

24.7% 18.5% 18.5% 24.5% 31.3%

Minority- Owned $145.2 $56.6 $66.7 $45.8 $106.0

16.9% 11.0% 12.7% 9.2% 19.1%

Women- Owned $104.2 $47.4 $46.2 $83.0 $75.8

12.1% 9.3% 8.8% 16.6% 13.7%

Both Minority- Owned

and Women- Owned

$37.8 $10.0 $16.2 $6.3 $8.3

4.3% 1.9% 3.0% 1.3% 1.5%

Asian American $51.8 $25.0 $31.2 $33.9 $83.1

6.0% 4.9% 6.0% 6.8% 15.0%

Black American $30.7 $9.4 $32.7 $1.9 $5.8

3.6% 1.9% 6.2% 0.4% 1.0%

Hispanic American $43.2 $20.6 $1.6 $7.0 $13.3

5.0% 4.0% 0.3% 1.4% 2.4%

Native American $0.0 $0.1 $0.9 $2.9 $3.5

0.0% 0.0% 0.2% 0.6% 0.6%

Other Minority

$19.5 $1.4 $0.3 $0.1 $0.3

2.3% 0.3% 0.0% 0.0% 0.1%

FDIC Payments to MWOBs, Five–Year Trend (in millions)

2015 2016 2017 2018 2019

Total Contract Payment $507.2 $415.2 $414.0 $429.6 $466.6

100.0% 100.0% 100.0% 100.0% 100.0%

Minority- Owned $89.3 $56.0 $54.6 $49.5 $54.0

17.6% 13.5% 13.2% 11.5% 11.6%

Women- Owned $83.2 $66.8 $66.9 $59.5 52.0

16.4% 16.1% 16.2% 13.9% 11.2%

Both Minority- Owned

and Women- Owned

$30.0 $11.3 $11.9 $11.1 $7.7

5.9% 2.8% 2.9% 2.6% 1.7%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress 61

APPENDICES

Appendix B

FDIC 2019 Contract Awards by Top Ten NAICS Codes

NAICS NAICS Description

Dollar Amount of 

Top 10 Awards

Dollar Amount of 

MWOB Awards

% of Dollars to 

MWOBs

541512

Computer Systems Design 

Services $ 96,667,762.19 $ 14,285,969.52 3.0%

561612

Security Guards and Patrol 

Services $ 86,692,028.62 $ - 0.0%

541519

Other Computer Related 

Services $ 65,644,039.64 $ 45,089,547.53 9.6%

541611

Administrative Management 

and General Management 

Consulting Services $ 48,377,390.98 $ 21,582,150.98 4.6%

511210 Software Publishers $ 46,940,423.60 $ 9,896,297.24 2.1%

522110 Commercial Banking $ 37,919,918.37 $ 35,862,152.22 7.6%

541511

Custom Computer 

Programming Services $ 27,391,227.80 $ 20,940,742.99 4.5%

561210 Facilities Support Services $ 24,228,707.66 $ - 0.0%

334111

Electronic Computer 

Manufacturing $ 21,665,766.72 $ 6,853,265.21 1.5%

519130

Internet Publishing and 

Broadcasting and Web 

Search Portals $ 14,219,668.61 $ - 0.0%

Total $ 469,746,934.19 $154,510,125.69 32.9%
62 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

APPENDICES

Appendix C

FDIC Total, Permanent, and Executive Manager Workforce, 

Five-Year Trend

Total Workforce (Permanent and Non-Permanent)

2015 2016 2017 2018 2019 Change

Minority 28.2% 28.0% 28.7% 29.8% 30.4% +0.6%

Non-Minority 71.8% 72.0% 71.3% 70.2% 69.6% -0.6%

Men 55.3% 55.2% 55.2% 55.2% 55.1% 0.1%

Women 44.7% 44.8% 44.8% 44.8% 44.9% -0.1%

Permanent Workforce

2015 2016 2017 2018 2019 Change

Minority 28.0% 28.2% 29.0% 29.9% 30.4% +0.5%

Non-Minority 72.0% 71.8% 71.0% 70.1% 69.6% -0.5%

Men 54.8% 54.9% 55.1% 55.3% 55.2% -0.1%

Women 45.2% 45.1% 44.9% 44.7% 44.8% +0.1%

Total Workforce - Executive Manager (Permanent and Non-Permanent)

2015 2016 2017 2018 2019 Change

Minority 18.0% 18.8% 18.3% 17.6% 16.7% -0.9%

Non-Minority 82.0% 81.2% 81.7% 82.4% 83.3% +0.9%

Men 66.9% 63.2% 61.1% 64.0% 62.3% -1.7%

Women 33.1% 36.8% 38.9% 36.0% 37.7% +1.7%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 63

APPENDICES

Appendix D

2019 FDIC Major Occupations, Total Workforce

Job Title/Series 

Occupational CLF

Race/Ethnicity

Non - Hispanic or Latino

Total Employees Hispanic 

American White Black American Asian American American Indian 

or Alaska Native 

Two or more 

races 

All Women Men Women Men Women Men Women Men Women Men Women Men Women Men

Economist (0110)

# 80 23 57 0 3 12 45 3 2 7 7 0 0 1 0

% 100.0% 28.8% 71.3% 0.0% 3.8% 15.0% 56.3% 3.8% 2.5% 8.8% 8.8% 0.0% 0.0% 1.3% 0.0%

CLF 100.0% 32.9% 67.1% 1.9% 3.3% 25.2% 55.8% 2.7% 2.8% 2.7% 4.4% 0.1% 0.2% 0.4% 0.6%

Financial Administration 

and Program (0501)

# 156 75 81 1 3 28 58 38 13 7 6 1 0 0 1

% 100.0% 48.1% 51.9% 0.6% 1.9% 17.9% 37.2% 24.4% 8.3% 4.5% 3.8% 0.6% 0.0% 0.0% 0.6%

CLF 100.0% 56.3% 43.8% 5.8% 4.0% 38.6% 32.5% 7.5% 4.7% 3.1% 1.7% 0.4% 0.3% 1.0% 0.6%

Accountants and 

Auditors (0510/0511) 

# 80 44 36 1 0 18 26 14 6 10 2 0 0 1 2

% 100.0% 55.0% 45.0% 1.3% 0.0% 22.5% 32.5% 17.5% 7.5% 12.5% 2.5% 0.0% 0.0% 1.3% 2.5%

CLF 100.0% 60.1% 39.9% 3.9% 2.2% 44.2% 31.8% 5.6% 2.4% 5.4% 3.0% 0.3% 0.1% 0.7% 0.4%

Financial Institution 

Examining (0570) 

# 2,715 1,064 1,651 42 73 774 1,383 171 104 51 57 7 11 19 23

% 100.0% 39.2% 60.8% 1.5% 2.7% 28.5% 50.9% 6.3% 3.8% 1.9% 2.1% 0.3% 0.4% 0.7% 0.8%

CLF 100.0% 45.2% 54.8% 3.7% 3.1% 28.3% 44.1% 8.4% 3.4% 3.7% 3.5% 0.2% 0.1% 1.0% 0.6%

Attorney (0905) 

# 313 130 183 2 6 102 157 14 12 11 4 1 1 0 3

% 100.0% 41.5% 58.5% 0.6% 1.9% 32.6% 50.2% 4.5% 3.8% 3.5% 1.3% 0.3% 0.3% 0.0% 1.0%

CLF 100.0% 33.3% 66.7% 1.9% 2.5% 26.7% 59.7% 2.5% 2.1% 1.6% 1.7% 0.1% 0.1% 0.6% 0.6%

General Business and 

Industry (1101)

# 266 91 175 1 8 63 134 18 15 7 13 0 1 2 4

% 100.0% 34.2% 65.8% 0.4% 3.0% 23.7% 50.4% 6.8% 5.6% 2.6% 4.9% 0.0% 0.4% 0.8% 1.5%

CLF 100.0% 63.3% 36.7% 5.9% 2.9% 43.8% 27.1% 8.8% 3.6% 3.3% 2.4% 0.4% 0.2% 1.1% 0.6%
64 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2019 Report to Congress

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FDIC-007-2020