FEDERAL DEPOSIT INSURANCE CORPORATION

Office of Minority and Women Inclusion

Section 342 Dodd-Frank Wall Street 

Reform and Consumer Protection Act

2018 REPORT TO CONGRESS

Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress i

Table of Contents

INTRODUCTION 1

FDIC CONTRACTING:

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

EMPLOYMENT AT THE FDIC:

Increasing Representation of Minorities and Women 21

OTHER ACTIVITIES 33

CONCLUSION 53

APPENDICES 55
ii Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 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 hiring qualified 

minority and women employees and contracting with qualified minority- and 

women-owned businesses.

The FDIC is pleased to submit this 2018 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 institution 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 long-standing commitment to promote diversity and inclusion in 

employment opportunities and all business areas of the FDIC. This report outlines 

both successes 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 2018 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.

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

OMWI Steering Committee (later renamed the FDIC Diversity and Inclusion Executive 

Advisory Council (EAC)), to ensure and promote coordination of OMWI programs. 

The EAC is chaired by the FDIC Deputy to the Chairman and Chief Operating Officer 

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

FDIC senior staff. The EAC provides leadership on diversity and inclusion initiatives 

throughout the FDIC. 

The FDIC’s 2018 – 2019 Diversity and Inclusion Strategic Plan continues to outline 

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. The strategic plan identifies agency strategies 

to promote increased diversity through the FDIC’s recruiting and hiring processes. 

The plan also ensures the sustainability of the FDIC’s diversity and inclusion efforts 

by equipping leaders with the ability to manage diversity, monitor results, and refine 

approaches on the basis of actionable data. There are specific steps outlined in the 

plan that continue to enhance diversity and inclusion at the FDIC in the areas of 

leadership engagement, analytics and reporting, training, communications, strategic 

planning, and program enhancement.

The agency’s success carrying out its missions is due in large-part to the commitment 

and dedication of the FDIC workforce. This workforce has managed the regulatory 

process through economic downturns and upturns over the years. These highly skilled 

professionals possess deep institutional knowledge of the banking industry. The FDIC 

has experienced an increase in retirements as baby boomers exit the workforce. As 

these professionals leave the workforce, FDIC’s continued commitment to diversity 

and inclusion is critical to recruiting and retaining the most qualified, talented, and 

motivated employees in the labor market.

Consistent with the DFA, the FDIC continues 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 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 3

INTRODUCTION

burdens for community banks. FDIC leadership is engaged in conducting a 

comprehensive review of supervisory processes including, workforce structure, 

and capabilities supporting the agency’s Community Affairs mission. These efforts 

will promote increased focus on underserved and unbanked communities through 

expanded engagement with Minority Depository Institutions so they are in a better 

position to serve their communities. Also, FDIC has efforts underway to promote the 

safe adoption of additional products and services to bring underserved communities 

more fully into the banking mainstream. In addition, FDIC is soliciting feedback on how 

the agency may better enable banks to offer small dollar credit to consumers.

2018 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. The Diversity and Inclusion Strategic Plan was reviewed and during 

2017 was updated and disseminated to the FDIC workforce and posted on the FDIC 

website in February 2018. The updated 2018 – 2019 Plan is designed to continue the 

FDIC’s success in ensuring all employees are valued members of the workplace and 

active participants in carrying out the FDIC mission. The two-year plan is designed 

to recognize that many specified actions have concrete steps, while other actions 

more broadly reflect the continuation of the FDIC’s general approach to diversity 

and inclusion. 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 priority. 

While this is a two-year plan, the EAC will review the plan during 2019 to determine if 

any changes are necessary.

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

and produces plans with strategies to further their diversity progress and address 

noted issues. The division and office level plans were consolidated into an FDIC 

Plan to Promote Increased Diversity through Division/Office Engagement and have 

been integrated into the agency’s annual strategic planning efforts. In April 2018, the 

progress made by divisions and major offices was reported and discussed at the EAC 

meeting. This process keeps the division and major offices engaged in the FDIC’s 

diversity and inclusion efforts and will continue in 2019.
4 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

INTRODUCTION

In recognition of the FDIC’s 2018 diversity and inclusion progress, the following 

initiatives are highlighted:

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

Groups (ERGs). These ERGs are networks of employees with similar interests or 

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 supported the establishment of two new ERGs: The Association of African 

American Professionals (A3P); and Networking Inclusion and Advancement for 

African American-Women: African American Women with a Purpose (NIA Women). 

This is in addition to the six existing ERGs: Corporate Advocacy Network for 

Disability Opportunities (CAN DO); Innovation Meetup (formerly Emerging Leaders); 

Hispanic Organization for Leadership and Advancement (HOLA); Partnership of 

Women in the Workplace (POWW); PRIDE; and Veterans Employee Resource Group 

(VERG).

§ Diversity 101 online training was implemented for all employees and OMWI began 

monitoring completion by employees.

§ A contract was awarded to provide diversity and inclusion consulting support 

services and diversity and inclusion training for employees. 

§ FDIC Corporate University continued administering manager and supervisor 

training on equal employment opportunity and diversity and inclusion, including the 

No FEAR Act biennial training.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 5

FDIC CONTRACTING:

Inclusion of Minority- and Women-Owned 

Businesses (MWOBs)

The FDIC places a high priority on achieving diversity in contracting and asset sales, 

and OMWI is an integral part of the contractor solicitation, education, and evaluation 

process. During 2018, the FDIC implemented new contracting initiatives and 

conducted focused outreach which improved MWOB participation in its contracting 

activities. However, the FDIC continued to face challenges in increasing the utilization 

and growth rates for MWOB contractors because new contract awards by the FDIC 

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 analyze future contracting needs to determine where MWOB 

opportunities may exist and if new procurement strategies can be used to maximize 

MWOB participation. The following sections provide detailed information on the 

agency’s 2018 contracting activities and successes; contracting initiatives, programs, 

and outreach; and challenges the FDIC faces in increasing MWOB participation in its 

contracting activities.
6 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

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

Contracting Activities and Successes

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

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

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 

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 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 more than 40 learning modules2 and is a technical assistance aid 

and self-assessment for businesses interested in competing for contract opportunities. 

Contract Payments with MWOBs

The FDIC paid $429.6 million to contractors in 2018 under 1,295 contracts, of which 

$98.0 million (22.8 percent) was paid to MWOBs under 299 contracts. [See Figure 1.] 

By comparison, the FDIC paid $414.0 million to contractors under 1,537 contracts in 

2017; $415.2 million to contractors under 1,786 contracts in 2016; $507.2 million to 

contractors under 2,029 contracts in 2015; and $491.6 million to contractors under 

1,962 contracts in 2014. The 2018 total payments (i.e., spend) to contractors included 

payments for contracts awarded in 2018 and payments for active contracts awarded 

prior to 2018.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 7

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

Figure 1 Contracting Payments (in millions)

2014 2015 2016 2017 2018

Total $491.6 $507.2 $415.2 $414.0 $429.6

100.0% 100.0% 100.0% 100.0% 100.0%

MWOB $128.2 $142.5 $111.5 $109.6 $98.0

26.1% 28.1% 26.8% 26.5% 22.8%

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

18.2% 17.6% 13.5% 13.2% 11.5%

Women Owned (WO) $63.6 $83.2 $66.8 $66.9 $59.5

12.9% 16.4% 16.1% 16.2% 13.9%

Overlap (Both MO & WO) $24.7 $30.0 $11.3 $11.9 $11.1

5.0% 5.9% 2.8% 2.9% 2.6%

Asian American $38.5 $39.9 $33.5 $30.1 $28.8

7.9% 7.9% 8.1% 7.2% 6.7%

Black American $15.9 $13.3 $11.5 $14.2 $9.5

3.2% 2.6% 2.8% 3.4% 2.2%

Hispanic American $26.7 $25.1 $10.3 $9.5 $ 8.4

5.4% 5.0% 2.5% 2.3% 2.0%

Native American

$0.3 $0.1 $0.1 $0.2 $2.2

0.1% 0.0% 0.0% 0.1% .05%

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

one in which payments were made or credits applied in 2018. In 2018, minorityowned firms were paid $49.5 million of the total dollars paid to MWOB contractors 

(11.5 percent). Women-owned firms were paid $59.5 million of the total dollars paid to 

MWOB contractors (13.9 percent). These two categories – minorities and women – are 

not mutually exclusive since $11.1 million (2.6 percent) was paid in 2018 to businesses 

classified as both minority-owned and women-owned. The FDIC paid MWOBs $109.6 

million (26.5 percent) of the total paid to all contractors in 2017 under 354 contracts; 

$111.5 million (26.8 percent) of the total paid to all contractors in 2016 under 461 

contracts; $142.5 million (28.1 percent) of the total paid to all contractors in 2015 under 

591 contracts; and $128.2 million (26.1 percent) to MWOBs in 2014 under 533 contracts.

In 2018, the FDIC awarded 166 contracts to MWOBs out of a total of 565 issued (29.4 

percent). [See Figure 2.] By comparison, the FDIC awarded 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; 346 contracts (29.9 percent) to MWOBs out of a 

total of 1,159 issued in 2015; and 288 contracts (26.9 percent) to MWOBs out of a total 

of 1,072 issued in 2014.
8 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

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

Figure 2 Contracting Actions

2014 2015 2016 2017 2018

Total

1072 1159 1181 737 565

100.0% 100.0% 100.0% 100.0% 100%

MWOB

288 346 287 210 166

26.9% 29.9% 24.3% 28.5% 29.4%

Minority Owned (MO) 170 148 142 100 87

15.9% 12.8% 12.0% 13.6% 15.4%

Women Owned (WO) 167 243 187 151 119

15.6% 21.0% 15.8% 20.5% 21.1%

Overlap (Both MO & WO) 49 45 42 41 40

4.6% 3.9% 3.5% 5.6% 7.1%

Asian American

54 56 62 63 54

5.1% 4.8% 5.2% 8.6% 9.6%

Black American

45 35 24 22 11

4.2% 3.0% 2.0% 3.0% 1.9%

Hispanic American

59 39 48 4 11

5.5% 3.4% 4.1% 0.5% 1.9%

Native American

2 1 2 7 6

0.2% 0.1% 0.2% 1.0% 1.1%

Other

10 17 6 4 5

0.9% 1.5% 0.5% 0.5% 0.9%

As of December 31, 2018, the FDIC had 251 (18.9 percent) active contracts with 

MWOBs out of a total of 1,331 active contracts. The active contracts to MWOB firms by 

category were as follows: Asian American (81), Black American (25), Hispanic American 

(18), Native American (10), and Women (166). These include contracts awarded to firms 

that were both minority-owned and women-owned.

Contract Awards to MWOBs

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

which $122.5 million (24.5 percent) were awarded to MWOBs. By comparison, the 

FDIC awarded contracts with a combined value of $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; 

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

(24.7 percent) awarded to MWOBs; and awarded contracts with a combined value of 

$686.8 million in 2014, with $239.9 million (34.9 percent) awarded to MWOBs. [See 

Figure 3.]
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 9

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

Figure 3 Total Contract Dollar Awards

2014 2015 2016 2017 2018

Total $686.8 $858.4 $508.8 $523.7 $499.5

100.0% 100.0% 100.0% 100.0% 100.0%

MWOB $239.9 $211.6 $93.9 $96.7 $122.5

34.9% 24.7% 18.5% 18.5% 24.5%

Minority Owned (MO) $143.7 $145.2 $56.5 $66.7 $45.8

20.9% 16.9% 11.1% 12.7% 9.2%

Women Owned (WO) $132.6 $104.2 $47.4 $46.2 $83.0

19.3% 12.1% 9.3% 8.8% 16.6%

Overlap (Both MO & WO) $36.4 $37.8 $10.0 $16.2 $6.3

5.3% 4.3% 1.9% 3.0% 1.3%

Asian American $27.1 $51.8 $25.0 $31.2 $33.9

4.0% 6.0% 4.9% 6.0% 6.8%

Black American $21.3 $30.7 $9.4 $32.7 $1.9

3.1% 3.6% 1.9% 6.2% 0.4%

Hispanic American $66.1 $43.2 $20.6 $1.6 $7.0

9.6% 5.0% 4.0% 0.3% 1.4%

Native American $0.8 $- $0.1 $0.9 $2.9

0.1% 0.0% 0.0% 0.2% 0.6%

Other

$28.4 $19.5 $1.4 $0.3 $0.1

4.1% 2.3% 0.3% 0.0% 0.0%

The FDIC’s five-year trend from 2014 – 2018 of contract awards and payments can be 

found at Appendix A.

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 2018 under 66 different NAICS codes. Figure 

4 depicts the FDIC’s 2018 contracts categorized for the top ten NAICS codes and 

percentage of the total award value ($499.5 million).
10 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

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

Figure 4 FDIC 2018 Contracts by Top Ten NAICS Codes

Janitorial Services

561720 

4%

Software Publishers

511210 

8%

Electronic Computer Manufacturing 

334111 

4% 

Computer Systems 

Design Services 

541512

10%

Administrative Management 

and General Management 

Consulting Services 

541611 

5%

Data Processing, Hosting, 

and Related Services

518210 

8%

Other Computer 

Related Services

541519 

28%

Internet Publishing and Broadcasting 

and Web Search Portals 

519130

3%

Human Resources Consulting Services 

541612

3%

Custom Computer Programming 

Services

541511 

3%

In 2018, these awards consisted of the following: 28 percent for other related computer 

services; 10 percent for computer systems design services; 8 percent for software 

publishers; and 8 percent for data processing, hosting, and related services. The 

remaining 22 percent – each five percent or under – was awarded in the areas of 

administrative management and general management consulting services (five 

percent); electronic computer manufacturing (four percent); janitorial services (four 

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

custom computer programming services (three percent); and human resources 

consulting services (three percent). Collectively, 26.8 percent of the top ten NAICS 

code contracts were awarded to MWOBs. [See Figure 5.]

Figure 5 2018 Contract Awards by Top 10 NAICS

Non-MWOB

73.2% 

MWOB

26.8% 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 11

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

The 2018 FDIC contract awards associated with the top ten NAICS codes can be found 

in Appendix B.

Legal Contracting

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 Section 342 of the 

DFA that encourages diversity and inclusion at all levels. Taken together, FDIC paid 

$12.7 million to MWOLF firms and Diverse Attorneys out of a total of $48.0 million 

dollars paid to outside counsel in 2018 [See, Figure 6.] For both MWOLFs and Diverse 

Attorneys, FDIC legal matters provide important learning and professional client 

development opportunities that can be quite meaningful to career advancement. For 

the year 2018, the Legal Division has an aggregate 26.5 percent diversity and inclusion 

participation rate in legal contracting.

Figure 6 2018 Participation Rate of MWOLFs and Diverse Attorneys (in Millions) 

$35.3 

73.5% 

$12.7

26.5% 

MWOLFs and Diverse Attorneys Non-MWOLFs

Referrals to 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 104 referrals to outside counsel in 2018, of which 29 (28 

percent) were to MWOLFs, compared to a total of 363 referrals, of which 67 (18.4 

percent) were to MWOLFs in 2017. Referrals to MWOLFs in 2018, by category, were as 

follows: Black American – 13 (12.5 percent), Hispanic American – 9 (8.6 percent), Native 

American – 1 (<1 percent), and Women – 6 (5.8 percent). [See Figure 7.]
12 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

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

Figure 7 2018 Number of Referrals to MWOLFs by Category

Non-MWOLF 65

62.5%

Black 13

12.5%

Hispanic 9

8.6%

Native American 1

1%

Women 6

5.8%

Non-Reported 10

9.6%

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

decreased from 2017 to 2018. In 2018, the FDIC paid $48.0 million to outside counsel, as 

compared to $61.5 million in 2017. The FDIC paid $3.7 million to MWOLFs in 2018, 

which represents 7.7 percent of the total paid to all law firms. This percentage is below 

that of 2017, during which the FDIC paid a total of $6.5 million to MWOLFs, which was 

10.5 percent of the total paid to all law firms that year. The decrease in bank resolution 

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

since the peak levels in 2013 [See Figure 8.]

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

MWOLFs Non-MWOLFs

$15.3 $11.7 $11.1 $3.7 

$105.6 

$86.7 

$65.7 

$55.0 

$44.3 

 $-

 $20.0

 $40.0

 $60.0

 $80.0

 $100.0

 $120.0

 $140.0

2014 2015 2016 2017 2018

$98.4

$61.5

$48.0

$120.9

$76.8

$6.5 $3.7 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 13

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

Although there was an overall decline in referrals to all outside counsel in 2018, there 

was an increase in the percentage of referrals to MWOLF firms in 2018 over 2017, 

28 percent in 2018 versus 18.4 percent in 2017. The FDIC remains committed to seeking 

ways to increase the level of referrals and fees paid to MWOLFs and Diverse Attorneys 

in 2019 and beyond.

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, women, and minority-owned and women-owned businesses 

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 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 which all further the 

partnership potential of Diverse Attorneys.

In 2018, Diverse Attorneys at majority owned law firms billed $8.9 million on FDIC legal 

matters or 18.6 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 2018 Fees Billed by Diverse Attorneys at Majority Law Firms (in Millions) 

$8.9

18.6% 

$39.1

81.4%

Diverse Attorneys Non-Diverse Attorneys
14 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

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

Outreach to MWOLFs

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

partnerships with minority bar associations and specialized stakeholder organizations. 

In 2018, the FDIC Legal Division participated in six minority bar association 

conferences and three stakeholder events in support of maximizing the participation 

of MWOLFs and Diverse Attorneys in FDIC legal contracting. FDIC representatives 

at these events participated on several panels and committees, such as the National 

Association of Minority and Women Owned Law Firms (NAMWOLF) Advisory Council, 

the NAMWOLF Events Committee, the NAMWOLF Law Firm Admissions Committee, 

and the NAMWOLF Diversity and Inclusion Initiative.

In 2018, NAMWOLF 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. Members of the Inclusion Initiative have spent over $1 billion with MWOLF 

firms since its inception. The FDIC participates in the Inclusion Initiative along with 

major corporations.

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

contracting opportunities by producing tangible, meaningful, and measurable results. 

The most important source of legal contracting opportunities lies with the FDIC 

in-house attorneys. To that end, in 2018 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 participation. The Legal Division, 

among other things, consistently emphasizes the importance of diverse staffing 

of legal contracts to its attorneys in its regional offices. For example, the Legal 

Division held its annual MWOLF Outreach Workshop in the Dallas Regional Office 

for those in-house FDIC attorneys, who assign work to outside counsel. The purpose 

of the workshop was to focus on the contribution of the FDIC in-house attorneys 

in supporting the goal of diversity and inclusion in legal contracting. The program 

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

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

and retention of outside counsel.

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

MWOLF outreach. In 2018 the Legal Division collaborated with a top rated New York 

MWOLF firm to present a full day continuing education seminar on cutting edge legal 

issues in the capital markets area to FDIC attorneys who are responsible for engaging 

outside counsel. The program was designed to showcase the MWOLF’s expertise 

while providing the firm with valuable opportunities to build meaningful relationships 

with FDIC oversight attorneys at headquarters and in the regional offices. In its 

ongoing diversity and inclusion efforts, the Legal Division continues to seek more 

opportunities to highlight the expertise of MWOLF firms in accordance with the needs 

of the FDIC at any given point in time.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 15

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

The Legal Division evaluated and approved six new MWOLF applications in 2018. 

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 MWOLF outreach programs that 

mirror FDIC’s program. 

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 ten billing law firms (both 

majority-owned 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 best 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, FDIC’s Legal Division 

keeps apprised of innovative diversity strategies, new opportunities for inclusion, 

pursuant to this program. Further, the Legal Division reaches commitments with 

various firms to increase diverse staffing on FDIC legal matters. As a result, the FDIC 

has witnessed a meaningful shift in the diversity and inclusion efforts at many of 

the largest majority owned outside firms to which FDIC refers legal work since the 

inception of the assessment program.

Contracting Initiatives, Programs and Outreach

The FDIC awarded 565 new contracts with a combined value of $499.5 million in 

2018. The number of new contracts awarded in 2018 represents the fewest number 

of awarded contracts by the FDIC since 2009, and represents a 56 percent decrease 

from the average number of contracts awarded annually between 2009 and 2017. The 

total contract award dollars in 2018 of $499.5 million represents the lowest contract 

award value since 2008, and a 74 percent decrease in the average total contract 

dollars awarded during the height of the financial crisis from 2009 to 2012. As stated 

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

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

were no bank failures in 2018. 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 2018, only 13.9 percent of FDIC total contract dollars 

awarded supported the FDIC’s Division of Resolutions and Receiverships (DRR) in their 

mission to resolve failed banks.
16 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

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

As a result, the FDIC continued to identify contracting opportunities for MWOBs 

in non-financial goods and services requirements. For example, contracts were 

awarded to MWOBs in the following areas: IT consulting, software development and 

maintenance services; IT security services; IT hardware and software licenses; training 

services; shuttle bus services; janitorial services; deskside coaching services, video 

production services; facilities services; and equal employment opportunity (EEO) 

investigation services.

Despite no bank failures in 2018, the FDIC continued to include MWOBs in the 

procurement process for the financial services contract opportunities that arose. 

Several of the contracts used to perform failed bank resolution services during 

the most recent financial crisis expired in 2018. The FDIC’s strategy is to re-bid 

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

needs arise. 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 

2018 for financial advisory services-complex financial institution (CFI) non-deposit 

claims; receivership financial accounting and reporting; qualified financial contracts 

(QFC) portfolio valuation and consulting services; strategic communications advisory 

services; accounting services; and audit services that will be used to support future 

bank failures. Additional existing failed bank resolution contracts will expire in 2019 

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 awarded 

task orders to MWOBs under existing contracts in 2018 to support planning for future 

bank failures and for services to resolve pre-2018 bank failures.

Lastly, 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 2016, 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 17

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

additional firms were competitively added to the ITAS II BOA. Currently, 7 of the 14 

firms (50 percent) under the ITAS II BOA are MWOBs. Only 1 in 4 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. Fifteen of the 29 task orders 

awarded under ITAS II in 2018 were awarded to MWOBs with a combined value of 

$24.8 million. This represented 51.7 percent of the total task orders awarded and 48.1 

percent of the $51.5 million in total task order dollars awarded. The services provided 

under the task orders awarded to MWOBs in 2018 were for mission critical services to 

develop, maintain and enhance FDIC’s IT systems.

ITAS II is not the only contract that supports the FDIC’s Information Technology 

program. Three contracts with a combined value of $1.6 million were awarded to 

MWOBs to provide IT security services and/or FISMA support services.

Lastly, the FDIC also recognizes 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 90 contract awards to 

MWOBs with a combined value of $40.3 million.

Facilities Management Services

Significant awards to MWOBs in facilities management services included contracts 

valued at $17.6 million for janitorial services; $7 million for shuttle bus services; $6.2 

million for an HVAC project; $913,301 for Video Production Services; and $128,042 for a 

generator replacement project.

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

and replacement furniture and carpet. In total, six contracts with a combined value 

of $888,075 were awarded to MWOBs to provide furniture and carpet for FDIC 

locations nationwide.

Bank Resolution Contracts

Although there were no bank failures in 2018, there are still over 250 active failed bank 

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

task orders to MWOBs to provide required services to resolve pre-2018 bank failures 

and planning services for future bank failures. In 2018, 37 contracts and task orders 

with a combined value of $9 million were awarded to MWOBs to provide the required 

financial services to support the FDIC in resolving past and future bank failures. 

Contracts awarded to MWOBs included, but were not limited to: accounting services; 

information security services; information technology development services; financial 
18 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

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

valuation services; receivership assistance services; temporary staffing services; 

security assessment services; internet marketing and sales services; tax services; and 

translation and transcreation services for conveying messages in another language.

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 a contract with a value of $180,375 to an MWOB firm to provide learning and 

curriculum development services. The FDIC’s Legal Division awarded a $1.8 million 

contract to an MWOB to provide deskside coaching services. The FDIC’s Division of 

Depositor and Consumer Protection awarded two contracts with a combined value of 

$371,844 to an MWOB firm to provide information security awareness training. The 

Office of Inspector General awarded a $686,078 contract to an MWOB for IT support 

services. The Office of Minority and Women Inclusion awarded a $1 million contract to 

an MWOB for EEO investigative services.

Outreach to MWOBs

In 2018, the FDIC participated in a combined total of 36 business expos, one-on-one 

matchmaking sessions, and panel presentations. The FDIC and other OMWI agencies 

presented as panelists during various procurement events including the Reservation 

Economic Summit (RES), the Annual Government Procurement Conference and the 

United States Pan Asian American Chamber of Commerce, educating attendees 

about doing business with their agencies. 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 encouraged to register 

through the FDIC’s CRL.

The eight OMWI agencies co-hosted the Smart Contacts – Smart Contracts Technical 

Assistance Event in collaboration with the University of Texas San Antonio, Institute 

for Economic Development, Minority Business Development Agency and the Business 

Center San Antonio. The event was held August 29, 2018, in San Antonio, Texas. The 

featured presenters’ topics were Smart Tactics, Tools, and Resources for Connecting 

the Dots, and Smart Federal Proposal Writing. Other highlights of the event included 

the Doing Business with the OMWI Agencies panel, Local Resource Partner Panels, 

and various Resource Panels exhibiting at the event including a joint OMWI resource 

table. There were 199 attendees at this event.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 19

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

In addition, the FDIC attended the 2018 Puerto Rico Federal Business Opportunities 

Conference to identify MWOBs to do business with FDIC. This conference has been 

successful in identifying mature firms that were able to compete and win significant 

work with FDIC. This was a structured program that included networking and 

matchmaking sessions. Attending a similar conference and including firms from that 

conference in the 2012 competitive acquisition for the second generation Information 

Technology Application Services (ITAS II) contract directly resulted in the competitive 

award of over $48 million dollars from 2013 to 2018 to a Hispanic firm that FDIC was 

introduced to at the conference.

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. No events were held 

in 2018, as there were no bank failures.

Challenges

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

contract dollars awarded has declined significantly since 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. In 2018, total FDIC contract dollars awarded were 

$499.5 million, which represented the lowest total value of new contracts awarded 

since 2008, and total contracts awarded were 565, which represented the fewest 

contracts awarded since 2009. Only 13.9 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 contract awards. In years when there are few bank failures, these 

non-financial recurring goods and services contracts represent the majority of FDIC 

contract awards. Typical contract awards for non-financial goods and services (e.g., 

dental, life, and vision insurance for employees; subscription services; office supplies; 

security guard services; facilities management services; and IT services) may range 

from $300 million to $500 million annually.
20 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

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

While smaller firms that are not national in scope are capable of providing some of the 

FDIC’s required recurring services, 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. 

However, for each new contract, the FDIC explores alternative strategies to determine 

if a change in procurement strategy can increase competition while still providing 

cost and administratively effective services. One example of a strategy change that 

was successful to increase MWOB participation was the ITAS II BOA described earlier. 

Despite expanded market research and proposed strategy changes, the FDIC has 

not found success to date with some of the other larger contracts that make up a 

disproportionate share of the total dollars awarded. Examples of this are the dental, 

life and vision insurance benefits programs for employees and the management of 

the FDIC’s student residence center and cafeterias. The FDIC will continue to explore 

procurement strategy changes where feasible.

An additional challenge the FDIC will face is the unknown impact on new contract 

awards that the implementation of updated National Institute of Standards and 

Technology (NIST) security standards will have on future FDIC contracts. These 

standards pertain to contracts where the FDIC provides confidential, sensitive, or 

personally identifiable information to a contractor to host the information on a third 

party system that is not directly owned by the federal government or the FDIC. 

The FDIC implemented new contract clauses that incorporated these new security 

standards in late 2018. These new contract clauses include additional information 

technology security controls that were not included in previous FDIC contracts. Since 

the new contract clauses add additional requirements to protect FDIC’s information, 

the possibility exists that some firms may elect to not bid on an FDIC contract. This 

may occur if the contractor’s security systems do not meet FDIC’s new standards.

Despite the decline in contract dollars awarded, the FDIC through its aggressive 

outreach program continues to educate and equip MWOBs with the tools they need 

to compete for contracting opportunities. These programs resulted in an increase in 

total contract dollars awarded to MWOBs from 18.5 percent in 2017 to 24.5 percent in 

2018, and total contracts awarded to MWOBs from 28.5 percent in 2017 to 29.4 percent 

in 2018. 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 2018 Report to Congress 21

EMPLOYMENT AT THE FDIC:

Increasing Representation of Minorities 

and Women

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

segments of society. The following sections provide information on current levels of 

diversity within the agency, initiatives to promote diversity and inclusion, as well as 

challenges the agency faces in its efforts to promote greater diversity within hiring 

and employment.

Diversity in Employment and Hiring

As of December 31, 2018, minorities accounted for 29.8 percent (1,760) of the 

FDIC’s total workforce (permanent and non-permanent) of 5,911 employees, and 

women accounted for 44.8 percent (2,648). [See Figure 10.] More specifically, the 

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

end of December 2018 were as follows: 1.6 percent for people of two or more races, 

0.6 percent American Indian or Alaska Native (AIAN), 5.9 percent Asian American, 17.5 

percent Black American, and 4.2 percent Hispanic American.
22 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

WORKFORCE DIVERSITY

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

 as of 12/31/2018

Minority Non-Minority Total

Number 1760 4151 5911

Percent 29.8% 70.2% 100.0%

Men Women Total

Number 3263 2648 5911

Percent 55.2% 44.8% 100%

2 or More AIAN Asian Black Hispanic White Total

Number 94 33 348 1037 248 4151 5911

Percent 1.6% 0.6% 5.9% 17.5% 4.2% 70.2% 100.0%

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

slightly 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 29.8 percent as 

of December 31, 2018. The percentage of women in the FDIC’s permanent workforce 

was 43.6 percent as of July 31, 2010, and 44.8 percent as of December 31, 2018. [See 

Appendix C.]

As of December 31, 2018, minorities accounted for 17.6 percent (24) of the FDIC’s total 

Executive Manager (EM) workforce of 136 employees, and women accounted for 36.0 

percent (49). [See Figure 11.]

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

 Executive Manager Workforce as of 12/31/2018

Minority Non-Minority Total

Number 24 112 136

Percent 17.6% 82.4% 100.0%

Men Women Total

Number 87 49 136

Percent 64% 36.0% 100.0%

2 or More AIAN Asian Black Hispanic White Total

Number 0 1 5 15 3 112 136

Percent 0.0% 0.7% 3.7% 11.0% 2.2% 82.4% 100.0%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 23

WORKFORCE DIVERSITY

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

the passage of Section 342 of the DFA. Of the FDIC’s total EM workforce, minorities 

accounted for 15.7 percent as of July 31, 2010, and 17.6 percent as of December 31, 

2018. The percentage of women in the FDIC’s EM workforce was 25.0 percent as of 

July 31, 2010, and 36.0 percent as of December 31, 2018. Appendix C depicts the FDIC’s 

five-year trends for the total, permanent, and EM workforce for 2014 through 2018.

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. FDIC’s largest occupational group 

is bank examiners. The recruitment of entry-level examiners as Financial Institution 

Specialists (FIS) is conducted primarily through the FDIC’s Corporate Employee 

Program (CEP). 

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 each incoming class of CEP hires, and 

each report included the total CEP participants from the inception of the program, FISs 

currently onboard, and voluntary and involuntary attrition information.

For the years before the inception of the CEP in 2005, several racial, ethnic and gender 

groups, as well as employees with disabilities, had low representation rates in the 

FDIC’s examiner workforce. To help address these issues, the FDIC has engaged 

in a proactive recruitment effort and has used recruiting strategies that have been 

successful in improving low representation rates of several racial, ethnic, and gender 

groups. That progress is especially apparent with respect to the overall percentage of 

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

31, 2004, to 38.8 percent as of December 31, 2018. 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 White women in the overall 

examiner workforce all have increased since the beginning of the CEP. 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.

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

percentages in the CLF for American Indian or Alaska Native men and women, Black 

American men and women, and men of two or more races, but lower than the CLF 

for Asian American men and women, Hispanic American men and women, White 
24 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

WORKFORCE DIVERSITY

women, and women of two or more races. [See Figure 12.] The overall minority 

hiring rate since the inception of the CEP has been 27.4 percent; and the overall hiring 

rate for women has been 38.9 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 17 21 4 11 41 59 182 117 37 45 476 937 1947

% 0.9% 1.1% 0.2% 0.6% 2.1% 3.0% 9.3% 6.0% 1.9% 2.3% 24.4% 48.1% 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%

During 2018, the CEP hiring rates were at or above the CLF percentages for Asian 

American women, Black American men, White women, and men and women of two 

or more races, and were below the CLF for American Indian or Alaska Native women 

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

women, and White men. While the hiring rates appear to be normal annual fluctuation 

in most cases, targeted recruitment will continue in order to reach Black American 

women, Asian men, and Hispanic American women and men. [See Figure 13.] The 

overall hiring rate in 2018 for minorities and women was positive with minorities 

having little statistical disparity from the CLF and women hired at a rate above the CLF.

Figure 13 CEP Hires in 2018 (Classes 63 – 67)

2 or More AIAN Asian Black Hispanic White Total

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

CEP 3 4 0 0 5 4 9 5 4 1 42 59 136

% 2.2% 2.9% 0.0% 0.0% 3.7% 2.9% 6.6% 3.7% 2.9% 0.7% 30.9% 43.4% 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%

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 126 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 2018, FDIC recruiters attended 

22 national diversity outreach events and 6 regional outreach events to increase 

awareness of the FDIC as an employer of choice to professionals. The FDIC also met 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 25

WORKFORCE DIVERSITY

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 2018 Association of Latino 

Professionals for America (ALPFA) National Convention. 

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

corporate recruiters participated in 203 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 2018 also 

included the following:

§ Hosted two student workshops at the 2018 ALPFA National Convention entitled 

Career Choices (Passion vs Salary), inspiring students to consider various factors 

during their search for employment.

§ Hosted a student workshop at the 2018 Hispanic Association of Colleges and 

Universities (HACU) Annual Conference, Money Management and Wealth Building 

Skills: College and Beyond, educating students on advanced money management 

skills that will assist them in achieving their financial goals.

§ Organized participation in the CyberCorps Scholarship for Service Virtual Career 

Fair in support of expanding awareness and interest in cybersecurity positions at 

the FDIC.

§ Hosted a workshop at the 2018 Thurgood Marshall Leadership Institute on 

personal branding for students from HBCUs. FDIC representatives also conducted 

informational interviews for the Financial Management Scholars Internship Program 

during the Leadership Institute.

To assist in increasing participation rates for underrepresented groups in the nonexaminer occupations listed above, the FDIC recruitment plan includes strategies 

for outreach to prospective applicants for entry-level positions in these occupations 

throughout the agency. In 2018, these efforts led to increased level of minority 

representation within the economist occupation at FDIC. The FDIC’s Division of 

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

partnered with Delaware State University (DSU) to improve the diversity pipeline of 

economic applicants for Economic Research Assistants and intern positions. Recruiters 

met with DSU staff and students to expand the students’ knowledge of how pursuing 

a degree in economics can benefit their careers. Staff participated in DSUs Delaware 

Executive Exchange Program (DEEP) Day. DEEP Day was developed to provide 

students with an opportunity for professional development, while engaging with toplevel executives. In 2019, DIR plans to establish partnerships with other HBCUs.
26 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

WORKFORCE DIVERSITY

In an effort to cultivate and strengthen diversity outreach for entry-level positions 

through alumni relationships with universities and colleges, DIR established an alumni 

log for Economists, Economic Analysts, and Economic Research Assistants. 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.

In addition, the EAC held a discussion on recruiting from a diverse pipeline, after a 

presentation on that subject was conducted by the Human Resource Branch. 

Diversity and Inclusion Analytics Dashboard

Included in the FDIC’s Diversity and Inclusion Strategic Plan is the goal to develop 

structures and strategies to equip FDIC leaders with the ability to manage diversity, 

measure results, refine approaches on the basis of available data, and institutionalize 

a culture of inclusion. In addition, after reviewing several financial services industry 

regulators in 2013, the U.S. Government Accountability Office (GAO) recommended 

that the agencies report on efforts to measure the progress of their employment 

diversity and inclusion practices, including measurement outcomes as appropriate, to 

indicate areas for improvement as part of their annual reports to Congress.3

To implement its strategic plan and address the GAO recommendation, the FDIC 

developed a workforce analytics dashboard to provide actionable data to senior 

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

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

(permanent and non-permanent). The analytics dashboard has been an important 

management tool for diversity and inclusion since being launched on June 20, 2013. 

It allows FDIC senior leaders to support diversity and inclusion efforts in hiring, 

promotion and retention, and to identify ways to make improvements over time.

The dashboard was used during 2018 by FDIC divisions and offices to support 

recruitment activities geared toward increasing the pool of minority and women 

applicants; assess the inclusion of minorities and women at all levels of the 

organization; and evaluate diversity-related issues reported in the Federal Employee 

Viewpoint Survey. Senior leaders have access to workforce data that are updated 

quarterly and give them the ability to develop strategies, measure progress and adjust 

plans where needed. The FDIC will continue to identify additional enhancements to the 

dashboard that will permit senior leaders to continue understanding and advancing 

3 Trends and Practices in the Financial Services Industry and Agencies after the Recent Financial Crisis, 

GAO-13-238, April 16, 2013
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 27

WORKFORCE DIVERSITY

diversity and inclusion within their organizations. As in past years, the FDIC will use 

data from the dashboard in 2019 to help drive diversity and inclusion strategic plans at 

the division and office levels.

Succession Planning

Like many other federal agencies, the FDIC faces potential succession management 

challenges as many of its long-term, experienced employees become eligible 

for retirement. Introduced in 2014, the FDIC’s Workforce Development Program 

(WDP) seeks to prepare employees to fulfill current and future workforce capability 

and leadership roles. This focus will help to ensure that the FDIC has a workforce 

positioned to meet today’s core responsibilities while preparing to fulfill its mission in 

the years ahead.

During 2018, the FDIC continued to develop and implement the WDP to address 

comprehensive succession planning needs and workforce development challenges 

and opportunities. The FDIC is committed to building and growing its talent pipeline 

to ensure succession challenges are met. To that end, the agency expanded its 

succession planning efforts approach to include a survey of 4,000 non-supervisory 

employees occupying positions that could populate the agency’s longer term pipeline 

for management positions. The survey was designed to identify the population’s 

aspiration to higher level and management roles, their perceptions of readiness for 

these opportunities and actions they have taken to prepare themselves.

In 2018, the FDIC analyzed the results, finding that nearly two-thirds of mid-level nonsupervisor respondents reported that they were interested in seeking higher-level 

positions at the FDIC. Of these, over three-fourths believe they have the talents and 

skills for higher level positions and plan to apply for promotions and details over the 

next five years, demonstrating their ongoing interest in career development. The FDIC 

also learned that less than half of respondents have discussed their career interests 

and plans with a manager.

As a result, in 2019, FDIC plans to leverage non-supervisors’ interest in higher 

level and management positions to further develop the longer-term pipeline of the 

FDIC’s aspiring leadership pool. Plans include supervisory training in succession 

management techniques, the development of resources to support career planning 

discussions between managers and staff, and promotion of emerging manager 

coaching through FDIC’s Career Management Program. 

In 2019, the FDIC will continue to develop and implement the strategies and programs 

to support the goal of meeting its long-term workforce needs. OMWI collaborates 

closely on these efforts and helps to ensure that minorities and women have an equal 

opportunity to participate.
28 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

WORKFORCE DIVERSITY

Inclusion Initiatives

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

efforts within the agency, 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.

Additionally, the 2018 FDIC Performance Goal to promote diversity, inclusion, and 

workplace excellence, through the roll out of Diversity 101 online training for FDIC 

employees, was successfully accomplished. The FDIC launched the web-based 

Diversity 101 training, which is available to all employees and required for new FDIC 

employees. The training helps employees recognize the importance of inclusion and 

respect in the workplace and provides techniques on how to respond appropriately 

in common situations involving diversity dynamics. Completion rates are tracked and 

reports are periodically shared with agency executives at EAC meetings.

In 2018, 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, two area office, 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 

and inclusion goals and strategies.

In 2018, the CDACs continued to advise senior management regarding diversity 

related issues generated by employees. 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 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.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 29

WORKFORCE DIVERSITY

The FDIC also continues to engage with and leverage its ERGs. OMWI staff regularly 

meets with the ERGs to discuss programs and issues. In 2018, two ERGs briefed the 

FDIC executives serving on the agency’s EAC, and provided information on group 

accomplishments and planned activities. This exchange initiated discussions on 

ways in which ERGs can further support diversity and inclusion initiatives at the FDIC. 

Opportunities for additional briefings will be provided in 2019.

Challenges

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

continues to be the ability to attract and retain minorities and women in its bank 

examiner workforce. The examiner occupation represents the largest occupational 

group at the FDIC and accounts for 46.4 percent (2,743) of the FDIC total workforce 

(5,911). 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.

One of the feeder pools for the CEP program, 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 under the CEP. The FMS program has hired, in 

aggregate, above the CLF for women since the inception of the program in 2011. While 

the pool is small, comprising 262 (46 percent) women out of 570 participants over the 

life of the program this success has helped to diversify the pool of potential examiners 

with regard to gender. Participation for minorities in the FMS program has increased 

steadily, but has remained below the CLF.

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, Black American women, and women of two of more races. CEP attrition 

data will continue to be monitored and strategies implemented to retain qualified 

examiner workforce. [See Figure 14.]
30 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

WORKFORCE DIVERSITY

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 1947 17 21 4 11 41 59 182 117 37 45 476 937

Involuntary

Departures 39 0 0 0 0 1 1 8 9 1 2 4 13

Involuntary

Attrition

Rate+(%)

2.0% 0.0% 0.0% 0.0% 0.0% 2.4% 1.7% 4.4% 7.7% 2.7% 4.4% 0.8% 1.4%

Subtotal 1908 17 21 4 11 40 58 174 108 36 43 472 924

Voluntary

Departures 666 2 2 1 5 14 30 67 52 11 15 162 305

Voluntary

Attrition

Rate *(%)

34.9% 11.8% 9.5% 25.0% 45.5% 35.0% 51.7% 38.5% 48.1% 30.6% 34.9% 34.3% 33.0%

Number

Retained 1242 15 19 3 6 26 28 107 56 25 28 310 619

+ “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/ 

auditors, attorneys, and general business and industry, the FDIC faces 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 has improved significantly and is currently 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 and women 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.

In the financial administration and program occupation, women overall, Hispanic 

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

men fall below the CLF. American Indian or Alaska Native men and women of two or 

more races are absent in this occupation. Overall, minorities are above the CLF for this 

occupational series.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 31

WORKFORCE DIVERSITY

Women overall, including Hispanic American women, White women, Black American 

women, Asian American women, American Indian or Alaska Native women, and 

women of two or more races fall below the CLF in the general business and industry 

occupation. Men overall, including Hispanic American men, White men, Black 

American men, Asian American men, American Indian and Alaska Native men, and 

men of two or more races all exceed the relevant CLF for this occupation.

For the accountant/auditor occupations, Hispanic American men and women, 

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

races are absent. White women and Asian American men have a low representation 

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

minorities are above the CLF benchmark for this occupation while women are below.

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

Hispanic American men and women and Asian American men have participation 

rates slightly below the relevant CLF in the attorney occupation. Women overall are 

above the CLF, while men overall are below. Women of two or more races are absent 

in this occupation.

In 2018, the FDIC continued monitoring race, ethnicity, gender, and grade levels by 

FDIC divisions and offices. As a result, the FDIC continues expanding outreach and 

recruitment more broadly to increase minority and women representation at senior 

levels within the FDIC. The FDIC also issued an updated Diversity and Inclusion 

Strategic Plan in 2018. Implementation of this plan includes strategies to recruit, 

advance, and retain a diverse workforce.
32 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

PAGE 

INTENTIONALLY 

LEFT BLANK
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 33

OTHER ACTIVITIES

Financial Institutions Diversity

The FDIC’s Financial Institution Diversity program is responsible for assessing the 

diversity policies and practices of FDIC-regulated financial institutions.

The FDIC OMWI continued to work closely with the OMWI Directors of the Office of the 

Comptroller of the Currency (OCC), the National Credit Union Administration (NCUA), 

the Federal Reserve Board (FRB), the Consumer Financial Protection Bureau (CFPB), 

and the Securities and Exchange Commission (SEC) to further implement Section 

342(b)(2)(C) of the DFA, which requires regulatory agencies to develop standards for 

assessing the diversity policies and practices of the institutions they regulate. After 

publishing the final Interagency Policy Statement Establishing Joint Standards for 

Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies

(Policy Statement), in the Federal Register in June 2015, the FDIC sought OMB approval 

to collect information from their regulated entities.
34 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

OTHER ACTIVITIES

The Policy Statement provides the framework for FDIC-regulated financial institutions 

to voluntarily assess their diversity policies and practices in the following areas:

§ 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-regulated financial institutions began using and voluntarily submitting 

diversity self-assessments to OMWI for the 2016 reporting period. Results of the FDIC’s 

2016 analyses established the baseline for subsequent reporting periods.

In November 2017, the FDIC’s then Acting OMWI Director distributed a letter 

to the Presidents and Chief Executive Officers of 820 FDIC-regulated financial 

institutions identified as having 100 or more employees. The letter encouraged 

these institutions to conduct the annual self-assessment of its diversity policies 

and practices and submit their diversity information to the FDIC. In March 2018, a 

reminder letter from the OMWI Director was distributed to financial institutions to 

again encourage participation.

In 2018, OMWI issued internal procedures related to the processing of diversity selfassessments.

Self-Assessment Benchmarking Results for 2017 Reporting 

Period

The FDIC received diversity self-assessments from 137 (16.7 percent) of its regulated 

financial institutions. This was a 44.2 percent increase from the 2016 reporting period 

(95 financial institutions) to the 2017 reporting period (137 financial institutions).

While the FDIC is pleased with the increased participation of financial institutions in 

2017, it will continue to take steps to increase voluntary participation by augmenting 

outreach at banking conferences, developing financial institution diversity marketing 

materials, and making improvements to the program website.

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

practices for the 2017 reporting period and a conducted a comparative analysis 

conducted against the 2016 reporting period, 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.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 35

OTHER ACTIVITIES

The data for the 2016 versus the 2017 reporting period showed a small decrease in 

the number of financial institutions with designated Diversity and Inclusion Officers 

and a slight increase in financial institutions with Supplier Diversity Officers. In 2016, 

82 of 95 financial institutions had Diversity and Inclusion Officers versus 81 of 137 in 

2017. In 2016, 41 of 95 financial institutions had Supplier Diversity Officers versus 44 

of 137 in 2017.

Aggregated Assessment of FDIC-Regulated Financial 

Institutions Policies and Practices - Breakdown by Standard

Subsection 1: Organizational Commitment to Diversity and Inclusion

Based on the 2016 and 2017 data, the organizational commitment to Diversity and 

Inclusion has increased. This subsection had the second highest overall percent 

of change from 2016 to 2017 (a six percent increase). The responses indicated 

the financial institutions embrace the Standards in this subsection. The highest 

increased response (nine percent) was in reference to the financial institutions that 

included employment and contracting diversity and inclusion considerations in their 

strategic plan.

Organizational Commitment to Diversity and Inclusion 2016 versus 2017 Results

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

1. Organizational Commitment to Diversity and Inclusion Average: 

82%

Average: 

88%

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% 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% 87%

1.3 The financial institution provides regular progress 

reports to the board and senior management. 75% 81%

1.4 The financial institution regularly conducts training 

and provides educational opportunities on equal 

employment opportunity and on diversity and 

inclusion.

82% 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% 91%
36 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

OTHER ACTIVITIES

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

1. Organizational Commitment to Diversity and Inclusion Average: 

82%

Average: 

88%

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% 93%

Subsection 2: Workforce Profile and Employment Practices 

The workforce profile and employment practice had the highest average change 

from 2016 to 2017 (a seven percent increase). These numbers indicated the financial 

institutions embraced the Standards in this subsection. The highest positive change 

(14 percent) referred to holding management at all levels accountable for diversity 

and inclusion efforts. The second highest positive change (10 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 versus 2017 Results

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

2. Workforce Profile and Employment Practices Average: 

77%

Average: 

84%

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% 96%

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% 98%

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% 81%

2.3(b) Outreach to educational institutions serving significant 

minority and women student populations. 66% 74%

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% 71%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 37

OTHER ACTIVITIES

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

2. Workforce Profile and Employment Practices Average: 

77%

Average: 

84%

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% 88%

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% 83%

Subsection 3: Procurement and Business Practices - Supplier Diversity

Procurement and Business Practices - Supplier Diversity had the lowest average 

with five percent decrease from 2016 to 2017. In future years, the FDIC expects to see 

percentage improvement in all of the Supplier Diversity responses.

Procurement and Business Practices – Supplier Diversity 2016 versus 2017 Results

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

3. Procurement and Business Practices - Supplier 

Diversity

Average: 

24%

Average: 

19%

3.1 The financial institution has a supplier diversity policy 

that provides for a fair opportunity for minorityowned 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%

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% 19%

3.2(b) Percentage of contract dollars awarded to minorityowned and women-owned businesses by race, 

ethnicity, and gender.

16% 14%
38 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

OTHER ACTIVITIES

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

3. Procurement and Business Practices - Supplier 

Diversity

Average: 

24%

Average: 

19%

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

women-owned business subcontractors. 15% 13%

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%

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%

3.3(c) An ongoing process to publicize its procurement 

opportunities. 23% 16%

Subsection 4: Practice to Promote Transparency of Organizational 

Diversity and Inclusion

The practice to promote transparency of organizational diversity and inclusion had 

an average positive change of three percent from 2016 to 2017. The highest positive 

change (seven percent) referred to a financial institution publicizing its policy on its 

commitment to diversity and inclusion. The second highest positive change (five 

percent) referred to financial institutions publicizing opportunities to promote diversity 

with their current employment and procurement opportunities. 

Practice to Promote Transparency of Organizational Diversity and Inclusion 2016 

versus 2017 Results

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

4. Practice to Promote Transparency of Organizational 

 Diversity and Inclusion

Average: 

51%

Average: 

54%

4.1 The financial institution publicizes its diversity and 

inclusion strategic plan. 33% 32%

4.2 The financial institution publicizes its policy on its 

commitment to diversity and inclusion. 64% 71%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 39

OTHER ACTIVITIES

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

4. Practice to Promote Transparency of Organizational 

 Diversity and Inclusion

Average: 

51%

Average: 

54%

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% 59%

4.4. The financial institution publicizes its opportunities to 

promote diversity, which may include:

4.4(a) Current employment and procurement 

opportunities.

76% 81%

4.4(b) Forecasts of potential employment and procurement 

opportunities. 23% 24%

4.4(c) The availability and use of mentorship and 

developmental programs for employees and 

contractors.

54% 55%

Subsection 5: Financial Institutions’ Self-Assessment

In this subsection, the average for financial institutions performing their annual selfassessment from 2016 to 2017 increased by two percent. 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’ Self-Assessment 2016 versus 2017 Results

Section II. Assessment of the Financial Institution’s Diversity 

Policies and Practices 2016 2017

5. Financial Institutions’ Self - Assessment Average: 

66%

Average: 

68%

5.1 The financial institution conducts an assessment of its 

diversity policies and practices annually. 86% 87%

5.2. The financial institution monitors and evaluates its 

performance under its diversity policies and practices 

on an ongoing basis.

83% 87%

5.3. The financial institution publishes information 

pertaining to its assessment of its diversity policies and 

practices.

28% 29%
40 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

OTHER ACTIVITIES

Financial Institution Diversity Data

The collective number of self-assessment responses from financial institutions on their 

workforce and employment practices, reflected an increase from 2016 to 2017. The 

collective responses received on the supplier diversity questions reflected a decrease 

for the same reporting periods.  As the program matures, the FDIC anticipates the selfassessments in aggregate will provide more data to build trend analysis on financial 

institution workforce and supplier diversity. 

In both the 2016 and 2017 reporting periods Workforce Profile data indicates that 

approximately 80 percent of the financial institutions reported their diversity data on 

their workforces, management, and board members. 

The data provided from both 2016 and 2017 for Procurement- Supplier Diversity are 

inconclusive. There was not enough data to analyze or to determine trends for the 

procurement supplier diversity subsection. The FDIC expects 2018 responses will 

provide more data to review and analyze. 

OMWI Outreach 

The OMWIs from eight financial regulatory agencies held the “Financial Regulatory 

Agencies’ Diversity and Inclusion Summit.” The Summit was held at the Federal 

Reserve Bank of New York on September 13, 2018, and included: the FDIC, OCC, 

NCUA, FRB, CFPB; the SEC; the Federal Housing Finance Agency; and the Department 

of the Treasury. 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 best 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 FDIC, OCC, SEC, 

NCUA, and FRB OMWI Directors. The Directors shared highlights on the results of 

assessments agencies received from their regulated entities. The OMWI Directors 

closed the Summit by encouraging participants to complete and submit their diversity 

self-assessments to their respective regulatory OMWI agency in order to contribute to 

the reports that the agencies release providing trends on diversity and inclusion in the 

financial industry. These efforts will continue to advance the visibility and adoption 

of diversity and inclusion practices in the financial industry. The Summit was wellreceived according to the feedback received from participants. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 41

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 2017 selfassessments showed:

1. Some financial institutions implemented or leveraged technology to connect with 

the public by posting information regarding their Diversity and Inclusion programs 

and efforts along with related recognitions and awards; while others aligned their 

Diversity and Inclusion business strategies and individual performance plans 

through diversity dashboard analytics that incorporate Diversity and Inclusion 

goals related to recruitment, hiring, and/or development.

2. Financial institutions identified, attracted, recruited and trained a diverse and 

qualified workforce by participating on the board of colleges; utilizing minority 

and women owned recruiting firms; reaching out to low income, minoritymajority local high schools and offering internships to students; and partnering 

and collaborating with professional diversity organizations, HBCUs, HACU, 

local non-profits and other diversity organizations to provide internship and 

learning opportunities. Several financial institutions established successful 

programs focusing on leadership, personal development and recruitment of 

recent college graduates.

3. Financial institutions implemented formal supplier diversity programs to 

provide opportunities for minority and women-owned businesses to compete 

for procurement of business goods and services, and required the inclusion of 

minority- or women-owned businesses in bid opportunities.

4. Financial institutions are also developing systems to facilitate the augmentation 

of demographic and procurement information. When vendor demographics are 

reflected in the market that matches an institution’s business and contractual 

needs, minority- or women-owned businesses are included in bid opportunities.
42 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 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 FDIC 

divisions and major offices engage in employment policies and practices that promote 

diversity and inclusion in their workforce. Therefore as a condition of doing business 

with the FDIC, contractors must commit to equal opportunity in employment and 

contracting. The fair inclusion standard is incorporated into the FDIC procurement 

policy from solicitation through contract execution.

Since September 1, 2011, the Fair Inclusion of Minorities and Women Standard 

is required in all FDIC solicitations and any contract for goods and services over 

$100,000. This mirrors the threshold at which, OMWI review is required to identify 

competitive MWOBs to include in contract solicitations. Under FDIC procurement 

policy, pursuant to Section 342 of the DFA, contractors doing business with the 

FDIC must certify their commitment to the inclusion of minorities and women in 

their workforce to the maximum extent possible. The standard advises contractors, 

currently engaged or seeking to do business with the FDIC, of their responsibility as a 

federal contractor to ensure equal employment opportunity.

Contractors seeking to do business with the FDIC must provide a written statement, 

known as the Fair Inclusion Certification, stating commitment to good faith efforts to 

include minorities and women in the workforce. Also, contractors are encouraged to 

promote workforce diversity with suppliers with whom they do business in relation 

to FDIC work. In addition, upon request, contractors must provide evidence of their 

efforts to include minorities and women in their workforce. The FDIC developed review 

procedures, Contractors’ Workforces Review Process (CWRP) to verify contractors’ 

commitment to diversity and inclusion. The CWRP established internal procedures 

to carry out the annual assessment of contractors’ good faith efforts. The CWRP 

monitors compliance with the Fair Inclusion requirements; and methods to enhance 

and improve contractor performance in the achievement of the workforce objectives 

and 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 160 reviews assessing the good faith efforts 

of contractors to promote diversity in employment. This represents 36 percent of 

the average total number of active FDIC contractors (448) with awards valued over 

$100,000 between 2016 and 2018. The number of active contractors does not remain 

static from year-to-year due to the expiration and award of new contracts. In 2018, the 

FDIC continued implementing the CWRP, selecting 75 contractors for review.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 43

OTHER ACTIVITIES

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. 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 diversity in employment 

and overcome identified barriers to minority and gender equitable employment. 

The FDIC requests support documentation from contractors that demonstrates 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, FDIC reviews 

OFCCP compliance investigation results and other available online information on the 

contractors’ diversity and inclusion practices. 

2018 Contractors’ Workforces Review

For 2018, 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 18 percent 

of active contractors for the year. For five contractors, compliance data was found in 

the OFCCP database. However, the information did not generally correspond to the 

contractors’ locations 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 that employed less than 50 people up to large 

corporations that employed 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 documentation that demonstrated their commitment. Eighty-four (84) percent of 

contractors responding to the good faith effort request leveraged information already 

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 professional 

organizations, etc. All information submitted was reviewed to determine whether the 

contractor efforts demonstrated: leadership commitment to diversity and inclusion; 
44 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

OTHER ACTIVITIES

availability of a plan to ensure minorities and women appropriate opportunities to 

enter and advance in the workforce; workforce demographics aligns with the labor 

market; outreach to broadly communicate opportunities; and or 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 that 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.

Community and Small Business Development 

In 2018, the FDIC provided technical assistance to banks and community organizations 

through more than 254 outreach events designed to increase shared knowledge and 

support collaboration between financial institutions and other community, housing, 

and small business development resources and to improve knowledge about the 

Community Reinvestment Act (CRA).

The FDIC’s work emphasized sharing information to support bank efforts to prudently 

provide affordable mortgage, small business credit and complementing access to safe 

accounts and financial education. As part of this effort, the FDIC also maintained the 

Affordable Mortgage Lending Center, a website that houses the Affordable Mortgage 

Lending Guide, a three-part resource to help community banks identify affordable 

mortgage products. The Guide’s three parts are: Part 1: Federal Agencies and 

Government Sponsored Enterprises (updated in October 2018); Part II: State Housing 

Finance Agencies; and Part III: Federal Home Loan Banks. 

Together these resources provide a comprehensive overview of the programs and 

products available to community banks to support affordable mortgage lending, 

particularly for borrowers with low or moderate incomes. 

By year-end 2018, the Affordable Mortgage Lending Center had: 

§ Added more than 7,000 subscribers from year-end 2017 to over 15,000;

§ Experienced more than 12,000 downloads since inception; and

§ Received more than 68,000 page views since inception.

In addition, the FDIC sponsored sessions with interagency partners covering basic 

and advanced CRA training for banks. The agencies also offered CRA basics for 

community-based organizations, as well as seminars on establishing effective bankcommunity collaborations for community development in more than 27 communities. 

The FDIC focused on encouraging community development initiatives in rural 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 45

OTHER ACTIVITIES

communities. This work included workshops that highlighted housing needs and 

programs, economic development programs, and community development financial 

institution collaborations, including those serving Native American communities.

Promoting Financial Access and Financial 

Literacy

Financial education helps consumers understand and use bank products effectively 

and sustain a banking relationship over time. The FDIC continued to be a leader 

in developing high-quality, free financial educational resources and pursuing 

collaborations to use those tools to educate the public. Money Smart products are 

available to teach consumers of all ages, as well as for people to learn on their own 

online. In particular, the newly updated Money Smart for Adults can help adults build 

the fundamental financial knowledge, skills, and confidence they need to use banking 

services effectively.

Money Smart for Adults 

Building on insights gained from more than 17 years of experience with the Money 

Smart program, the FDIC announced the release of the updated instructor-led 

curriculum for adults in October. The revised curriculum, field-tested twice with 

community organizations and banks, features 14 modules that cover basic financial 

topics for use during a group training or in one-on-one work with clients. A selfpaced online learning tool based on the updated curriculum is expected to be 

released in 2020.

The updated curriculum features:

§ An updated supplement featuring scenarios featuring individuals with disabilities 

thinking about a financial decision, which trainers can use to promote workshop 

discussions,

§ Expanded content on topics such as mobile banking, reading a pay statement, 

renting an apartment, and creative ways to save money, and updated information 

on standard topics such as credit reports and scores,

§ Vibrant graphics and discrete sections so instructors can create effective training 

sessions by choosing topics of interest to training participants,

§ “Try It” activities that provide engaging opportunities for participants to practice 

what they’re learning during training in many contexts, including realistic scenarios,

§ “Apply It” activities to help participants apply what they have learned to their own 

lives, either during or after training,
46 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

OTHER ACTIVITIES

§ “Key Takeaways” that briefly summarize the main message of each section,

§ A “Take Action” section in every module that encourages participants to identify at 

least one thing they plan to do because of what they learned during the training,

§ A new Guide to Presenting Money Smart for Adults that includes tools to help 

instructors present interactive, non-biased training using the updated curriculum, 

such as “roadmaps” to create customized training across modules, fun and 

engaging introductory activities to energize participants to learn, and detailed 

checklists to prepare for training.

More than 1,500 organizations were trained on the updated materials before year-end, 

including through two national webinars. In addition plans are underway to provide 

training to many more organizations.

The maximum potential of the curriculum is reached when banks collaborate with nonprofits or other community-based organizations to bring Money Smart training to local 

communities, and, when appropriate, connect the training to banking products and 

services that respond to the needs of participants. Through the Money Smart Alliance, 

the FDIC recognizes organizations that commit to using Money Smart and that want to 

receive regular updates and training tips to enhance their use of the curriculum.

More than 450 organizations joined the Alliance during 2018, bringing the total 

members to 1,062. The Alliance experienced a 34 percent growth during 2018 

compared to year-end 2017. This growth is largely attributable to the Money Smart 

Advance Team effort that built engagement with organizations that have or will deliver 

Money Smart to adults.

The FDIC engaged Alliance members through quarterly webinars that share helpful 

information to assist them with offering Money Smart training. Staff also conducted 

one-on-one calls with Alliance members to help increase communication between 

the FDIC and Alliance members. The calls were well received and appreciated by the 

Alliance members who shared how they use and plan to use Money Smart and shared 

input on the curriculum products. Alliance members also learned about the updated 

Money Smart for Adults curriculum (and had opportunity for early review of the 

modules) starting in September, several weeks before the broader public release.

Youth Financial Education 

Recognizing the promise of hands-on learning approaches, the FDIC’s youth work 

centered on helping banks understand strategies to connect financial education to 

savings accounts. The FDIC’s Youth Banking Network provides opportunities for 66 

banks to learn from one another and FDIC staff on promising strategies to connect 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 47

OTHER ACTIVITIES

financial education to savings accounts for school-aged children. Membership 

in the Network is open to banks interested in community collaborations to help 

school children receive financial education and have the opportunity to open a 

savings account.

Youth Banking Network members participated in periodic learning calls to discuss 

helpful strategies and resources. For example, the April call highlighted practical 

approaches conducting reality fairs, a strategy to help young people understand the 

tradeoffs of money choices that they can expect to experience as they enter adulthood.

The FDIC also engaged Network participants to develop an operational toolkit of 

resources that can support the development of new youth savings collaborations, and 

drafted new resources for the Network based on consultations with members that 

included:

§ Frequently asked questions pertaining to operating youth banking programs,

§ A tip sheet to help banks communicate with parents and caregivers about the 

financial education provided through schools,

§ A tip sheet to help banks communicate with teachers and administrators to help 

secure an agreement to educate students,

§ Strategies bankers can use to make financial education relevant when visiting 

classrooms to talk about money,

§ A guide to reality fairs, and

§ A guide to measuring outcomes of youth savings programs.

These and other resources are provided to participants in the Youth Banking Network 

to strengthen efforts to build and expand collaborations with schools and non-profit 

organizations.

Many youth banking programs provide financial education training based on 

FDIC’s Money Smart for Young People curriculum. To help inform future curriculum 

improvements, the FDIC obtained feedback from 26 educators who taught 83 Money 

Smart for Young People sessions as part of a special project. The participating 

educators overwhelmingly reported that the materials were structured well, were easy 

to use, and initiated critical thinking among students. Still, teachers provided valuable 

suggestions for improvement. These suggestions generally involved including more 

activities, updating the content, and reorganization to facilitate practical usefulness. In 

2018, the FDIC began to revise Money Smart for Young People based on this teacher 

feedback and an assessment using curriculum review tools.
48 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

OTHER ACTIVITIES

Financial Education Outreach 

Highlights of outreach include FDIC collaboration with other members of the federal 

Financial Literacy and Education Commission (FLEC) to share financial education 

resources during Financial Capability Month (April) using the #FinancialFuture2018 

hashtag on social media. FDIC also developed resources on the Be Ready Financially: 

Resources to Help Individuals and Families with Financial Preparedness webinar 

hosted by FLEC with about 200 organizational participants.

The FDIC also collaborated with the U.S. Department of Education and other FLEC 

agencies on the “Financial Education in America’s Schools” program convening on 

April 27, 2018. This event promoted the exchange of ideas among state and local 

leaders and highlighted federal resources that support promising ideas.

In addition, youth employment programs were engaged to encourage Money Smart 

financial education for young workers. For example, FDIC staff met with a Job Corps 

site in Washington, DC to provide technical assistance and later conducted a Money 

Smart train-the-trainer session for 10 staff members, as well as a banker roundtable. 

A brochure was also developed for workforce providers with tips on how to more 

effectively engage financial institutions to provide financial education or deposit 

account opportunities for young people participating in workforce programs. The 

FDIC also partnered with the National Credit Union Administration to engage more 

than 15 cities participating in the America Saves for Young Workers initiative to learn 

challenges and opportunities in connecting young workers to basic deposit accounts 

at insured financial institutions.

Finally, the FDIC released an updated version of Money Smart for Older Adults in 

Spanish (the original curriculum was released in English in 2017) in collaboration 

with the Consumer Financial Protection Bureau. This resource offers information and 

resources to help older adults and their caregivers avoid financial exploitation through 

fraud and scams. 

Money Smart for Small Business 

The FDIC convened forums and roundtables featuring safe small business products 

and services and provided information and technical assistance to support initiatives 

geared to increase access to capital for small businesses. In 2018, the FDIC completed 

74 events and activities primarily focused on small business.

The Small Business Administration, its partner network – including the Small 

Business Development Centers, Women’s Business Centers and SCORE Chapters, 

the Federal Trade Commission and the CFPB were among other stakeholders the 

FDIC collaborated with to produce the revised version of the Money Smart for Small 

Business Credit and Banking Modules. This revision helps entrepreneurs make more 

informed financing decisions. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 49

OTHER ACTIVITIES

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, and other coalitions originated by local and state governments, 

and in collaboration with federal partners and many local and national 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.

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. For example, the FDIC promoted savings 

opportunities for low- and moderate-income people and communities, conducted 

outreach to bring larger numbers of people to free tax preparation assistance 

sites, and coordinated education to help small business owners develop stronger 

banking relationships. 

The FDIC worked across the nation including 16 targeted communities to convene 12 

forums and 19 roundtables that helped 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.

The FDIC sponsored more than 55 events, 80 outreach activities, and 13 speaking 

engagements and exhibitions during 2018. These events provided collaborative 

opportunities to increase access to bank accounts and credit services for people who 

are unbanked and underbanked, as well as small businesses. 
50 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

OTHER ACTIVITIES

Minority Depository Institution Activities

The preservation of minority depository institutions (MDI) remains a high priority for 

the FDIC. In 2018, the FDIC continued to promote and support MDI and Community 

Development Financial Institution (CDFI) industry-led strategies for success. These 

strategies include increasing collaboration between MDI and CDFI bankers and other 

financial institutions; partnering to share costs, raise capital, or pool loans; and 

making innovative use of available federal programs. The FDIC supports this effort 

by providing outreach, education and training, and technical assistance to MDI and 

CDFI banks.

During 2018, the FDIC led discussions with MDI bankers and the MDI Advisory 

Committee on Community Banking (CBAC) about the FDIC’s Resource Guide for 

Collaboration with Minority Depository Institutions. This guide, published in December 

2017, encourages collaboration among MDIs and between MDIs and other institutions. 

The publication describes some of the ways that financial institutions, including 

community banks, can partner with MDIs to the benefit of all institutions involved, 

as well as the communities they serve. Both community banks and larger insured 

financial institutions have valuable incentives under the CRA to undertake ventures 

with MDIs, including capital investment and loan participations. In 2018, the FDIC 

began preparations to host roundtables or other opportunities for MDIs to engage with 

potential collaboration partners in 2019.

The FDIC added additional minority bankers to its CBAC to bring more diverse 

perspectives and input to these discussions. The FDIC began updating its 2014 study, 

“Minority Depository Institutions: Structure, Performance, and Social Impact,” for 

publication in 2019. In support of its statutory goal to preserve the minority character 

in mergers and acquisitions, the agency hosted outreach sessions with MDI bankers 

to provide an overview of the process for bidding on failed minority banks, and to 

offer technical assistance to banks desiring to place a bid on a failed MDI franchise. 

The FDIC also began planning for the 2019 Interagency Minority Depository 

Institution and CDFI Bank Conference, which the FDIC will host in collaboration with 

the OCC and the FRB.

The FDIC continuously pursued efforts to improve communication and interaction 

with MDIs and to respond to the concerns of minority bankers in 2018. 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, 

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.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 51

OTHER ACTIVITIES

The FDIC’s website invites inquiries and provides contact information for any MDI to 

request technical assistance at any time.

In 2018, the FDIC provided 149 individual technical assistance sessions on nearly 50 

risk management and compliance topics, including:

§ Accounting;

§ Bank Secrecy Act and Anti-Money Laundering;

§ Community Reinvestment Act;

§ Funding and liquidity;

§ Information technology risk management and cybersecurity;

§ Third-party oversight; and

§ Troubled debt restructuring.

The FDIC also held outreach, training, and educational programs for MDIs through 

conference calls and regional banker roundtables. In 2018, topics of discussion for 

these sessions included many of those listed above, as well as collaboration and 

partnerships, capital markets, cybersecurity, liquidity risk, and Ombudsman services. 

In addition, the FDIC assisted four MDIs in the early termination of Shared Loss 

Agreements related to the purchase of failed bank franchises during the crisis. 

In 2018, the FDIC’s National Director for Minority and Community Development met 

with the OMWI Director to discuss appropriate collaborative efforts going forward.
52 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

PAGE 

INTENTIONALLY 

LEFT BLANK
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 53

CONCLUSION

During 2018, OMWI continued to make progress in enhancing the diversity of the 

FDIC’s workforce and its 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 percent) and women (44.7 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 220 new MWOBs being added 

to the Contractor Resource List, the internal FDIC database for vendors interested 
54 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

CONCLUSION

in doing business with the FDIC. 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.

The FDIC remained fully engaged and continued 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 

Review Process 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 2018 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 2018 Report to Congress 55

APPENDICES
56 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

APPENDICES

Appendix A

FDIC Contracting Awards to MWOBs, Five–Year Trend (in millions)

2014 2015 2016 2017 2018

Total Awards $686.8 $858.4 $508.8 $523.7 $499.5

100.0% 100.0% 100.0% 100.0% 100%

Minority- Owned or

Women- Owned

Business Totals

$239.9 $211.6 $93.9 $96.7 $122.5

34.9% 24.7% 18.5% 18.5% 24.5%

Minority- Owned $143.7 $145.2 $56.6 $66.7 $45.8

20.9% 16.9% 11.0% 12.7% 9.2%

Women- Owned $132.6 $104.2 $47.4 $46.2 $83.0

19.3% 12.1% 9.3% 8.8% 16.6%

Both Minority- Owned

and Women- Owned

$36.4 $37.8 $10.0 $16.2 $6.3

5.3% 4.3% 1.9% 3.0% 1.3%

Asian American $27.1 $51.8 $25.0 $31.2 $33.9

4.0% 6.0% 4.9% 6.0% 6.8%

Black American $21.3 $30.7 $9.4 $32.7 $1.9

3.1% 3.6% 1.9% 6.2% 0.4%

Hispanic American $66.1 $43.2 $20.6 $1.6 $7.0

9.6% 5.0% 4.0% 0.3% 1.4%

Native American $0.8 $0.0 $0.1 $0.9 $2.9

0.1% 0.0% 0.0% 0.2% 0.6%

Other Minority

$28.4 $19.5 $1.4 $0.3 $0.1

4.1% 2.3% 0.3% 0.0% 0.0%

FDIC Payments to MWOBs, Five–Year Trend (in millions)

2014 2015 2016 2017 2018

Total Contract Payment $491.6 $507.2 $415.2 $414.0 $429.6

100.0% 100.0% 100.0% 100.0% 100.0%

Minority- Owned $89.3 $89.3 $56.0 $54.6 $49.5

18.2% 17.6% 13.5% 13.2% 11.5%

Women- Owned $63.6 $83.2 $66.8 $66.9 $59.5

12.9% 16.4% 16.1% 16.2% 13.9%

Both Minority- Owned

and Women- Owned

$24.7 $30.0 $11.3 $11.9 $11.1

5.0% 5.9% 2.8% 2.9% 2.6%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 57

APPENDICES

Appendix B

FDIC 2018 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

541519

Other Computer Related 

Services $ 139,770,593.30 $ 16,412,115.38 4.3%

541512

Computer Systems Design 

Services $ 50,815,491.65 $ 23,674,716.26 6.2%

511210 Software Publishers $ 41,876,889.19 $ 14,435,080.35 3.8%

518210

Data Processing, Hosting, 

and Related Services $ 41,537,351.68 $ 452,640.92 0.1%

541611

Administrative Management 

and General Management 

Consulting Services $ 23,340,246.80 $ 200,000.00 0.1%

334111

Electronic Computer 

Manufacturing $ 20,380,173.19 $ 3,523,500.11 0.9%

561720 Janitorial Services $ 17,661,424.00 $ 17,661,424.00 4.6%

519130

Internet Publishing and 

Broadcasting and Web 

Search Portals $ 17,011,298.51 $ - 0.0%

541511

Custom Computer 

Programming Services $ 16,539,815.67 $ 12,077,240.74 3.2%

541612

Human Resources Consulting 

Services $ 14,301,968.40 $ 14,301,968.40 3.7%

Total $ 383,235,252.39 $ 102,738,686.16 26.8%
58 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

APPENDICES

Appendix C

FDIC Total, Permanent, and Executive Manager Workforce, 

Five-Year Trend

Total Workforce (Permanent and Non-Permanent)

2014 2015 2016 2017 2018 Change

Minority 28.1% 28.2% 28.0% 28.7% 29.8% +1.1%

Non-Minority 71.9% 71.8% 72.0% 71.3% 70.2% -1.1%

Men 55.5% 55.3% 55.2% 55.2% 55.2% 0%

Women 44.5% 44.7% 44.8% 44.8% 44.8% 0%

Permanent Workforce

2014 2015 2016 2017 2018 Change

Minority 27.6% 28.0% 28.2% 29.0% 29.9% +0.9%

Non-Minority 72.4% 72.0% 71.8% 71.0% 70.1% -0.9%

Men 55.0% 54.8% 54.9% 55.1% 55.3% +0.2%

Women 45.0% 45.2% 45.1% 44.9% 44.7% -0.2%

Total Workforce - Executive Manager (Permanent and Non-Permanent)

2014 2015 2016 2017 2018 Change

Minority 14.1% 18.0% 18.8% 18.3% 17.6% -0.7%

Non-Minority 85.9% 82.0% 81.2% 81.7% 82.4% +0.7%

Men 64.1% 66.9% 63.2% 61.1% 64.0% +2.9%

Women 35.9% 33.1% 36.8% 38.9% 36.0% -2.9%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 59

APPENDICES

Appendix D

2018 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)

# 81 25 56 0 3 15 46 3 2 7 5 0 0 0 0

% 100.0% 30.9% 69.1% 0.0% 3.7% 18.5% 56.8% 3.7% 2.5% 8.6% 6.2% 0.0% 0.0% 0.0% 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)

# 166 76 90 2 3 30 67 36 13 7 6 1 0 0 1

% 100.0% 45.8% 54.2% 1.2% 1.8% 18.1% 40.4% 21.7% 7.8% 4.2% 3.6% 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) 

# 89 48 41 0 0 22 31 18 6 8 2 0 0 0 2

% 100.0% 53.9% 46.1% 0.0% 0.0% 24.7% 34.8% 20.2% 6.7% 9.0% 2.2% 0.0% 0.0% 0.0% 2.2%

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) 

# 2743 1064 1679 40 69 778 1,424 170 103 53 52 6 11 17 20

% 100.0% 38.8% 61.2% 1.5% 2.5% 28.4% 51.9% 6.2% 3.8% 1.9% 1.9% 0.2% 0.4% 0.6% 0.7%

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) 

# 328 139 189 2 7 110 164 16 10 10 4 1 1 0 3

% 100.0% 42.4% 57.6% 0.6% 2.1% 33.5% 50.0% 4.9% 3.0% 3.0% 1.2% 0.3% 0.3% 0.0% 0.9%

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)

# 279 93 186 2 9 64 143 19 15 7 14 0 1 1 4

% 100.0% 33.3% 66.7% 0.7% 3.2% 22.9% 51.3% 6.8% 5.4% 2.5% 5.0% 0.0% 0.4% 0.4% 1.4%

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%
60 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

PAGE 

INTENTIONALLY 

LEFT BLANK
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress 61

PAGE 

INTENTIONALLY 

LEFT BLANK
62 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2018 Report to Congress

PAGE 

INTENTIONALLY 

LEFT BLANK

FDIC-018-2019