8/23/2018 1

Analysis of Diversity Self- Assessments for 2016

ANALYSIS OF 2016 REPORTING PERIOD

Section 342 of the Dodd-Frank Act required agencies to establish OMWIs and instructed the OMWI director 

at each agency to develop standards for assessing the diversity policies and practices of the institutions they 

regulate. FDIC has now completed its analysis of the responses received from these institutions for the first 

reporting period (2016).

BACKGROUND

The FDIC sought and 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, FDIC Form 2710/05, Diversity Self-Assessment of FDIC 

Regulated Financial Institutions (OMB 3064-0200, Expiration Date 02/29/2020). In October 2016, the 

Acting Director, FDIC OMWI, distributed a letter to the Presidents and Chief Executive Officers of 805 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. In March 2016, a second reminder letter from the Acting Director was distributed to financial 

institutions to encourage participation. 

Financial institutions that voluntarily conducted a self-assessment of their diversity policies and practices 

could use FDIC’s instrument or its own assessment tool. The self- assessment instrument is separated into 

five 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

The FDIC received diversity self-assessments from 95 (11.8 percent) of its regulated financial institutions. 

FDIC conducted a coordinated review of the financial industry’s diversity policies and practices for the 

purpose of monitoring progress and trends of diversity and inclusion in employment and contracting 

activities. The reviews also provided the opportunity to identify best practices in the form of exemplary 

diversity policies and practices. Results of FDIC’s analyses establish the baseline for subsequent reporting 

years, and are summarized below. 

Any questions about the diversity self-assessment should be directed to FDIC’s OMWI. The point of contact 

is Victor Christiansen, Branch Chief, at VChristiansen@fdic.gov.
8/23/2018 2

The 2016 reporting period provided FDIC with a baseline for analysis. The 2017 reporting period will be 

compared to this baseline. 

SELF-ASSESSMENT BENCHMARKING RESULTS FOR 2016 REPORTING PERIOD

AGGREGATED ASSESSMENT RESULTS - OVERALL BREAKDOWN BY FDIC REGION AND ASSET SIZE

Financial Institutions by FDIC Regional Offices

The self-assessments were aggregated by FDIC region, with the New York region having the most reported 

financial institutions (30) and the Dallas region following with 20 reported financial institutions. Both, the 

Chicago and Atlanta regions had 13 financial institutions reporting, and the San Francisco region had 12. 

The least reported region was Kansas City, with seven financial institutions. The FDIC received responses at 

rates proportional to the total number of regulated entities with 100 or more employees in each region.

Financial Institutions by Asset Size

Financial Institutions were further aggregated by Asset Size, which are divided by Small, Intermediate Small 

and Large1. Small institutions have assets less than $307 million; Intermediate Small institutions have assets 

between $307 million to $1.226 billion; and Large institutions have assets totaling more than $1.226 billion. 

Most of FDIC’s regulated financial institutions that completed a self-assessment fall in the Intermediate 

Small category (55 financial institutions). Thirty-five were Large institutions and 5 were Small.

A comparative analysis between the asset size in relation to the FDIC Regional Office to which they report 

revealed that the largest number of self-assessments was submitted by financial institutions in the New 

York region (30). Of the 30 institutions, 11 are categorized as being Large institutions; 19 Intermediate 

Small institutions; and zero Small institutions. The second largest number of self-assessments was 

submitted by financial institutions in the Dallas region (20). Of the 20 institutions, 16 were categorized as 

Intermediate Small; 3 were Large; and 1 Small. Financial institutions reporting from FDIC’s Chicago region 

(13) were categorized as 1 Large; 9 Intermediate Small; and 3 Small. Financial institutions reporting from 

the Atlanta region (13) included 9 Large; 4 Intermediate Small; and zero Small. Financial institutions 

located in San Francisco region (12) were categorized as 6 Large institutions; 4 Intermediate Small 

institutions; and 2 Small institutions. The Kansas City region had the lowest number of submissions (7). Of 

the 7 institutions, 3 are Large and 3 are Intermediate Small.

 

1 Reference FFIEC’s Community Reinvestment Act (CRA) https://www.ffiec.gov/CRA/pdf/AssetThreshold2016.pdf
8/23/2018 3

AGGREGATED ASSESSMENT RESULTS - OVERALL BREAKDOWN BY EACH 

STANDARD:

SECTION I - FINANCIAL INSTITUTION INFORMATION

Eighty-six percent of the 95 financial institutions reported having a designated Diversity and Inclusion 

Officer; while forty-seven percent of the financial institutions have someone designated as the Supplier 

Diversity Officer. 

SECTION II – ASSESSMENT OF THE FINANCIAL INSTITUTION’S DIVERSITY POLICIES AND PRACTICES

Subsection 1: Organizational Commitment to Diversity and Inclusion

A high percentage of respondents reported having an organizational commitment to Diversity and Inclusion 

within their Financial Institutions, from the governing body to senior officials and managers. On average, 

82% indicated that they practice the Standards outlined in this subsection. 

Organizational Commitment to Diversity and Inclusion Results

Section II. Assessment of the Financial Institution's Diversity Policies and Practices

1. Organizational Commitment to D&I

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.

1.2 The financial 

institution has a 

diversity and 

inclusion policy that 

is approved and 

supported by senior 

leadership, including 

senior management 

and the board of 

directors.

1.3 The financial 

institution provides 

regular progress 

reports to the board 

and senior 

management.

1.4 The financial 

institution regularly 

conducts training and 

provides educational 

opportunities on 

equal employment 

opportunity and on 

diversity and 

inclusion.

1.5 The financial 

institution has a 

senior level official, 

preferably with 

knowledge of and 

experience in 

diversity and 

inclusion policies 

and practices, who 

oversees and directs 

the financial 

institution's diversity 

and inclusion efforts.

1.6 The financial 

institution takes 

proactive steps to 

promote a diverse pool 

of candidates, including 

women and minorities, 

in its hiring, recruiting, 

retention, and 

promotion, as well as in 

its selection of board 

members, senior 

management, and other 

senior leadership

positions.

79 77 71 78 80 81

83% 81% 75% 82% 84% 85%

Average# 78 / Average% 82
8/23/2018 4

Subsection 2: Workforce Profile and Employment Practices

There is a range of participation in the financial institutions’ promotion of fair inclusion of minorities and 

women in their workforce by publicizing employment opportunities, creating relationships with minority 

and women professional organizations and educational institutions, creating a culture that values the 

contribution of all employees, and encouraging a focus on these objectives when evaluating the performance 

of managers. On average 77% responded that they practice the Standards outlined in this subsection.

Workforce Profile and Employment Practices Results

Section II. Assessment of the Financial Institution's Diversity Policies and Practices

2. Workforce Profile and Employment Practices

2.1 The financial 

institution 

implements 

policies and 

practices related 

to workforce 

diversity and 

inclusion in a 

manner that 

complies with all 

applicable laws.

2.2 The financial 

institution 

ensures equal 

employment 

opportunities for 

all employees 

and applicants 

for employment 

and does not 

engage in 

unlawful 

employment 

discrimination 

based on gender, 

race, or 

ethnicity.

2.3 The financial 

institution has 

policies and 

practices that 

create diverse 

applicant pools 

for both internal 

and external 

opportunities 

that may 

include:2.3(a) 

Outreach to 

minority and 

women 

organizations.

2.3(b) Outreach 

to educational 

institutions 

serving 

significant 

minority and 

women student 

populations.

2.3(c) 

Participation in 

conferences, 

workshops, and 

other events to 

attract 

minorities and 

women and to 

inform them of 

employment and 

promotion 

opportunities.

2.4 The financial 

institution utilizes 

both quantitative and 

qualitative 

measurements to 

assess its workforce 

diversity and 

inclusion efforts. 

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.

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.

89 91 70 63 58 75 66

94% 96% 74% 66% 61% 79% 69%

Average# 73 / Average% 77
8/23/2018 5

Subsection 3: Procurement and Business Practices - Supplier Diversity

Overall, a low percentage of respondents reported that they have metrics and analytics to monitor how 

much they spend to procure and contract for goods and services; how much they spend with minorityowned and women-owned businesses; and that they are knowledgeable about the availability of relevant 

minority-owned and women-owned businesses. On average 24% responded that they practice the 

Standards outlined in this subsection; the lowest percentage, 15%, reported having contracts that 

subcontracted with minority-owned and women owned businesses. 

Procurement and Business Practices - Supplier Diversity Results

Section II. Assessment of the Financial Institution's Diversity Policies and Practices

3. Procurement and Business Practices - Supplier Diversity

3.1 The financial 

institution has a 

supplier diversity 

policy that provides 

for a fair opportunity 

for minority-owned 

and women-owned 

businesses to 

compete for 

procurement of 

business goods and 

services. 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 institutional 

assets, and the 

development of the 

financial institutional 

equity investments.

3.2 The financial 

institution has 

methods to 

evaluate its 

supplier diversity, 

which may 

include metrics 

and analytics 

related to:3.2(a) 

Annual 

procurement 

spending.

3.2(b) Percentage 

of contract dollars 

awarded to 

minority-owned 

and womenowned businesses 

by race, ethnicity, 

and gender.

3.2(c) Percentage 

of contracts with 

minority-owned 

and womenowned business 

subcontractors.

3.3. The financial 

institution has 

practices to 

promote a diverse 

supplier pool, 

which may 

include:3.3(a) 

Outreach to 

minority-owned 

and womenowned 

contractors and 

representative 

organizations.

3.3(b) 

Participation in 

conferences, 

workshops, and 

other events to 

attract minorityowned and 

women-owned 

firms and inform 

them of 

contracting 

opportunities.

3.3(c) An 

ongoing process 

to publicize its 

procurement 

opportunities.

39 22 15 14 29 19 22

41% 23% 16% 15% 31% 20% 23%

Average# 23 / Average% 24
8/23/2018 6

Subsection 4: Practice to Promote Transparency of Organizational Diversity and Inclusion

The self-assessments show that financial institutions engage in practices that provide greater information, 

awareness and transparency to the public regarding their diversity and inclusion policies and practices. On 

average, 52 % responded in the affirmative to this section.

Practice to Promote Transparency of Organizational Diversity and Inclusion Results

Section II. Assessment of the Financial Institution's Diversity Policies and Practices

4. Practice to Promote Transparency of Organizational D&I

4.1 The financial 

institution publicizes 

its diversity and 

inclusion strategic 

plan.

4.2 The financial 

institution publicizes 

its policy on its 

commitment to 

diversity and 

inclusion.

4.3. The financial 

institution is 

transparent about its 

progress toward 

achieving diversity 

and inclusion in its 

workforce and 

procurement 

activities, which may 

include the financial 

institution's current 

workforce and 

supplier demographic 

profiles.

4.4. The financial 

institution publicizes 

its opportunities to 

promote diversity, 

which may include:

4.4(a) Current 

employment and 

procurement 

opportunities.

4.4(b) Forecasts of 

potential employment 

and procurement 

opportunities.

4.4(c) The availability 

and use of mentorship 

and developmental 

programs for 

employees and 

contractors.

31 61 54 72 22 51

33% 64% 57% 76% 23% 54%

Average# 49 / Average% 52
8/23/2018 7

Subsection 5: Financial Institutions’ Self-Assessment

Approximately 85% of financial institutions reported positively to having successful diversity policies and 

practices, and allocating time and resources to monitor and evaluate performance under their diversity 

policies and practices on an ongoing basis. However, only 28% publish information pertaining to their 

assessment of diversity policies and practices. 

Financial Institutions’ Self- Assessment Results

Section II. Assessment of the Financial Institution's Diversity Policies and Practices

5. Financial Institutions' Self-Assessment

5.1 The financial institution conducts an 

assessment of its diversity policies and 

practices annually.

5.2. The financial institution monitors 

and evaluates its performance under its 

diversity policies and practices on an 

ongoing basis.

5.3. The financial institution publishes 

information pertaining to its 

assessment of its diversity policies and 

practices.

82 79 27

86% 83% 28%

Average# 63 / Average% 66

SECTION III - DIVERSITY DATA

Subsection 1: Workforce Profile

A majority of financial institutions (approximately 80%) provided diversity data on their workforce, 

management, and board members. The aggregated numbers are provided below. 

Diversity Data for Workforce Profile

Section III. Diversity Data

1-3. Workforce Profile

Diversity Data Total Women# Women% Men# Men% Minorities# Minorities% NonMinorities#

NonMinorities%

1. Total 

Workforce 46,269 28,516 62% 17,753 38% 14,792 32% 31,477 68%

2. Total 

Management 5,333 2,191 41% 3,142 59% 1,219 23% 4,114 77%

3. Total Board 

Members 850 128 15% 722 85% 82 10% 768 90%

Subsection 2: Procurement-Supplier Diversity

The data submitted on the procurement supplier diversity was insufficient. Therefore, an accurate 

portrayal of industry practices could not be established. 

 
8/23/2018 8

EXEMPLARY PRACTICES

FDIC identified four exemplary practices that financial institutions implemented as part of their recruitment, 

supplier diversity procurement and training practices.

1. More specifically, several financial institutions provided information about hiring a third party 

company to conduct a survey for assessing employee engagement and satisfaction levels. The 

benefits of hiring a third party company to survey employees are:

• Neutral expertise in administration,

• Unbiased results, and

• Increase confidence level for the employees as they complete the survey anonymously.

2. A financial institution developed a partnership with trade organizations to create an eight week 

training course about careers in the financial services industry for young adults from low income 

and underrepresented communities.

3. A financial institution utilizes its Advisory Boards of Directors to assist with Diversity and Inclusion 

initiatives, including the City Advisory Board and the Women’s Advisory Board. These Boards serve 

as referral sources for candidate and customer prospects, and advise and participate in the 

institution’s community outreach efforts. The Women’s Advisory Board is made up of local women 

professionals, entrepreneurs, and community volunteers that focus on outreach to women and 

women-owned businesses.

4. A financial institution conducted a local and regional supplier survey to determine how many 

diverse suppliers were available to the financial institution to procure goods and services.