FEDERAL DEPOSIT INSURANCE CORPORATION

Office of Minority and Women Inclusion

Diversity and Business Inclusion Branch

FINANCIAL INSTITUTION 

DIVERSITY SELF-ASSESSMENT

2019 ANALYSIS
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 

CONTENTS

EXECUTIVE SUMMARY: 2019 DIVERSITY SELF-ASSESSMENT 1

Promoting Diversity and Inclusion ......................................................................................................1

Outreach to Increase Participation......................................................................................................1

Aggregated Results ..............................................................................................................................2

2019 REPORTING PERIOD: SELF-ASSESSMENT RESULTS 3

Encouraging Self-Assessment Participation .......................................................................................3

Partnering with Financial Institutions.................................................................................................4

Expanding Outreach to Financial Institutions.....................................................................................5

Maximizing Technology for Increased Efficiency ................................................................................5

Promoting Diversity and Inclusion in the Banking System.................................................................6

Increasing Transparency on Challenges ..............................................................................................8

EXEMPLARY PRACTICES FOR 2019 9

Organizational Commitment to Diversity and Inclusion ....................................................................9

Workforce Profile and Employment Practices ................................................................................. 10

Procurement and Business Practices - Supplier Diversity............................................................... 11

Monitoring, Tracking and Reporting on Diversity Practices ............................................................ 11

CONCLUSION 12
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS i

APPENDIX 1: AGGREGATED ASSESSMENT RESULTS 13

Results by FDIC Region...................................................................................................................... 13

Financial Institutions by FDIC Region.......................................................................................... 13

Overall Breakdown by Each Standard .............................................................................................. 14

Section I – Financial Institution Information .............................................................................. 14

Section II – Assessment of the Financial Institution’s Diversity Policies and Practices............ 14

Standard 1: Organizational Commitment to Diversity and Inclusion................................... 14

Standard 2: Workforce Profile and Employment Practices................................................... 16

Standard 3: Procurement and Business Practices - Supplier Diversity.................................17

Standard 4: Practice to Promote Transparency of Organizational Diversity and Inclusion.....19

Standard 5: Financial Institutions’ Self-Assessment............................................................. 20

Section III – Diversity Data........................................................................................................... 21

Subsection 1: Workforce Profile............................................................................................. 21

Subsection 2: Procurement-Supplier Diversity ..................................................................... 21

APPENDIX 2: TREND ANALYSIS OF SELF-ASSESSMENT RESULTS: REPORTING 

PERIODS 2016-2019 22

Overall Breakdown by FDIC Region for Reporting Period 2016 to 2019 .......................................... 23

Financial Institutions by FDIC Region.......................................................................................... 23

Aggregated Assessment Results for Reporting Period 2016 to 2019: 

Comparative Breakdown by Each Standard..................................................................................... 24

Section I – Financial Institution Information .............................................................................. 24

Section II – Assessment of the Financial Institution’s Diversity Policies and Practices............ 24

Subsection 1: Organizational Commitment to Diversity and Inclusion ............................... 25

Subsection 2: Workforce Profile and Employment Practices ............................................... 27

Subsection 3: Procurement and Business Practices - Supplier Diversity............................. 29

Subsection 4: Practice to Promote Transparency of Organizational Diversity and Inclusion ....31

Subsection 5: Financial Institutions’ Self-Assessment ......................................................... 33

Section III – Diversity Data........................................................................................................... 34

Subsection 1: Workforce Profile............................................................................................. 34

Subsection 2: Procurement-Supplier Diversity .................................................................... 34

Contents
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 1

Executive Summary: 

2019 Diversity Self-Assessment 

PROMOTING DIVERSITY AND INCLUSION

The FDIC’s commitment to diversity, equity, inclusion and accessibility (DEIA) remains strong. 

We engage with our regulated financial institutions to learn about their diversity programs and 

unique challenges so we are in a better position to provide technical assistance. Annually, we invite 

our institutions to complete a self-assessment, encouraging them to gather and analyze data 

concerning their diversity policies and practices. We encourage our financial institutions to share 

their assessment results with the FDIC. 

The FDIC developed the diversity self-assessment framework based on the Joint Standards for 

Assessing our Regulated Entities’ Diversity Policies and Practices that we established with five other 

federal agencies. The Standards provide institutions with data that support the adoption of leading 

diversity practices into their workforce, workplace, and supplier diversity. The data also can help 

institutions to build better relationships with their customers and communities served. 

The self-assessment covers the previous calendar year (the reporting period) and is due by June 

30th after the close of the calendar year. For the 2019 reporting period, the FDIC invited 787 

supervised financial institutions with 100 or more employees to participate in the diversity selfassessment. More than 150 financial institutions submitted self-assessments, representing a 19 

percent submission rate, an increase of 14 percent over the 2018 reporting period. 

OUTREACH TO INCREASE PARTICIPATION

The FDIC’s Office of Minority and Women Inclusion (OMWI) expanded outreach to learn about the 

challenges and support our financial institutions through the diversity self-assessment process. 

OMWI analyzed assessments received for diversity trends and exemplary practices. And in 2019, 
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 2

Executive Summary

OMWI continued efforts to maximize the use of technology, streamlining the data collection 

process. For the first time, our financial institutions could submit their diversity self-assessment 

electronically, reducing the burden and providing financial institutions with access to their data 

year-round.

During the reporting period, OMWI also presented at banking conferences, preparing assistive 

resource materials, and co-hosting the annual Summit with the other OMWI agencies. Also, we 

encouraged our regulated entities’ participation providing financial institutions with technical 

assistance on their diversity self-assessment. 

AGGREGATED RESULTS

The 2019 assessment results were consistent with the previous 2018 reporting period, with slight 

decreases and no notable improvements. For detailed analysis results see Appendix 1 – Aggregated 

Assessment Results and Appendix 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 

2016-2019. 

Financial institutions should direct questions about the diversity self-assessment to OMWI at 

Section342@fdic.gov.
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 3

2019 Reporting Period: 

Self-Assessment Results

Our regulated institutions provide employment, banking products, and services that have a broad 

impact on their communities’ economic well-being. To promote transparency and accountability 

about diversity, Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act 

established the Office of Minority and Women Inclusion (OMWI) with responsibility for diversity 

in management, employment, and business activities. The FDIC’s OMWI, in collaboration with 

the other federal financial regulators, developed Standards for assessing the diversity policies 

and practices of our regulated institutions. The Standards are outlined in the Interagency Joint 

Standards for Assessing the Diversity Policies and Practices issued in 2015. 

The OMWI’s Financial Institution Diversity Program (FID) manages the annual assessment process. 

The program provides tools and resources to our regulated financial institutions conducting the 

annual assessment. We are learning from our institutions to better position the program to provide 

technical assistance that supports maturing their diversity programs. 

ENCOURAGING SELF-ASSESSMENT PARTICIPATION

Each year, we encourage our financial institutions’ voluntary participation in the diversity selfassessment to create momentum for sustainable culture change in the banking industry. In January 

2020, the Director of the FDIC’s OMWI issued letters to Presidents and Chief Executive Officers, 

Human Resources Managers, Diversity and Inclusion Officers, and Supplier Diversity Officers of 

787 FDIC-regulated financial institutions that were identified as having 100 or more employees 

in calendar year 2019. The letter informed these institutions about conducting and voluntarily 

submitting their diversity information to the FDIC. In March 2020, the Deputy to the Chairman and 

Chief Operating Officer issued a reminder letter. 

Also, in March 2020, the FDIC issued Financial Institution Letter (FIL) 23-2020 to our regulated 

financial institutions to encourage participation and announce a new automated application, the 

Financial Institution Diversity Self-Assessment (FID-SA). The FIL also announced an extension of the 
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 4

2019 Reporting Period Analysis

submission deadline to accommodate institutions dealing with the pandemic crisis. 

Following receipt of the self-assessment submissions, the FDIC completed its analysis of the financial 

industry’s diversity policies and practices for the 2019 reporting period (See Appendix 1 – Aggregated 

Assessment Results). The FDIC also performed a comparative analysis against the previous reporting 

years for monitoring progress and trends in diversity employment and contracting activities (See 

Appendix 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019). Even with the 

pandemic crisis, OMWI observed an increase in submissions over the previous reporting periods. 

For the 2019 reporting period, more than 150 of the invited FDIC-regulated financial institutions 

submitted self-assessments, representing a 19 percent submission rate. These institutions employ 38 

percent of all employees and hold 42 percent of the assets held by FDIC-regulated financial institutions. 

The 19 percent response rate for diversity self-assessments received for the 2019 reporting period 

represents a 14 percent increase over the 16.9 percent response rate for the 2018 reporting period. 

PARTNERING WITH FINANCIAL INSTITUTIONS

Financial institution participation is important for assessing trends, progress, and exemplary 

practices across the financial services industry. For this reason, we strongly encourage our financial 

institutions to consider participating in the annual assessment. The more institutions that are 

transparent about their diversity policies and practices creates momentum around building a safer, 

fairer, and more inclusive financial system. 

We appreciate our regulated financial institutions that partner with us in promoting diversity and 

inclusion in the banking industry through participation in the diversity self-assessment. Below we 

illustrate the number of responses received by FDIC region. The response rate was highest in the 

Chicago region, at 24 percent, and lowest in the Dallas region at 12 percent. 

Financial Institution Response Rate by FDIC Region – 2019 Results

96

135

161

97

190

108

16

32

20 22

43

19

17%

24%

12%

23% 23%

18%

#Financial Institutions Invited #Financial Institutions Submitted %Response Rate 2019

Atlanta Chicago Dallas Kansas City New York San Francisco
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 5

2019 Reporting Period Analysis

In the fall of 2020, the FDIC began repositioning the FID Program to increase technical assistance to 

our regulated entities that addresses identified challenges. Our goal is to ensure that the resources 

provide clear and effective guidance about how financial institutions can develop and implement 

impactful diversity programs. 

EXPANDING OUTREACH TO FINANCIAL INSTITUTIONS

We continue to increase voluntary participation by expanding our outreach efforts. For the 2019 

reporting period, we realized some success from enhanced outreach efforts despite the pandemic. 

As mentioned, the response rate for the 2019 reporting period was 14 percent higher than the 

response rate for the 2018 reporting period. Outreach enables the FDIC to explain to our supervised 

institutions the benefits of increasing transparency about their diversity policies and practices to 

help build a more inclusive banking system. Each of our outreach efforts focused on the value of 

conducting voluntary self-assessments, as well as making diversity information available to the 

public. Such transparency advances the visibility and adoption of diversity and inclusion practices in 

the financial industry. 

OMWI successfully completed the following outreach initiatives for the 2019 reporting period:

 Co-hosted the Federal Regulatory Agencies Diversity and Inclusion Summit in Chicago with the 

other OMWI agencies.

 Conducted American Bankers Association webinar: “What Bankers Need to Know About the 

Diversity Self-Assessment.”

 Created a dedicated Resources page for Financial Institution Diversity.

 Provided technical assistance to financial institutions on the diversity self-assessment and 

registering for access to the Financial Institution Diversity Self-Assessment application. 

 Prepared guidance documents to provide guidance and informative resources for financial 

institutions to develop or strengthen their diversity and inclusion practices and policies:

• Guidance relating to Workforce Profile and Employment Practices; and 

• Guidance relating to Procurement and Business Practices for Supplier Diversity.

MAXIMIZING TECHNOLOGY FOR INCREASED EFFICIENCY

The FDIC diversity commitment extends to supporting our financial institutions in conducting an 

annual assessment. We developed the FID-SA electronic application to automate the process for the 

FDIC’s regulated financial institutions to complete and submit their annual Diversity Self-Assessment 

of FDIC Regulated Financial Institutions instrument. This tool streamlines the experience and is 

accessible through the secured FDICconnect portal. 

The FID-SA electronic application was designed to improve the financial institutions’ experience by 

reducing the estimated reporting burden associated with the Paperwork Reduction Act and offering 

a secure, easy and efficient electronic interface for submitting the diversity self-assessment. The 

FID-SA application permits multiple authorized users to complete a self-assessment view previous 

submissions attach supporting material and print and save in .pdf format.
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 6

2019 Reporting Period Analysis

PROMOTING DIVERSITY AND INCLUSION IN THE BANKING 

SYSTEM

To make meaningful culture change, our regulated institutions must have data on their existing 

workforce and supplier diversity practices. The diversity self-assessment provides a framework 

for our financial institutions to assess their workforce, workplace, and supplier diversity practices. 

The framework leverages leading practices of a successful diversity program that is built around 

five Standards. 

For the 2019 reporting period, responses to the five Standards were consistent with the previous 

reporting period, with slight decreases and no notable improvements. The average affirmative 

response percentage for each Standard is included below. For detailed self-assessment analysis 

results, see Appendix 1 – Aggregated Assessment Results and Appendix 2 – Trend Analysis for 

Reporting Periods 2016 - 2019.

 Standard 1- Organizational Commitment to Diversity and Inclusion: 84 percent

 Standard 2- Workforce Profile and Employment Practices: 81 percent 

 Standard 3- Procurement and Business Practices for Supplier Diversity: 21 percent

 Standard 4- Practice to Promote Transparency of Organizational Diversity and 

 Inclusion: 55 percent

 Standard 5- Financial Institutions’ Self-Assessment: 65 percent

STANDARD 2

Workforce Profile and Employment Practices

STANDARD 1

Organizational Commitment to 

Diversity and Inclusion

STANDARD 3

Procurement and Business Practices 

for Supplier Diversity

21%

84%

STANDARD 5

Financial Institutions' Self-Assessment

STANDARD 4

Practice to Promote Transparency of 

Organizational Diversity and Inclusion

81%

65%

55%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 7

2019 Reporting Period Analysis

We aggregate the financial institutions’ affirmative responses for each Standard as a measure of 

support for the individual assessment Standards. A higher percent of financial institutions that 

respond “Yes” to the Standard leading practices indicate strong support across the responding 

institutions. The percent of affirmative responses for each Standard has remained consistent across 

reporting periods (2016-2019), even though the universe of financial institutions that submit a 

diversity self-assessment varies from year to year. 

For the 2019 assessment, responding institutions continue to show strong support for Standards 

1 and 2. Adoption of supplier diversity policies and practices among the same institutions remains 

low in comparison. 

Diversity Self Assessment 2016 – 2019 Reporting Periods

0

10

20

30

40

50

60

70

80

90

100

in percentages (%)

Organizational Commitment to Diversity and Inclusion

Workforce Profile and Employment Practices

Procurement and Business Practices - Supplier Diversity

Practice to Promote Transparency of Organizational Diversity and Inclusion

Financial Institutions' Self-Assessment

82

87 88

84

77

83 85 81

24

51 53 54 55

66 68 68 65

21 19 18

2016 2017 2018 2019

In addition, some responding institutions also provide narrative information about their diversity 

practices that addressed each Standard. We have made it a practice to highlight these exemplary 

practices for possible adoption by other financial institutions.
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 8

2019 Reporting Period Analysis

INCREASING TRANSPARENCY ON CHALLENGES

Our financial institutions have shared with us in the diversity self-assessment some challenges in 

maturing their diversity programs. We appreciate their willingness to be open so we may learn and 

provide assistance in the future. Our financial institutions identify challenges in their diversity and 

inclusion practices: 

 Location and size are factors that may challenge small community banks’ ability to grow their 

diversity and inclusion program that may extend to their ability to recruit, hire, retain, and 

promote a diverse workforce. Diversity and inclusion programs are not one-size-fits-all. For 

example, institutions in rural areas may have limited access to the types of diverse talent pools 

available in urban communities. 

 A key challenge that these institutions have identified is limited opportunities for advancement 

due to lean staffing strategies. However, institutions that struggle to recruit a diverse pool of 

candidates have increased their efforts to participate in diversity job fairs, and they continue to 

encourage their employees to become actively involved by volunteering in causes and events 

to interact with a more diverse community. Employee interaction helps build relationships to 

understand the banking needs of diverse communities better and share information about 

employment opportunities in the banking industry. 

 Although the area of supplier diversity remains a challenge, the 2019 assessment results 

indicated a slight increase in the percent of affirmative responses over the 2018 reporting 

period. Overall, responses indicated financial institutions have not widely adopted supplier 

diversity policies and practices. A diversity leading practice is that companies increasingly 

understand the competitive advantage of having a broad selection of available suppliers 

to choose from with respect to factors such as price, quality, attention to detail, and future 

relationship building.

Despite the challenges, adopting one or more of the exemplary practices discussed below may help 

financial institutions to successfully increase the diversity of their workforce and suppliers.
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 9

Exemplary Practices for 2019

Exemplary practices demonstrate our financial institutions’ commitment to advancing diversity 

and inclusion, not only in their organization but across the banking industry. Sharing these 

practices provides useful insights to financial institutions looking to enhance their diversity efforts. 

Information about exemplary practices may be especially useful to smaller financial institutions 

that lack resources to engage a diversity consultant or hire staff focused on diversity and inclusion.

Review of financial institutions’ 2019 self-assessments demonstrated the following exemplary 

diversity practices under the Standards: 

ORGANIZATIONAL COMMITMENT TO DIVERSITY AND 

INCLUSION

Senior leadership and board commitment to diversity and inclusion creates a culture that values 

the contribution of all employees and consultancy to assist in developing a robust diversity strategy. 

Some examples follow.

 Conducting engagement surveys to gauge workforce’s attitudes, perceptions, and views on 

diversity.

 Developing a Diversity Committee or formal diversity and inclusion program that is approved 

by the board to oversee the organizations’ diversity policies and practices.

 Involving senior leadership and board members in developing the diversity strategy to create 

opportunities, provide corporate training, and hold managers accountable for progress.
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 10

Exemplary Practices for 2019

WORKFORCE PROFILE AND EMPLOYMENT PRACTICES

The workforce profile provide candidates with information on who you attract as an employer. 

Exemplary employment practices reflect a culture that welcomes all segments of society in your 

organization, in recruitment, hiring, and retention. 

RECRUITMENT:

 Using minority and women-owned recruitment firms, or notifying recruitment firms of the 

organization’s commitment to hire a diverse workforce.

 Conducting outreach and recruitment activities at diverse professional organizations, campus 

job fairs located in the surrounding community, such as community colleges and universities, 

to help ensure the talent pool includes candidates from various ethnic and socioeconomic 

backgrounds.

 Building relationships with minority groups and community outreach programs to help job 

seekers with resume writing techniques, mock interviewing skills, and business etiquette. 

HIRING:

 Selecting board members and senior leadership positions from diverse candidate slates and 

having diverse interview panels. 

 Developing an onboarding program for new managers that focuses on the diversity of their 

team, and the strengths that those team members bring to the department and organization.

 Creating a formal summer internship and development program that is marketed to area 

colleges and universities (feeder program). 

RETENTION:

 Hosting mentoring events throughout the year where students and employees have the 

opportunity to learn about the organization’s diversity programs, and build relationships with 

HR and hiring managers.

 Conducting exit interviews with departing employees and developing strategies for 

professional growth, focusing on career development and personal skill development.

 Implementing formal development programs for key management positions creating a 

succession pipeline for future promotional opportunities by developing knowledge, skills, and 

abilities of diverse employees.
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 11

Exemplary Practices for 2019

PROCUREMENT AND BUSINESS PRACTICES - SUPPLIER 

DIVERSITY

Reporting results in the area of supplier diversity continues to remain a challenge across the 

industry. Most of the reporting financial institutions do not have procedures in place to adequately 

track the diversity in their procurement spending practices. However, despite the challenge noted, 

there were some exemplary practices identified. 

 Having a published Supplier Diversity Policy Statement signed by executive management. 

 Establishing supplier diversity goals to ensure the inclusion of diverse suppliers for 

opportunities. 

 Promoting a diverse supplier pool by partnering with supplier advocacy groups, and marketing 

with their local affiliates to identify and invite diverse businesses to participate in sourcing 

projects.

 Soliciting diverse businesses to become potential vendor partners through a dedicated 

supplier diversity webpage. 

MONITORING, TRACKING AND REPORTING ON DIVERSITY 

PRACTICES

A key benefit of using the FDIC diversity self-assessment analysis results is to conduct an external 

benchmark exercise against peers to identify underutilization of women and minorities in 

employment practices, determine how to improve diversity and inclusion initiatives, and identify 

areas of strength and diversity gaps to support a more inclusive workplace and diverse workforce. 

Other benefits of participating in the FDIC diversity self-assessment include:

 Using quantitative and qualitative measures to assess diversity and inclusion efforts internally 

(workforce) and externally (outreach). 

 Tracking supplier diversity metrics in quarterly, annually, and year-over-year procurement 

spend (dollars and percentage) with ethnically and racially diverse, women, veteran, people 

with disabilities, LGBTQ+ owned, and small businesses. 

 Practicing transparency by making a public commitment to diversity and inclusion that 

includes the metrics it uses to measure success in both workplace and supplier diversity, and 

by posting diversity policies, practices, strategies and assessments on social media, corporate 

website, and careers page.
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 12

Conclusion

As we continue to build relationships with our financial institutions and learn their programs, we are 

in a better position to provide technical assistance. Our financial institutions are invaluable partners 

in promoting a safer, fairer, more inclusive banking system for all Americans. 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 FID-SA. 

Each year the response rate of financial institutions with 100 or more employees has averaged 

around 19 percent. Greater participation would enhance the financial services industry as a whole. 

A diverse workforce and inclusive culture help financial institutions to connect with the local 

community and an increasingly diverse customer base. To meet the evolving banking needs of 

customers, it is important for the diverse perspectives from all the communities to be represented 

at the table.

The 2019 analysis found that the financial institutions continue to employ a variety of methods and 

approaches to identify, attract, recruit, retain and train a diverse workforce. And, while smaller 

banks have noted their limited resources, methods were nonetheless improvised to implement 

diversity into their workforce diversity practices. The self–assessment data also identifies areas 

where additional diversity guidance could be useful and beneficial to the industry. Based on 

supplemental information included in assessment data, OMWI has prepared informational 

resources to provide guidance to strengthen diversity programs. FID Program resources are 

available at https://www.fdic.gov/about/diversity/fidr.html.

For the 2020 reporting period, OMWI will continue to conduct outreach to promote more voluntary 

participation in the assessment. This outreach will provide education about the program, 

encourage submission through the electronic FID-SA application, and promote the benefits of 

sharing diversity data. 
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 13

APPENDIX 1

Aggregated Assessment Results

RESULTS BY FDIC REGION

FINANCIAL INSTITUTIONS BY FDIC REGION

The chart shows the number of responses received by FDIC region. The bar graph representing the 

response rate by region shows the aggregated number of self-assessments received (blue) against 

the number of financial institutions that were invited to conduct a diversity self-assessment for 

2019 (gold). Although the New York region had the highest number of submissions (43), the Chicago 

region had the highest response rate, at 24 percent. Atlanta had the lowest number of submissions; 

however the Dallas region had the lowest response rate, at 12 percent. 

Financial Institution Response Rate by FDIC Region – 2019 Results

96

135

161

97

190

108

16

32

20 22

43

19

17%

24%

12%

23% 23%

18%

#Financial Institutions Invited #Financial Institutions Submitted %Response Rate 2019

Atlanta Chicago Dallas Kansas City New York San Francisco
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 14

APPENDIX 1 – Aggregated Assessment Results

OVERALL BREAKDOWN BY EACH STANDARD

SECTION I – FINANCIAL INSTITUTION INFORMATION

Ninety-one percent of the 152 financial institutions reported having a designated Diversity and 

Inclusion Officer. Thirty-five percent of the financial institutions have an individual designated as 

the Supplier Diversity Officer. 

Diversity and Inclusion Officers Yes

Responses %

1. Does your organization have a Diversity and Inclusion 

Officer or Equivalent? 139 91%

2. Does your organization have a Supplier Diversity Officer 

or Equivalent? 53 35%

SECTION II – ASSESSMENT OF THE FINANCIAL INSTITUTION’S DIVERSITY

POLICIES AND PRACTICES

This section summarizes the aggregated results of the 2019 diversity self-assessments by standard. 

Standard 1: Organizational Commitment to Diversity and Inclusion

Responses to this Standard reflect how the leadership of an organization with successful diversity 

policies and practices demonstrates its commitment to diversity and inclusion. This is important 

because leadership comes from the governing body, such as a board of directors, as well as senior 

officials and those managing the organization on a day-to-day basis. Demonstrated leadership 

commitment fosters a corporate culture that embraces 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, 84 percent of the 152 financial institutions indicated that they practice the 

Standards outlined in this subsection. Ninety–three percent of responding financial institutions take 

proactive steps to promote a diverse pool of candidates in their hiring, recruiting, retention, and 

promotion, as well as in their selection of board members, senior management, and other senior 

leadership positions. 

The lowest affirmative responses are to Questions 1.2 and 1. 3. The affirmative response rate 

to Question 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, is 78 percent. 

The affirmative response rate to Question 1.3, The financial institution provides regular progress 

reports to the board and senior management, is 71 percent. 
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 15

APPENDIX 1 – Aggregated Assessment Results

 1. Organizational Commitment to 

Diversity and Inclusion

Yes

Responses %

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.

137 90

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.

119 78

1.3 The financial institution provides regular progress reports to the 

board and senior management. 108 71

1.4 The financial institution regularly conducts training and provides 

educational opportunities on equal employment opportunity and on 

diversity and inclusion.

128 84

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.

136 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.

142 93

Average: 128 84%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 16

APPENDIX 1 – Aggregated Assessment Results

Standard 2: Workforce Profile and Employment Practices

Responses to this Standard reflect how financial institutions promote the fair inclusion of minorities 

and women in their workforce by publicizing employment opportunities, creating relationships 

with minority and women professional organizations and educational institutions, creating a 

culture that values the contribution of all employees, and encouraging a focus on these objectives 

when evaluating the performance of managers. Financial institutions with successful diversity and 

inclusion programs also regularly evaluate their programs and identify areas to be improved.

The highest affirmative response rate, 95 percent, related to Question 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. The lowest 

affirmative response rates were to the questions under Question 2.3, The financial institutions has 

policies and practices that create diverse applicant pools for both internal and external opportunities. 

The affirmative response rate for each of the three sub-questions ranged between 68 to 74 percent. 

Overall, an average of 81 percent responded that they practice the Standards outlined in this 

subsection.

 2. Workforce Profile and Employment Practices Yes

Responses %

2.1 The financial institution implements policies and practices related to 

workforce diversity and inclusion in a manner that complies with all 

applicable laws.

143 94

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.

145 95

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.

112 74

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

women student populations. 107 70

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

minorities and women and to inform them of employment and 

promotion opportunities.

103 68

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.

130 86

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.

122 80

Average: 123 81
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 17

APPENDIX 1 – Aggregated Assessment Results

Standard 3: Procurement and Business Practices - Supplier Diversity

Responses to this Standard reflects how organizations increasingly understand the competitive 

advantage of having a broad selection of available suppliers to choose from with respect to factors such 

as price, quality, attention to detail, and future relationship building. A number of financial institutions 

have achieved success at expanding available business options by increasing outreach to minorityowned and women-owned businesses. Financial institutions often use metrics to identify the baseline of 

how much they spend contracting for goods and services, how much they spend with minority-owned 

and women-owned businesses, and the availability of relevant minority-owned and women-owned 

businesses, as well as changes over time. Similarly, financial institutions may use outreach to inform 

minority-owned and women-owned businesses (and affinity groups representing these constituencies) 

of these opportunities and of the procurement process. In addition, financial institutions’ prime 

contractors often use subcontractors to fulfill the obligations of various contracts. The use of minorityowned and women-owned businesses as subcontractors provides valuable opportunities for both the 

minority-owned and women-owned businesses and the prime contractor. Financial institutions may 

encourage the use of minority-owned and women-owned subcontractors by incorporating this objective 

in their business contracts.

The overall affirmative responses related to Procurement and Business Practices for Supplier Diversity 

averaged 21 percent. The average affirmative response rate to the seven questions ranged from 16 to 

30 percent. The highest affirmative response rate (30 percent) related to the financial institution having 

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. The lowest affirmative response 

rate (16 percent) related to contracts with minority-owned and women-owned business subcontractors.
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 18

APPENDIX 1 – Aggregated Assessment Results

 3. Procurement and Business Practices - Supplier Diversity Yes

Responses

%

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.

45 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.

36 24

3.2(b) Percentage of contract dollars awarded to minority-owned and womenowned businesses by race, ethnicity, and gender. 27 18

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

business subcontractors. 24 16

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.

32 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.

28 18

3.3(c) An ongoing process to publicize its procurement opportunities. 27 18

Average: 31 21
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 19

APPENDIX 1 – Aggregated Assessment Results

Standard 4: Practice to Promote Transparency of Organizational Diversity and 

Inclusion

Responses to this Standard reflect how financial institutions’ transparency and publicity are 

important aspects of assessing diversity policies and practices. This is important because greater 

awareness and transparency give the public information to assess those policies and practices. 

Financial institutions publicize information about diversity and inclusion efforts through normal 

business methods, which include displaying information on their websites, in their promotional 

materials, and in their annual reports to shareholders, if applicable. By publishing a financial 

institution’s commitment to diversity and inclusion, its plans for achieving diversity and inclusion, 

and the metrics it uses to measure success in both workplace and supplier diversity, a financial 

institution informs a broad constituency of investors, employees, potential employees, suppliers, 

customers, and the general community about its efforts. The publication of this information can 

make new markets accessible for minorities and women and illustrate the progress made toward an 

important business goal.

The affirmative response rate for the questions about financial institutions practices that 

promote diversity and inclusion transparency ranged from 28 percent to 78 percent, averaging 

55 percent. Seventy-eight percent of respondents publicize their current employment and 

procurement opportunities, whereas 28 percent forecast their potential employment and 

procurement opportunities. 

 4. Practice to Promote Transparency of Organizational 

Diversity and Inclusion

Yes

Responses

%

4.1 The financial institution publicizes its diversity and inclusion strategic 

plan. 56 37

4.2 The financial institution publicizes its policy on its commitment to 

diversity and inclusion. 108 71

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.

88 58

4.4. The financial institution publicizes its opportunities to promote 

diversity, which may include: 4.4(a) Current employment and 

procurement opportunities.”

119 78

4.4(b) Forecasts of potential employment and procurement opportunities. 43 28

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

for employees and contractors.

87 57

Average: 84 55
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 20

APPENDIX 1 – Aggregated Assessment Results

Standard 5: Financial Institutions’ Self-Assessment

Responses to this Standard reflects how financial institutions that have successful diversity policies 

and practices allocate time and resources to monitoring and evaluating performance under their 

diversity policies and practices on an ongoing basis. Financial institutions are encouraged to 

disclose their diversity policies and practices, as well as information related to their assessments, 

to the FDIC and the public. Disclosure includes but is not limited to producing a diversity progress 

report on website about workforce and supplier diversity as well as highlighting partnership success 

between the financial institution and organization(s).

The average affirmative response rate for questions about this standard was 65 percent. In response 

to Question 5.3, about publishing information pertaining to their assessment of diversity policies 

and practices, 30 percent of financial institutions answered yes. In response to Questions 5.1 and 

5.2, about conducting an annual assessment of diversity policies and practices, and monitoring and 

evaluating performance under diversity policies and practices on an ongoing basis, 84 percent and 

80 percent of financial institutions, respectively, responded yes. 

 5. Financial Institutions’ Self-Assessment Yes

Responses

%

5.1 The financial institution conducts an assessment of its diversity 

policies and practices annually. 127 84

5.2. The financial institution monitors and evaluates its performance under 

its diversity policies and practices on an ongoing basis. 122 80

5.3. The financial institution publishes information pertaining to its 

assessment of its diversity policies and practices. 46 30

Average: 98 65
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 21

APPENDIX 1 – Aggregated Assessment Results

SECTION III – DIVERSITY DAT

Subsection 1: Workforce Profile

The Standards encourage financial institutions to promote the fair inclusion of minorities and 

women in their workforce. 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, lower in management and even lower in Board 

membership. In the aggregate, responding financial institutions reported representation of women 

as follows: 63 percent of the workforce; 37 percent of management, and 16 percent of Board 

members. Again in the aggregate, responding financial institutions reported representation of 

minorities as follows: 32 percent in the workforce, 12 percent of management, and 6 percent of 

Board members. 

Diversity Data for Workforce Profile 2019 Results

Diversity Data Total W (#) W (%) M (#) M (%) Ms (#) Ms (%) NMs(#) NMs(%)

Workforce 157,601 99,446 63 58,155 37 51,216 32 106,385 68

Management 11,049 4,065 37 6,984 63 1,363 12 9,686 88

Board Members 1,667 270 16 1,397 84 107 6 1,560 94

Legend

W = Women M = Men Ms = Minorities NMs = Non-Miniorites

Subsection 2: Procurement-Supplier Diversity

Similarly, the Standards promote active outreach to minority and women-owned businesses in the 

procurement process. However, the responses indicate most of the financial institutions do not 

have procedures in place to adequately track the diversity in their procurement spending practices. 

The metrics reported for supplier diversity spending are not sufficient to draw any conclusions or 

trends for this reporting period. 
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 22

APPENDIX 2

Trend Analysis of Self-Assessment Results: 

Reporting Periods 2016-2019

The 2016 reporting period provided the baseline for the trend analysis, since that was the year the 

FDIC began collecting diversity assessment information. 

The unprecedented crises created by a worldwide pandemic of historic proportions has had an 

understandable impact on all segments of society, including the financial industry. Recognizing the 

severity of the current environment, the FDIC shifted its priorities and made adjustments to best 

meet the immediate needs of its regulated financial institutions to ensure their focus and priorities 

were on the wellbeing of their employees and public consumers. Despite the crisis, responses for 

the 2019 reporting period have increased over the last three reporting period years, reaching a 19 

percent response rate. The FDIC received 152 diversity self-assessments from its regulated financial 

institutions having 100 or more employees, a 60 percent increase over the first 2016 reporting 

period submissions. 

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

each reporting period, from 2016 to 2019. 

Comparative of Responding Financial Institutions by Reporting Period

Reporting 

Period

# Financial 

Institutions (Invited)

# Self-Assessments 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

2019 787 152 19.31 16 6

Out of the 152 responding institutions, the FDIC has received repeat submissions from 33 

institutions for all four reporting periods. Eighty financial institutions previously submitted 

responses for 2016, 2017 or 2018, but not all three reporting periods. FDIC received 39 first-time 

submissions from financial institutions for the 2019 reporting period. 
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 23

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

OVERALL BREAKDOWN BY FDIC REGION FOR REPORTING 

PERIOD 2016 TO 2019

FINANCIAL INSTITUTIONS BY FDIC REGION

For the 2019 reporting period, the response rate increased in five regions, with Kansas City having 

the highest increase in response rate (69 percent) over the 2018 reporting period, followed by 

Chicago (45 percent) and Atlanta (23 percent). For the last three reporting periods, the response 

rate for the Chicago region has been the second highest among the FDIC’s six regions (22 percent in 

2017, 22 percent in 2018, and 32 percent in 2019, respectively). However, the Chicago region had the 

highest response rate (24 percent) for the 2019 reporting period. 

Financial Institution Submissions by FDIC Region – 2016 to 2019

13

20

7

30

12

19

22

19

37

18

13

22

19

13

49

16 17

32

20 22

43

19

2016 2017 2018 2019

Atlanta Chicago Dallas Kansas City New York San Francisco

13

22

2016 -2019 Financial Institution Response Rate by FDIC Region

Reporting 

Period Atlanta Chicago Dallas Kansas City New York

San 

Francisco

2016 12% 9% 13% 8% 14% 11%

2017 18% 15% 14% 21% 18% 17%

2018 13% 16% 12% 14% 24% 17%

2019 17% 24% 12% 23% 23% 18%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 24

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

AGGREGATED ASSESSMENT RESULTS FOR REPORTING 

PERIOD 2016 TO 2019: COMPARATIVE BREAKDOWN BY EACH 

STANDARD

SECTION I – FINANCIAL INSTITUTION INFORMATION

The data from the 2016 to the 2019 reporting period showed a steady and consistent increase of 

financial institutions having a designated Diversity and Inclusion Officer. There was a 16 percent 

increase from 2018 to 2019 (from 120 to 139 financial institutions). Similarly, the data reflect an 

increase in the percentage of institutions that have a designated Supplier Diversity Officer from 

2016 to 2019, although the percentage was lower in 2019 (53 percent) than in 2018 (58 percent). The 

universe of reporters changes from year to year, so the data do not necessarily indicate that some 

reporters eliminated a Supplier Diversity Officer position.

Diversity and Inclusion Officers - 2016 to 2019 Results

Diversity and Inclusion Officers 2016 2017 2018 2019

1. Does your organization have a Diversity and 

Inclusion Officer or Equivalent? 81 82 120 139

2. Does your organization have a Supplier Diversity 

Officer or Equivalent? 44 41 58 53

SECTION II – ASSESSMENT OF THE FINANCIAL INSTITUTION’S DIVERSITY

POLICIES AND PRACTICES

The table below represents the submission results across the five Standards for each consecutive 

reporting period (2016 through 2019). A breakdown for each of the five Standards is reported on the 

following pages. 

Submission Responses to Standards - 2016 to 2019 Results

2016

95 Institutions

2017

137 Institutions

2018

133 Institutions

2019

152 Institutions

1. Organizational Commitment to 

Diversity and Inclusion 82% 87% 88% 84%

2. Workforce Profile and Employment 

Practices 77% 83% 85% 81%

3. Procurement and Business 

Practices - Supplier Diversity 24% 19% 18% 21%

4. Practice to Promote Transparency 

of Organizational Diversity and 

Inclusion

51% 53% 54% 55%

5. Financial Institutions’ SelfAssessment 66% 68% 68% 65%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 25

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

Subsection 1: Organizational Commitment to Diversity and Inclusion

Based on the 2016 to 2019 data, the responding financial institutions demonstrate their 

organizational commitment to diversity and inclusion, with an overall average of 85 percent 

across the four reporting periods. Affirmative responses to questions in this subsection decreased 

by four percentage point from 2018 to 2019 (from 88 percent to 84 percent). Responses for the 

2019 reporting period reflect an overall decline across all questions relating to organizational 

commitment to diversity and inclusion from the 2018 reporting period, with the exception of 

responses to Question 1.5, which did not change. The largest decrease (10 percent) was in reference 

to Question 1.2, about financial institutions having a diversity and inclusion policy that is approved 

and supported by senior leadership, including senior management and the board of directors (88 

percent in 2018 to 78 percent in 2019). 

Organizational Commitment to Diversity and Inclusion - 2016 to 2019 Results

83%

81% 82%

84% 85%

91%

85%

80%

82%

92%

90% 91%

88%

77%

87%

89%

95%

90%

78%

71%

84%

89%

93%

75%

Question 1.1 Question 1.2 Question 1.3 Question 1.4 Question 1.5 Question 1.6

2016 2017 2018 2019
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 26

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

 1. Organizational Commitment to Diversity and 

Inclusion 2016 2017 2018 2019

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% 90%

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% 78%

1.3 The financial institution provides regular progress 

reports to the board and senior management. 75% 80% 77% 71%

1.4 The financial institution regularly conducts training 

and provides educational opportunities on equal 

employment opportunity and on diversity and inclusion.

82% 82% 87% 84%

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% 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% 93%

Average: 82% 87% 88% 84%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 27

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

Subsection 2: Workforce Profile and Employment Practices 

Responding financial institutions reported positively to their workforce profile and employment 

practices, with an overall average of 81 percent across the four reporting periods, 2016 through 2019. 

Responses for the 2019 reporting period reflected an overall decline across all questions. 

This section resulted in a four percentage point decrease in 2019 (81 percent) since the 2018 

reporting period (85 percent). The largest decrease (6 percent) was in response to Question 

2.3(a), The financial institution has policies and practices that create diverse applicant pools 

for both internal and external opportunities that may include outreach to minority and women 

organizations (80 percent in 2018 to 74 percent in 2019).

Workforce Profile and Employment Practices - 2016 to 2019 Results

94% 96%

74%

66%

61%

79%

69%

95% 96%

80%

73% 70%

87%

82%

98% 97%

80%

73%

89%

83%

94% 95%

74% 70% 68%

86%

80%

73%

Question 2.1 Question 2.2 Question 2.3 Question 2.4 Question 2.5 Question 2.6 Question 2.7

2016 2017 2018 2019
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 28

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

 2. Workforce Profile and Employment 

Practices 2016 2017 2018 2019

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% 94%

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% 95%

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% 74%

2.3(b) Outreach to educational institutions serving 

significant minority and women student 

populations.

66% 73% 73% 70%

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% 68%

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% 86%

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% 80%

Average: 77% 83% 85% 81%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 29

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

Subsection 3: Procurement and Business Practices - Supplier Diversity

Responses to Subsection 3, Procurement and Business Practices, consistently have demonstrated 

that supplier diversity is an area of challenge. The percentage of affirmative responses has averaged 

20 percent across the four reporting periods, 2016 through 2019. 

Despite Supplier Diversity being an area of challenge, results for the 2019 responses trended slightly 

upward (3 percent) over the 2018 reporting period (21 percent and 18 percent, respectively). The 

largest increase in affirmative responses (7 percentage points) over the 2018 results was associated 

with Question 3.2(b), Percentage of contract dollars awarded to minority-owned and women-owned 

businesses by race, ethnicity, and gender (18 percent in 2019 and 11 percent in 2018).

Procurement and Business Practices – Supplier Diversity - 2016 to 2019 Results 41%

23%

16% 15%

31%

20%

23%

31%

20%

14% 13%

21%

18%

15%

30%

19%

11% 12%

21%

14%

16%

30%

24%

18% 16%

21%

18% 18%

Question 3.1 Question 3.2 (a) Question 3.2 (b) Question 3.2 (c) Question 3.3 (a) Question 3.3 (b) Question 3.3 (c)

2016 2017 2018 2019
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 30

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

 3. Procurement and Business Practices - 

Supplier Diversity 2016 2017 2018 2019

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% 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% 24%

3.2(b) Percentage of contract dollars awarded to 

minority-owned and women-owned businesses 

by race, ethnicity, and gender.

16% 14% 11% 18%

3.2(c) Percentage of contracts with minority-owned 

and women-owned business subcontractors. 15% 13% 12% 16%

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% 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% 18%

3.3(c) An ongoing process to publicize its procurement 

opportunities. 23% 15% 16% 18%

Average: 24% 19% 18% 21%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 31

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

Subsection 4: Practice to Promote Transparency of Organizational Diversity and 

Inclusion 

Affirmative responses to questions about promoting transparency with respect to organizational 

diversity and inclusion averaged 53 percent across all reporting periods. The rate of affirmative 

responses was one percentage point higher in 2019 (55 percent) than in the previous reporting 

period (54 percent). The greatest increase (five percentage points) related to Question 4.1, The 

financial institution publicizes its diversity and inclusion strategic plan (37 percent in 2019 and 32 

percent in 2018). The largest decrease in affirmative responses (4 percentage points) was related to 

Question 4.2., The financial institution publicizes its policy on its commitment to diversity and inclusion

(71 percent in 2019 and 75 percent in 2018).

Practice to Promote Transparency of Organizational Diversity and Inclusion - 2016 to 2019 

Results

33%

64%

57%

76%

23%

54%

31%

71%

58%

80%

23%

54%

32%

75%

57%

78%

24%

56%

37%

71%

58%

78%

28%

57%

2016 2017 2018 2019

Question 4.1 Question 4.2 Question 4.3 Question 4.4(a) Question 4.4(b) Question 4.4(c)
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 32

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

 4. Practice to Promote Transparency 

of Organizational Diversity and 

Inclusion

2016 2017 2018 2019

4.1 The financial institution publicizes its diversity 

and inclusion strategic plan. 33% 31% 32% 37%

4.2 The financial institution publicizes its policy on 

its commitment to diversity and inclusion. 64% 71% 75% 71%

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% 58%

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% 78%

4.4(b) Forecasts of potential employment and 

procurement opportunities. 23% 23% 24% 28%

4.4(c) The availability and use of mentorship and 

developmental programs for employees and 

contractors.

54% 54% 56% 57%

Average: 51% 53% 54% 55%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 33

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

Subsection 5: Financial Institutions’ Self-Assessment

Affirmative responses to questions about the assessment of financial institution’s diversity policies 

and practices averaged 66 percent across all four reporting periods. There was an average four 

percentage point reduction reported for the 2019 financial institutions’ self-assessment compared 

with the 2018 reporting period (65 percent and 68 percent, respectively). The largest decrease 

(7 percentage points) was associated with Question 5.1, The financial institution conducts a selfassessment of its diversity policies and practices annually (84 percent in 2019 and 91 percent in 2018). 

Financial Institutions’ Self-Assessment - 2016 to 2019 Results

86%

83%

28%

86% 86%

28%

91%

86%

29%

84% 80%

30%

Question 5.1 Question 5.2 Question 5.3

2016 2017 2018 2019

 5. Financial Institutions’ SelfAssessment

2016 2017 2018 2019

5.1 The financial institution conducts an 

assessment of its diversity policies and practices 

annually.

86% 86% 91% 84%

5.2. The financial institution monitors and evaluates 

its performance under its diversity policies and 

practices on an ongoing basis.

83% 86% 86% 80%

5.3. The financial institution publishes information 

pertaining to its assessment of its diversity 

policies and practices.

28% 28% 29% 30%

Average: 66% 67% 68% 65%
FINANCIAL INSTITUTION DIVERSITY SELF-ASSESSMENT 2019 ANALYSIS 34

APPENDIX 2 – Trend Analysis of Self-Assessment Results: Reporting Periods 2016-2019

SECTION III – DIVERSITY DAT

Subsection 1: Workforce Profile

For the 2019 reporting period, 93 percent of responding institutions shared the diversity data on 

their workforce. Consistent with previous years, diversity in the workforce remains high overall but 

notably lower at the management and Board member levels. 

The FDIC has developed informational guides for its regulated financial institutions to develop or 

improve diversity policies and practices relating to Workforce Profile and Employment Practices, 

highlighting the importance of diversity in the workplace and to assist its regulated financial 

institutions through best practices observed in the industry. This informational guide is available at 

https://www.fdic.gov/about/diversity/guidance-diversity-workforce.html.

Subsection 2: Procurement-Supplier Diversity 

Supplier diversity as a whole is challenging to the regulated financial institutions. For the reporting 

period 2016 through 2019, 17 percent of institutions report that they are able to track spend data. 

Consistently, there has not been enough data to analyze or to determine trends for the procurement 

supplier diversity subsection to establish an accurate portrayal of industry practices.

The FDIC has developed guidance for its regulated financial institutions to develop or improve 

diversity policies and practices relating to Procurement and Business Practices for Supplier 

Diversity, highlighting the importance of supplier diversity and to assist its regulated financial 

institutions through best practices observed in the industry. This informational guide is posted at 

https://www.fdic.gov/about/diversity/guidance-supplier-diversity.html.