2016

Section 342 Dodd-Frank Wall Street 

Reform and Consumer Protection Act

REPORT TO CONGRESS

FEDERAL DEPOSIT INSURANCE CORPORATION 

Office of Minority and Women Inclusion

Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress i

Table of Contents

Introduction 3

FDIC Contracting: 

Inclusion of Minority- and Women-Owned Businesses (MWOBs) 7

Employment at the FDIC: 

Increasing Representation of Minorities and Women 21

Other Activities 30

Conclusion 38

Appendices 39
ii Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 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 2016 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, as well as other relevant information, including the agency’s 

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 2016 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. In 1999, the 

FDIC published its first Diversity Strategic Plan, which outlined its commitment 

to recruiting and retaining the most qualified, talented, and motivated employees 

in the labor market. 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.

In 2012, the FDIC Chairman established performance goals to update the Diversity 

Strategic Plan and asked each division and major office to develop strategic plans 

that identify steps to promote increased diversity through the FDIC’s recruiting 

and hiring processes. Since 2013, the FDIC has annually updated the Diversity 

and Inclusion Strategic Plan to ensure the plan remains current and relevant. The 

Diversity and Inclusion Strategic Plan was updated in 2016 to continue the FDIC’s 

efforts in this important area and to address the FDIC’s goals to develop and 

implement a more comprehensive, integrated, and strategic focus on diversity and 

inclusion. The 2016 Diversity and Inclusion Strategic Plan was disseminated to the 

FDIC workforce and posted externally to the public on www.fdic.gov.

The 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 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. 

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

an OMWI Steering Committee to ensure and promote coordination of OMWI 

programs. In 2013, the OMWI Steering Committee was renamed the FDIC Diversity 

and Inclusion Executive Advisory Council (EAC). The EAC is chaired by the FDIC 

Deputy to the Chairman and Chief Operating Officer/Chief of Staff and includes the 

OMWI Director, the OMWI Senior Deputy 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 EAC also reviews the Diversity and 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 3

INTRODUCTION

Inclusion Strategic Plan annually, and updates it as needed to refine the agency’s 

efforts in promoting diversity and inclusion on an ongoing basis.

2016 Diversity and Inclusion Initiatives

Annually, the FDIC Chairman issues a number of performance goals designed to 

further promote diversity, inclusion, and equal employment opportunity at the 

agency. One of these goals required the agency’s division and major office directors to 

develop customized strategic plans for their organizations to identify steps to promote 

increased diversity throughout the FDIC. Again in 2016, each division and major office 

assessed available workforce data and produced 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 July 2016, the progress made by divisions and major offices was reported 

and discussed at the monthly EAC meeting. This process keeps the division and major 

offices engaged in the FDIC’s diversity and inclusion efforts and will continue in 2017. 

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 revised in late 2016 and was 

disseminated to the FDIC workforce and posted on the FDIC website in early 2017. The 

2017 Diversity and Inclusion Strategic Plan includes updated strategies to continue the 

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

and active participants in carrying out the FDIC’s mission.

In recognition of the FDIC’s 2016 diversity and inclusion progress, the following 

initiatives are highlighted: 

§ The FDIC supported the establishment of an additional Employee Resource Group, 

the Veterans Employee Resource Group (VERG), and continued to support, and 

encouraged collaboration with the four existing ERGs: Emerging Leaders; Hispanic 

Organization for Leadership and Advancement; PRIDE; and Partnership of Women in 

the Workplace.

§ OMWI and the FDIC’s Corporate University explored opportunities to provide 

diversity and inclusion training for employees in an online environment. OMWI 

continued administering manager and supervisor training on equal employment 

opportunity and diversity and inclusion, No FEAR Act training, and webinars on 

anti-harassment and non-discrimination in employment policies and procedures.
4 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

INTRODUCTION

§ The FDIC completed the implementation of the recommendations from the Office 

of Inspector General’s Review of the FDIC’s Efforts to Promote Equal Opportunity 

and Achieve Senior Management Diversity. The following improvements were 

implemented:

 Formalized recruitment strategy;

 Developed metrics to measure recruitment success;

 Developed process to track and report on leadership training programs 

participation by race, gender and national origin;

 Developed a policy and procedures for “Expressions of Interest (EOI)” programs; 

and,

 Developed a process to track EOI participation by race, gender, and national 

origin.

§ The FDIC implemented innovative procurement strategies on several contracts to 

foster increased minority- and women-owned business participation in contracting 

opportunities.

§ Through focused outreach, internal and external training, and related initiatives, the 

FDIC Legal Division increased the percentage of minority- and women-owned law 

firm referrals and payments for agency legal matters.

§ The FDIC’s Workplace Excellence (WE) program, composed of a national WE 

Steering Committee and division/office WE Councils, continued the focus on 

maintaining, enhancing and institutionalizing a positive workplace environment 

throughout the agency. OMWI worked closely with WE to develop and provide 

recommendations related to fairness, diversity and inclusion, to include:

Conducting and presenting a preliminary analysis of Federal Employee Viewpoint 

Survey results and trends delineated by FDIC dimension and minority, gender, 

ethnicity, and disability status; and,

 Forming a joint Fairness, Diversity and Inclusion Working Group composed of 

WE Steering Committee, Council, and Chairman’s Diversity Advisory Council 

members to further evaluate available information in an effort to better 

understand how employees in different demographic groups view the FDIC 

workplace.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 5

INTRODUCTION

§ The FDIC continued to develop and implement the Workforce Development 

Initiative (WDI) designed to address comprehensive succession planning needs and 

workforce development challenges and opportunities, and to develop future FDIC 

leaders. As a part of the initiative, OMWI:

Continued to track succession planning review results by race, ethnicity, and 

gender and provide the results to WDI program management;

Provided guidance as needed about potential diversity and inclusion issues in 

other WDI programs e.g., career paths, external details, learning, development 

and training, leadership mentoring, administrative career paths; manager 

rotations, and onboarding; and, 

Participated in efforts to research opportunities to make better use of social 

media resources, particularly LinkedIn, in corporate recruiting outreach efforts to 

attract applicants from diverse backgrounds.
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Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 7

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 2016, 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 2016 contracting activities and successes; contracting initiatives, programs, 

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

contracting activities. 
8 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

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

Contracting Activities and Successes 

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 that includes 

registered MWOBs. OMWI also identifies qualified MWOBs through the System for 

Award Management and the Minority Business Development Agency. This process 

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

major contract.

The FDIC’s website1 provides 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 selfassessment for businesses interested in competing for contract opportunities.

Contract Payments to MWOBs

The FDIC paid $415.2 million to contractors in 2016 under 1,786 contracts, of which 

$111.5 million (26.8 percent) was paid to MWOBs under 461 contracts. [See Figure 

1.] By comparison, the FDIC paid $507.2 million to contractors under 2,029 contracts 

in 2015; $491.6 million to contractors under 1,962 contracts in 2014; $553.7 million to 

contractors under 1,982 contracts in 2013; and $660.0 million to contractors under 

577 contracts in 2012. The 2016 total payments (i.e., spend) to contractors included 

payments for contracts awarded in 2016 and payments for active contracts awarded 

prior to 2016. 

1 See www.fdic.gov/mwop

2 See www.fdic.gov/about/diversity/sbrp/index.html. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 9

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

Figure 1 Contracting Payments (in millions)

2012 2013 2014 2015 2016

Total $660.0 $553.7 $491.6 $507.2 $415.2

100% 100% 100% 100% 100%

MWOB $161.4 $140.6 $128.2 $142.5 $111.5

24.5% 25.4% 26.1% 28.1% 26.8%

Minority Owned (MO) $117.7 $102.9 $89.3 $89.3 $56.0

17.8% 18.6% 18.2% 17.6% 13.5%

Women Owned (WO) $70.1 $63.7 $63.6 $83.2 $66.8

10.6% 11.5% 12.9% 16.4% 16.1%

Overlap (Both MO & WO) $26.4 $26.0 $24.7 $30.0 $11.3

4.0% 4.7% 5.0% 5.9% 2.8%

Asian American $51.3 $50.3 $38.5 $39.9 $33.5

7.8% 9.1% 7.9% 7.9% 8.1%

Black American $35.7 $19.8 $15.9 $13.3 $11.5

5.4% 3.6% 3.2% 2.6% 2.8%

Hispanic American $28.7 $26.0 $26.7 $25.1 $10.3

4.3% 4.7% 5.4% 5.0% 2.5%

Native American $2.0 $1.2 $0.3 $0.1 $0.1

0.3% 0.2% 0.1% 0.0% 0.0%

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

one in which payments were made or credits applied in 2016. In 2016, minority-owned 

firms were paid $56 million of the total dollars paid to contractors (13.5 percent). 

Women-owned firms were paid $66.8 million of the total dollars paid to contractors 

(16.1 percent). These two categories – minorities and women – are not mutually 

exclusive since $11.3 million (2.8 percent) was paid in 2016 to businesses classified as 

both minority-owned and women-owned. By contrast, the FDIC paid MWOBs $142.5 

million (28.1 percent) of the total paid to all contractors in 2015 under 591 contracts; 

$128.2 million (26.1 percent) to MWOBs in 2014 under 533 contracts; $140.6 million 

(25.4 percent) to MWOBs in 2013 under 608 contracts; and $161.4 million (24.5 percent) 

to MWOBs in 2012 under 754 contracts.
10 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

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

In 2016, the FDIC awarded 287 contracts to MWOBs out of a total of 1,181 issued (24.3 

percent). [See Figure 2.] By comparison, the FDIC awarded 346 contracts (29.9 percent) 

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

MWOBs out of a total of 1,072 issued in 2014; 282 contracts (28.3 percent) to MWOBs

out of a total of 995 issued in 2013; and 388 contracts (29.3 percent) out of a total of 

1,326 issued in 2012.

Figure 2 Contracting Actions

2012 2013 2014 2015 2016

Total 1326 995 1072 1159 1181

100% 100% 100% 100% 100%

MWOB 388 282 288 346 287

29.3% 28.3% 26.9% 29.9% 24.3%

Minority Owned (MO) 262 161 170 148 142

19.8% 16.2% 15.9% 12.8% 12.0%

Women Owned (WO) 192 162 167 243 187

14.5% 16.3% 15.6% 21.0% 15.8%

Overlap (Both MO & WO) 66 41 49 45 42

5.0% 4.1% 4.6% 3.9% 3.5%

Asian American 50 39 54 56 62

3.8% 3.9% 5.1% 4.8% 5.2%

Black American 104 50 45 35 24

7.8% 5.0% 4.2% 3.0% 2.0%

Hispanic American 87 61 59 39 48

6.6% 6.2% 5.5% 3.4% 4.1%

Native American 18 0 2 1 2

1.4% 0.0% 0.2% 0.1% 0.2%

Other 3 11 10 17 6

0.2% 1.1% 0.9% 1.5% 0.5%

As of December 31, 2016, the FDIC had 302 (17.3 percent) active contracts with MWOBs 

out of a total of 1,745 active contracts. The active contracts to MWOB firms by category 

were as follows: Asian American (92), Black American (51), Hispanic American (28), 

Native American (2), and Women (169). These include contracts awarded to firms that 

were both minority-owned and women-owned.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 11

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

Contract Awards to MWOBs

The FDIC awarded contracts with a combined value of $508.8 million in 2016, of 

which $93.9 million (18.5 percent) were awarded to MWOBs. By comparison, the 

FDIC awarded contracts with a combined value of $858.4 million in 2016, with $211.6 

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

of $686.8 million in 2014, with $239.9 million (34.9 percent) awarded to MWOBs; 

awarded contracts with a combined value of $572.8 million in 2013, with $198.7 

million (34.7 percent) awarded to MWOBs; and awarded contracts with a combined 

value of $1,041.7 billion in 2012, with $308.0 million (29.6 percent) awarded to 

MWOBs. [See Figure 3.]

Figure 3 Total Contract Dollar Awards

2012 2013 2014 2015 2016

Total $1,041.7 $572.8 $686.8 $858.4 $508.8

100% 100% 100% 100% 100%

MWOB $308.0 $198.7 $239.9 $211.6 $93.9

29.6% 34.7% 34.9% 24.7% 18.5%

Minority Owned (MO) $261.1 $158.5 $143.7 $145.2 $56.5

25.1% 27.7% 20.9% 16.9% 11.1%

Women Owned (WO) $90.7 $66.1 $132.6 $104.2 $47.4

8.7% 11.5% 19.3% 12.1% 9.3%

Overlap (Both MO & WO) $43.8 $25.9 $36.4 $37.8 $10.0

4.2% 4.5% 5.3% 4.3% 1.9%

Asian American $92.6 $38.0 $27.1 $51.8 $25.0

8.9% 6.7% 4.0% 6.0% 4.9%

Black American $105.6 $32.2 $21.3 $30.7 $9.4

10.1% 5.6% 3.1% 3.6% 1.9%

Hispanic American $50.0 $85.3 $66.1 $43.2 $20.6

4.8% 14.9% 9.6% 5.0% 4.0%

Native American $9.3 $ - $ 0.8 $ - $0.1

0.9% 0.0% 0.1% 0.0% 0.0%

Other $3.6 $3.0 $28.4 $19.5 $1.4

0.4% 0.5% 4.1% 2.3% 0.3%

The FDIC’s five-year trend from 2012-2016 of contract awards and payments can be 

found at Appendix A.
12 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

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

Contract Awards by North American Industry Classification System

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

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

statistical agencies in classifying business establishments for the purpose of 

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

economy. The FDIC awarded contracts in 2016 under 85 different NAICS codes. 

Figure 4 depicts the distribution of the FDIC’s 2016 contracts categorized for the top 

ten NAICS codes.

Figure 4 FDIC 2016 Contracts by Top Ten NAICS Codes

Computer Systems Design 

Services

541512

5%

Residential Property Managers

531311 

11%

Custom Computer Programming 

Services

541511 

7%

Administrative Management and 

General Management Consulting 

Services

541611

20%

Computer and Computer Peripheral 

Equipment and Software Merchant 

Wholesalers

423430 

7%

Ofces of Real Estate Appraisers

531320

 7%

Other Computer Related Services

541519 

29%

Other Warehousing and Storage

493190 

5%

Ofce Administrative Services

561110 

4%

Temporary Help Services

561320 

5%

In 2016, these awards consisted of the following: 29 percent for other computerrelated services; 20 percent for administrative management and general management 

consulting services; and 11 percent for residential property managers. The remaining 

40 percent – each seven percent or under – were awarded in the areas of real estate 

appraisers (seven percent); computer and computer peripheral equipment and 

software merchant wholesalers (seven percent); custom computer programming 

services (seven percent); computer systems design services (five percent); temporary 

help services (five percent); other warehousing and storage (five percent); and office 

administrative services (four percent). Collectively, 19 percent of the top ten NAICS 

code contracts were awarded to MWOBs. [See Figure 5.]
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 13

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

Figure 5 2016 Contract Awards by Top 10 NAICS Codes

Non-MWOB

81% 

MWOB

19% 

The 2016 FDIC contract awards associated with the top ten NAICS codes can be 

found in Appendix B.

Referrals to Law Firms

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

capacity, and status are among the criteria considered in making the selections. The 

FDIC made 342 referrals to outside counsel in 2016, of which 151 (44.2 percent) were 

minority- and women-owned law firms (MWOLFs), compared to a total of 600 referrals, 

of which 244 (40.7 percent) were to MWOLFs in 2015. Referrals to MWOLFs in 2016, by 

category, were as follows: Black American – 6 (2.0 percent), Hispanic American – 107 

(31 percent), Native American – 1 (<1 percent), Asian American – 2 (1 percent), and 

Women – 35 (10 percent). [See Figure 6.]

Figure 6 2016 Referrals

Hispanic American

31%

Women

10%

Non-MWOLF

41% 

Non-Reported

15%

Asian American

1%

Black American

2% 
14 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

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

The FDIC paid $76.8 million to outside counsel in 2016, as compared to $98.4 million in 

2015. [See Figure 7.] The FDIC paid $11.1 million to MWOLFs in 2016, which represents 

14.5 percent of the total paid to all law firms. This percentage exceeds 2015, during 

which the FDIC paid a total of $11.7 million to MWOLFs, which was 11.9 percent of the 

total paid to all law firms that year. 

Figure 7 Payments to Law Firms (Dollars in Millions)

15.3 16.5 15.3 11.7 11.1 

102.0 

113.8 105.6 

86.7 

65.7 

0

20

40

60

80

100

120

140

2012 2013 2014 2015 2016

117.3

130.3

98.4

76.8

120.9

MWOLFs Non-MWOLFs

As noted above, there has been a decline in referrals to outside counsel in 2016. 

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

decreased from 2015 to 2016. Furthermore, as shown in Figure 7, payments to 

MWOLFs decreased from $11.7 million in 2015 to $11.1 million in 2016. This decrease is 

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

levels in 2013. 

The FDIC remains committed to seeking ways to increase the level of referrals to 

MWOLFs in 2017. 

Outreach to MWOLFs 

Anticipating a decline in legal referrals in 2016, the Legal Division tailored its outreach 

strategy to focus on the substantive areas of the FDIC’s legal work that posed the 

greatest opportunities for MWOLF participation. The Legal Division continued to work 

closely with in-house attorneys in areas that account for a substantial dollar amount 

of legal referrals (e.g., professional liability and financial crimes). The Legal Division 

continued to emphasize the importance of diverse staffing. For example, in response 

to the needs of the Legal Division’s Professional Liability and Financial Crimes Section, 

the Legal Division is developing a user-friendly searchable database highlighting 

available minority- and women-owned legal support firms such as expert witnesses 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 15

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

and court reporters. Given the decline in bank failures, the Legal Division anticipates 

performing more work in-house, which will require legal support. To assist in that 

effort, the Legal Division anticipates awarding litigation support contracts to minorityand women-owned legal support firms. The Legal Division worked on a new program 

to enhance the MWOLF program spend figures by capturing the fees paid by larger 

firms and FDIC loan servicers that use MWOLFs as subcontractors. 

In addition to attending five bar association conferences during 2016, Legal Division 

staff attended three stakeholder events sponsored by the National Association of 

Minority and Women Owned Law Firms (NAMWOLF). During these networking 

events, the Legal Division counseled MWOLFs on how those firms can make strategic 

decisions in their pursuit of FDIC legal work, as well as work with other large corporate 

clients. It is also noteworthy that the FDIC redesigned and increased its advertising 

space in the organization’s annual diversity and inclusion magazine. 

The Legal Division evaluated and approved 12 new MWOLF applications in 2016. 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, the Legal Division 

continued a compliance review program developed in 2012 to assess internal 

diversity of majority law firms and MWOLFs comprising the FDIC’s “top ten” annual 

spending firms. This program provides the Legal Division another means to address 

diversity and inclusion and provides opportunities for women and minority attorneys 

seeking to provide services. These on-site visits are designed to engage firms in 

discussions about best practices, diversity staffing concepts, metrics and the FDIC’s 

MWOLF program. The results continue to be positive. The FDIC collected baseline 

diversity metrics, reviewed best practices on staffing of client matters, and reached a 

commitment with various firms to increase diversity concerning FDIC activities.

Contracting Initiatives, Programs and Outreach

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

financial institutions represented up to 85 percent of all FDIC contract dollars 

awarded in a given year. Due to the continued decline in the number of failed financial 

institutions, only 44 percent of FDIC total contract dollars awarded in 2016 supported 

the FDIC’s Division of Resolutions and Receiverships (DRR) whose primary mission is 

to resolve failed financial institutions. As a result, the FDIC continued to focus efforts 

in 2016 on identifying opportunities for MWOBs in non-financial recurring services. 

For example, contracts were awarded to MWOBs in the following areas: IT software 

development, maintenance and shared services; IT hardware and software licenses; 

IT security; IT consulting services; printing services; receptionist services; human 

resources program services; risk-modeling services; interpreting services; facilities 

management services; and training.
16 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

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

In addition, several of the contracts used to perform failed bank resolution services 

during the financial crisis expired in 2016. Although the number of bank failures has 

declined significantly, the FDIC re-bid these expiring contracts to ensure contractor 

resources are in place to provide assistance for future bank failures. MWOB 

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

result, the FDIC focused on ensuring continued MWOB participation in the rebidding of 

expiring contracts. MWOB firms were awarded new contracts in 2016 for receivership 

management support services, information security support services, business 

improvement support services, and pre-closing and post-closing resolution support 

services. Additional existing failed bank resolution contracts will expire in 2017 and 

beyond. The FDIC will continue to look for opportunities to include MWOBs in the recompetition of these mission critical services. 

The FDIC continued to develop procurement strategies for major solicitations at 

monthly EAC meetings attended by senior managers from FDIC divisions and offices, 

and at the FDIC’s Executive Management Committee meetings. Lastly, the FDIC 

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.

The FDIC continued its voluntary usage of the Small Business Administration’s 8(a) 

program which is designed to help small and disadvantaged businesses compete in 

the marketplace and gain access to federal and private procurement markets. In 2016, 

the FDIC awarded two contracts to MWOBs with a combined value of $1,345,200 

under the 8(a) program. One will assist the FDIC in developing a new IT continuity of 

operations strategy. The other is for the installation of two distribution units at the 

FDIC’s Data Center. 

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. This focused market research led 

to six MWOB firms being awarded an ITAS II BOA out of 11 total firms awarded the 

BOA (55 percent). The six BOA awards to MWOBs represented a significant increase 

in MWOB awards from the ITAS I BOA where only one MWOB firm was awarded the 

BOA out of four total firms (25 percent). In 2016, the FDIC conducted a competition to 

add additional firms to the ITAS II BOA to increase the number of vendors under the 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 17

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

contract. Once again, significant market research was conducted to ensure MWOB 

participation in the competitive process. The end result was three additional firms 

were added to the ITAS II BOA with two of the firms being MWOB firms. This increased 

the total number of firms under the ITAS II BOA from 11 to 14 and the total number of 

MWOB firms under the ITAS II BOA from six to eight. As a result, the percentage of 

MWOB firms under the BOA increased from 55 to 57 percent.

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. A significant number of multi-year task order awards were made under ITAS II 

between 2013 and 2015 resulting in fewer requirements for new task orders in 2016. 

However, 12 of the 17 task orders in 2016 under the ITAS II BOA were awarded to 

MWOB firms with a combined value of $11.2 million. This represented 71 percent of 

the total task orders awarded and 77 percent of the total dollars awarded under ITAS II 

during 2016. 

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

program. The FDIC awarded in 2016, four new contracts with a combined value of $1.2 

million to MWOBs to provide: (1) secure web authentication services; (2) open FISMA 

operations and support services; (3) automated loan examination tool services; and (4) 

strategic communications support.

The FDIC is also in the process of evaluating the move of some IT services to cloud 

technology services. A contract valued at $443,999 was awarded to an MWOB to 

provide support to move some FDIC IT services to cloud technology services. 

Additionally, the FDIC is reassessing its current IT continuity of operations strategy. 

One contract with a value of $1.2 million was awarded to an MWOB firm to assist with 

this assessment by providing technical inventory planning and organizational change 

management 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 87 contract awards to 

MWOBs with a combined value of $14.1 million.

Facilities Management

Significant awards to MWOBs in facilities management included contracts valued at 

$145,200 for power distribution for the FDIC Data Center; $61,519 for lighting design 

at the FDIC’s San Francisco Regional Office location; and $3.4 million for commercial 

printing services. 
18 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

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

In addition, the FDIC continued to provide opportunities to MWOBs for replacement 

furniture. In total, seven contracts with a combined value of $649,577 were awarded to 

MWOBs to provide furniture for multiple FDIC locations nationwide.

Human Resources Management

Three contracts were awarded to MWOBs in 2016 in the human resources 

management area. The FDIC strategically removed receptionist services from the 

existing administrative support services contract after determining these services 

represented more than 10 percent of the value of the contract and could be provided 

by MWOB firms. This strategy change resulted in a new competitive contract for 

receptionist services that was awarded to an MWOB with a value of $1.8 million. Also a 

contract valued at $900,000 was awarded to an MWOB to support the evaluation of an 

FDIC human resources program. Lastly, a contract valued at $80,984 was awarded to 

an MWOB firm to provide employee mentoring support services.

Bank Resolution Contracts

There were only five financial institution failures in 2016, continuing the decline in 

annual bank failures and far below the height of the financial crisis in 2010 when 

there were 157 financial institution failures. However, there are still hundreds of 

active failed bank receiverships from prior year failures. The FDIC continued to 

award contracts to MWOBs to provide the required services to resolve 2016 financial 

institution failures and prior year financial institution failures. In 2016, 152 contracts 

with a combined value of $54 million were awarded to MWOBs to provide the 

required financial services to assist the FDIC in resolving failed financial institutions. 

Contracts awarded to MWOBs related to the resolution of failed financial institutions 

included, but were not limited to, owned real estate management and disposition 

services, accounting services, IT development and reporting services, information 

security support services, receivership assistance services, loss share agreement 

services, asset valuation services, appraisal management services, underwriting 

services, temporary staffing services, internet marketing and disposition of loan 

assets services, environmental support services, furniture/fixtures and equipment 

services, tax return preparation services, oil and gas services, and translation/

transcreation/ interpreter services.

Other Significant MWOB Contract Awards

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

resolutions, information technology, human resources and facilities management, 

the FDIC looked for MWOB opportunities in other program areas. The FDIC’s 

Corporate University awarded eight contracts with a combined value of over 

$2 million to MWOB firms to provide training to FDIC employees on a variety of 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 19

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

subjects. The FDIC’s Division of Depositor and Consumer Protection (DCP) awarded 

a contract with a value of $80,000 to an MWOB to provide Money Smart training 

services. The Office of Corporate Risk Management awarded a contract with a 

value of $1 million to an MWOB firm to provide risk modeling services. Lastly, 

OMWI awarded a contract to an MWOB with a value of $900,000 for sign language 

interpreter/transcribing services. 

Outreach to MWOBs 

In 2016, the FDIC participated in a combined total of 38 business expos, one-on-one 

matchmaking sessions, and panel presentations. At these 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, MWO 

investors, and MWOLFs, these efforts also targeted veteran-owned and small 

disadvantaged businesses. Vendors were also encouraged to register through the 

FDIC’s Contractor Resource List (the principal database for vendors interested in doing 

business with the FDIC).

FDIC Asset Sales

During 2016, OMWI and DRR collaborated to present three FDIC-sponsored asset 

purchaser workshops that were marketed extensively to minority- and women-owned 

investors and companies interested in learning about DRR’s sales processes. DRR 

speakers with strong backgrounds in their respective programs provided details on the 

various tools used by DRR to market assets and presented information to attendees on 

how to participate in the transactions and bid on assets offered for sale. Also, OMWI 

staff presented sessions on Doing Business with the FDIC.

Asset purchaser workshops were held in San Juan, Puerto Rico and in Memphis 

and Jackson, Tennessee. The events were attended by 76 prospective investors and 

included a special focus on owned real estate investment opportunities to support 

a DRR auction of real estate properties scheduled after the outreach workshop. A 

segment regarding contracting services was also part of the event. In addition, in May 

2016, OMWI and DRR held a workshop in San Juan in support of an owned real estate 

auction. The workshop and subsequent auction attracted more than 160 participants 

and all available properties were sold in the auction.

Following the failure of a financial institution in Memphis, additional asset purchaser 

workshops were held in July 2016. Two sessions were held to target local purchasers 

in Jackson where most of the properties were located. The events focused on the 

owned real estate portfolio acquired in the financial institution’s resolution, which 

consisted primarily of affordable single family homes.
20 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

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

Challenges 

As noted, the FDIC’s annual new contract awards have declined significantly since 

the height of the financial crisis due to the reduction in financial institution failures. 

The total value of FDIC’s 2016 contract awards of $508.8 million was significantly less 

than the $858.4 million contract award value for 2015. This continued the downward 

trend in contract award values since the height of the financial crisis when awards 

peaked at $2.6 billion in 2009 and 2010. Non-financial goods and services contracts for 

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

annual contract awards. In years when there are few bank failures, these non-financial 

recurring goods and services will represent the majority of FDIC contract awards. 

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

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

of these services, there are significant administrative advantages to having 

fewer contractors provide these services to ensure consistent implementation of 

FDIC programs nationwide. 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. As described above, a new procurement 

strategy was developed for receptionist services which resulted in a $1.8 million 

award to an MWOB firm. Also, contracts to assist in moving IT services to the cloud 

and to develop a new continuity of operations strategy, were awarded to MWOB IT 

contractors. These are examples of the types of procurement strategies the FDIC 

will continue to consider for future new contracts, when feasible. Despite the decline 

in the overall contract dollars, the FDIC through its aggressive outreach program 

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

contracting opportunities. In 2016, OMWI initiated a study of MWOB participation in 

FDIC contracting opportunities. The results of the study will help provide information 

on where additional technical assistance could be provided to MWOBs to increase 

their ability to compete in the future.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 21

EMPLOYMENT AT THE FDIC: 

Increasing Representation of 

Minorities and Women 

The FDIC is strongly committed to diversity and inclusion at all levels of the agency’s 

workforce. The following sections provide information on the agency’s diversity in 

employment and hiring, initiatives to promote diversity in employment, and challenges 

the agency faces in promoting diversity in employment and hiring.

Diversity in Employment and Hiring

As of December 31, 2016, minorities accounted for 28.0 percent (1,771) of the FDIC’s 

total workforce (permanent and non-permanent) of 6,322 employees, and women 

accounted for 44.8 percent (2,831). [See Figure 8.] More specifically, the representation 

percentages in the total workforce for various minority groups at the end of December 

2016 were as follows: 1.2 percent for people of two or more races, 0.6 percent 

American Indian and Alaska Native (AIAN), 5.1 percent Asian American, 17.4 percent 

Black American, and 3.8 percent Hispanic American. 
22 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

EMPLOYMENT AT THE FDIC : Increasing Representation of Minorities and Women

Figure 8 Diversity in Total (Permanent and Non-Permanent) Employment as of 

12/31/2016

Minority Non-Minority Total

Number 1771 4551 6322

Percent 28.0 72.0 100%

Men Women Total

Number 3491 2831 6322

Percent 55.2 44.8 100%

2 or More AIAN Asian Black Hispanic White Total

Number 76 36 321 1099 239 4551 6322

Percent 1.2 0.6 5.1 17.4 3.8 72.0 100%

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

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

the FDIC’s permanent workforce as of July 31, 2010, and 28.2 percent as of December 

31, 2016. The percentage of women in the FDIC’s permanent workforce was 43.6 

percent as of July 31, 2010, and 45.1 percent as of December 31, 2016. [See Appendix C.]

As of December 31, 2016, minorities accounted for 18.8 percent (25) of the FDIC’s total 

Executive Manager (EM) workforce of 133 employees, and women accounted for 36.8 

percent (49). [See Figure 9.]

Figure 9 Diversity in Total (Permanent and Non-Permanent) Employment – 

Executive Manager Workforce as of 12/31/2016

Minority Non-Minority Total

Number 25 108 133

Percent 18.8 81.2 100%

Men Women Total

Number 84 49 133

Percent 63.2 36.8 100%

2 or More AIAN Asian Black Hispanic White Total

Number 0 1 2 18 4 108 133

Percent 0 0.8 1.5 13.5 3.0 81.2 100%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 23

EMPLOYMENT AT THE FDIC : Increasing Representation of Minorities and Women

Of the FDIC’s permanent EM workforce, minorities accounted for 15.4 percent as of 

July 31, 2010, and 18.2 percent as of December 31, 2016. The percentage of women 

in the FDIC’s permanent EM workforce was 25.0 percent as of July 31, 2010, and 36.4 

percent as of December 31, 2016. The racial, ethnic and gender diversity of the EM 

workforce overall has increased since the passage of DFA section 342.

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

workforce for 2012 through 2016.

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 all segments of society. The recruitment of examiners, the 

FDIC’s largest occupational group, is conducted primarily through the FDIC’s Corporate 

Employee Program (CEP). The CEP recruits and trains the FDIC’s workforce of Financial 

Institution Specialists (FISs), beginning examiners-in-training, in many areas. 

To help with recruitment throughout 2016, 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 from the inception of 

the CEP in 2005, several racial, ethnic and gender groups, as well as employees with 

disabilities, had very low representation rates in the FDIC’s examiner workforce. To 

help address these issues, the FDIC has engaged in a proactive recruitment effort 

and used recruiting strategies that have been successful in addressing the initially 

low representation rates of many 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 38.2 

percent as of December 31, 2016. In addition, the percentages of Black American men 

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

Indian and Alaska Native women, 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 women and 

Asian American men and women, and women of two or more races in the FDIC’s 

examiner workforce remain low.

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

in the Civilian Labor Force (CLF) for American Indian and Alaska Native men and 

women, Black American men and women, and men of two or more races, but lower 
24 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

EMPLOYMENT AT THE FDIC : Increasing Representation of Minorities and Women

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

women, White women, and women of two or more races. The overall minority hiring 

rate since the inception of the CEP has been 27.9 percent, compared to the CLF of 27.7 

percent; and the overall hiring rate for women is 38.0 percent, compared to the CLF of 

45.3 percent. [See Figure 10.]

Figure 10 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 11 15 4 11 29 52 159 110 30 43 399 802 1665

% 0.7 0.9 0.2 0.7 1.7 3.1 9.5 6.6 1.8 2.6 24.0 48.2 100%

CLF 1 0.6 0.2 0.1 3.7 3.5 8.4 3.4 3.7 3.1 28.3 44.1 100%

During 2016, the CEP hiring rates were above the CLF percentages for American Indian 

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

races, and were below the CLF for Asian American men and women, Black American 

women, and Hispanic American men and women. The hiring rates of Black American 

women and White women were positive and just slightly below the CLF. Additional 

targeted recruitment is needed to reach Hispanic American women, Asian American 

men and women, and American Indian and Native Alaska men. [See Figure 11.] The 

overall hiring rate in 2016 for minorities and women has been positive with both 

groups having little statistical disparity from the CLF.

Figure 11 CEP Hires in 2016 (Classes 53 – 57)

2 or More AIAN Asian Black Hispanic White Total

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

CEP 2 1 2 0 2 2 12 6 0 3 41 75 146

% 1.4 0.7 1.4 0 1.4 1.4 8.2 4.1 0.0 2.1 28.1 51.4 100%

CLF 1 0.6 0.2 0.1 3.7 3.5 8.4 3.4 3.7 3.1 28.3 44.1 100%

As a significant component of the recruitment strategy for the CEP, FDIC recruiters 

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

This includes 110 institutions designated as members of the Hispanic Association 

of Colleges and Universities, Historically Black Colleges and Universities, and other 

minority-serving institutions, tribal colleges and universities, and institutions with 

significant student populations of Asian Americans and women. 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 25

EMPLOYMENT AT THE FDIC : Increasing Representation of Minorities and Women

The FDIC corporate recruiters participated in 200 college career fairs, information 

sessions, and other recruitment-related campus activities throughout the United States 

to brand the FDIC and attract the best qualified candidates. In 2016, FDIC recruiters 

attended 23 national diversity outreach events and three regional outreach events 

to increase awareness of the FDIC as an employer of choice to professionals and 

students. Recruitment efforts during 2016 also included the following:

§ Met with key leaders in Hispanic American, Black American, Asian American, 

women’s, and veterans’ organizations to create awareness of FDIC careers and 

identify opportunities to expand outreach to their members.

§ Participated in three student symposiums and career fairs held by the Association 

of Latino Professionals For America (ALPFA): the West Regional Symposium with 

a senior FDIC manager serving on a leadership panel to explain the benefits of 

choosing a public service career; FDIC recruiters serving as luncheon mentors to 

provide insight into FDIC employment opportunities and suggestions to students 

on ways to develop their careers; and at the 2016 ALPFA National Convention where 

FDIC hosted a panel discussion entitled Financial Savviness for College Students.

§ Participated at the Adelante 2016 National Leadership Institute where a senior 

FDIC representative provided the keynote address to participants entitled Thinking 

Outside of the Box in Today’s Work Environment, and where FDIC recruiters hosted 

workshops entitled A Career with the FDIC. 

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

Education for students from Historically Black Colleges and Universities.

§ Provided industry trends and FDIC recruitment statistics to business deans of 

Historically Black Colleges and Universities during their annual summit, and a senior 

FDIC manager served on a panel to provide business deans and faculty members 

with insight on skills students should acquire in college to catapult their careers 

after graduation.

The FDIC continues to help minorities, women, and students with disabilities prepare 

for careers in business and finance. During 2016, the FDIC recruited summer interns 

through the Office of Personnel Management’s (OPM) Pathways Program and the 

Workforce Recruitment Program for College Students with Disabilities (WRP), as well 

as advertising intern opportunities in national publications and publications targeted to 

minorities and women. Over the past several years, the FDIC has been a leader in the 

federal government in the hiring of WRP students with disabilities, including veterans, 

and provided summer employment opportunities to six WRP students in 2016.

At the beginning of 2016, the Division of Insurance and Research (DIR) Diversity 

Working Group (DWG) performed data analytics on the population of schools 

included in the FDIC Corporate Recruitment Program to calculate diversity ratios 

and economic/finance degree ratios. The analyses helped align DIR’s recruitment 
26 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

EMPLOYMENT AT THE FDIC : Increasing Representation of Minorities and Women

program with its diversity plan. In 2016, six DIR recruiters worked with nine colleges 

and universities, eight minority-affiliated organizations, and participated in more 

than 15 on-site events, including outreach events and job fairs. Recruiters actively 

established relationships with key faculty and staff, and shared job postings with 

schools and other corporate recruiters. 

In addition, the DWG created brochures for the economic research assistant, 

economic analyst, financial analyst, and policy analyst occupations and distributed 

these brochures at recruiting and outreach events. The brochures are designed to 

fulfill two objectives: (1) to increase the effectiveness of candidates to navigate the 

federal application and interview process; and (2) to improve candidate awareness 

of FDIC job opportunities beyond the event date. Many job candidates are unfamiliar 

with the federal process and do not know that valuable resources are available on 

OPM’s USAJOBS website. By pointing candidates to these resources, candidates 

have a better chance of navigating the process successfully. Furthermore, many job 

candidates are not aware that they can sign-up to receive notices from USAJOBS 

when FDIC positions are posted. The information in the brochures provides candidates 

with instructions on how the FDIC job postings can be sent to email accounts 

automatically, resulting in a consistent method of reaching this candidate pool.

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. 

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 2016 Report to Congress 27

EMPLOYMENT AT THE FDIC : Increasing Representation of Minorities and Women

The dashboard was used during 2016 by FDIC divisions and offices to target 

recruitment activities to increase the pool of minority and women applicants; 

assess the inclusion of minorities and women at the entry, mid, and senior levels; 

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 measure progress and adjust strategies where needed. For 

example, DCP used the dashboard to monitor the employment of, and to develop 

strategies to attract, Hispanic Americans to employment in the FDIC; DIR used the 

dashboard to conduct outreach for its economist occupation; and the Corporate 

Recruitment Program used the dashboard to direct recruitment activities for the CEP. 

The FDIC will continue to identify additional enhancements to the dashboard that 

will permit senior leaders to continue understanding and advancing diversity and 

inclusion within their organizations.

Workforce Development Initiative

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

challenges as many of its long-term, experienced employees consider retirement. 

Introduced in 2014, the FDIC’s Workforce Development Initiative 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 2016, the FDIC continued to develop and implement the WDI to address 

comprehensive succession planning needs and workforce development challenges 

and opportunities. The WDI is focused on four broad objectives: (1) to attract and 

develop talented employees across the agency; (2) to enhance the capabilities of 

employees through training and diverse work experiences; (3) to encourage employees 

to engage in active career development planning and seek leadership roles in the FDIC; 

and (4) to build on and strengthen the FDIC’s operations to support these efforts. 

In 2017, the FDIC will continue to develop and implement the strategies, programs, 

and infrastructure to support the attainment of these objectives in meeting its longterm workforce needs. As a member of the WDI workgroup, OMWI helps ensure that 

minorities and women have an equal opportunity to participate. 
28 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

EMPLOYMENT AT THE FDIC : Increasing Representation of Minorities and Women

Challenges

A key challenge for the FDIC in promoting diversity at all levels of its workforce is 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 43.7 percent (2,761) of the FDIC total workforce (6,322). Individuals 

who began their FDIC careers as 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.

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

minorities in the examiner workforce, those percentages still remain significantly 

below the CLF, such as Asian American men and women, Hispanic American women, 

and women of two of more races. The attrition data will continue to be monitored and 

strategies will be developed to improve retention. [See Figure 12.]

Figure 12 CEP Attrition Rates

Total 2 or More AIAN Asian Black Hispanic White

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

Hired 1665 11 15 4 11 29 52 159 110 30 43 399 802

Involuntary 

Departures 30 0 0 0 0 1 1 5 9 1 2 3 8

Involuntary 

Attrition Rate+

(%)

1.8 0.0 0.0 0.0 0.0 3.5 1.9 3.1 8.2 3.3 4.7 0.8 1.0

Subtotal 1635 11 15 4 11 28 51 154 101 29 41 396 794

Transfers 

(Mid-Career/

Other)

36 0 0 0 0 0 0 4 3 2 1 13 13

Voluntary 

Departures 521 2 2 0 5 9 26 58 43 10 15 120 230

Voluntary 

Attrition Rate 

* (%)

31.9 18.2 13.3 0.0 45.5 32.1 51.0 37.7 42.6 34.5 36.6 30.3 29.0

Number 

Retained 1078 9 13 4 6 19 25 92 55 17 25 263 551

+

 “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 attorneys, economists, accountant/auditors, 

financial administration, and general business and industry, the FDIC faces challenges 

in attracting and recruiting minorities and women, primarily due to low representation 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 29

EMPLOYMENT AT THE FDIC : Increasing Representation of Minorities and Women

rates for minority groups and women in these occupations. [See Appendix D.]  

Overall, minorities fall below the relevant CLF in the economist occupation, 

with Hispanic American men and Asian American men having particularly low 

participation rates and Hispanic American women, Black American men, American 

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

races being absent. 

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

American Indian and Alaskan 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 the attorney occupation, the level of representation for some groups is not as 

pronounced, with Hispanic American men and women, Asian American men, and 

women of two or more races having participation rates below the relevant CLF.  

Women, Hispanic American men and women, White women, and women of two or 

more races also fall below the CLF in the financial administration and general business 

and industry occupations. In the general business and industry occupation, Black 

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

American women are slightly below the CLF.

To address the participation rates of the groups noted above in the non-examiner 

occupations, the FDIC recruitment plan includes strategies intended to increase 

outreach to prospective applicants in underrepresented groups at the entry, mid, and 

senior levels in these occupations throughout the agency. The plan includes reaching 

out to professional organizations, colleges and universities, and affinity groups. 

In 2016, 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. Also, the FDIC updated and continued implementing its 

Diversity and Inclusion Strategic Plan, which is designed to develop an integrated view 

of diversity and inclusion, strategically monitor and manage the employment life cycle 

(hire to retire), and address challenges at the FDIC.
30 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

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Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 31

OTHER ACTIVITIES

Status of DFA Section 342 Regulated Entity Requirements

Section 342(b)(2)(C) of the DFA requires the OMWI Director of each federal financial 

regulatory agency to develop standards for assessing the diversity policies and 

practices of its regulated institutions. 

The FDIC OMWI worked closely with its counterpart OMWI Directors at 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). On June 10, 2015, 

the OMWI agencies published in the Federal Register the final Interagency Policy 

Statement Establishing Joint Standards for Assessing the Diversity Policies and 

Practices of Regulated Entities (Policy Statement).

The Policy Statement reflects input received during a public comment period, as well 

as information gathered throughout the development process, and is intended to 

promote transparency and awareness of diversity policies and practices within the 

financial services industry. Furthermore, the Policy Statement provides a framework 

for regulated financial institutions to establish, assess, and strengthen their diversity 

policies and practices.
32 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

OTHER ACTIVITIES

In 2016, the FDIC continued to collaborate with its counterparts at the OCC, FRB, CFPB, 

and SEC. These five OMWI agencies received approval from the OMB on February 18, 

2016, as required by the Paperwork Reduction Act (PRA), to collect information from 

their regulated entities. Regulated entities were notified of the collection approval 

through the Federal Register on July 13, 2016, and were informed that they may now 

submit self-assessments of their diversity policies and practices to the OMWI Director 

of their primary federal financial regulator. 

During 2016, the FDIC OMWI participated with the other agencies in discussions 

with financial institutions regarding the requirements of the Policy Statement and, 

particularly, the self-assessments. Panel discussions were held at the American 

Bankers Association National Conference, the Massachusetts Bankers Association 

Human Resources Conference, the Community Bankers Association of Georgia’s Sixth 

Annual Workplace Conference, the Financial Services Industry Roundtable, and the 

Mortgage Bankers Association Roundtable hosted by the CFPB. 

To facilitate uniform and systematic collection of information, the FDIC developed a 

diversity self-assessment template for its regulated institutions to use as they assess 

their diversity policies and practices. After a period of public comment pursuant to the 

PRA, the FDIC received approval from OMB for the template in early 2017. In addition, 

FDIC, OCC, and FRB developed Frequently Asked Questions and posted them on each 

agency’s website as a resource to regulated institutions.

Guidance to the financial institutions strongly encourages them to disclose, on their 

websites, their diversity policies and practices, as well as information related to their 

self-assessments, to maximize transparency, and to provide their policies, practices, 

and self-assessment information to their primary federal financial regulator. In 2016, 

some FDIC-regulated institutions began conducting self-assessments against the 

diversity standards and submitting them to the FDIC OMWI Director. The FDIC plans 

to use self-assessment information provided by its regulated institutions to monitor 

progress and trends, and to identify and publicize promising diversity policies and 

practices in the financial services industry. Through inter-agency coordination with the 

OCC and the FRB, the FDIC will continue communicating with the regulated institutions 

about the value of conducting the self-assessment, submitting it to the OMWI Director 

of the primary federal regulator, and making information transparent to the public.

Contractor Workforce

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. Following 

passage of the DFA, OMWI worked with the Acquisition Services Branch (ASB) 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 33

OTHER ACTIVITIES

and Legal Division to develop a “Fair Inclusion” contract clause for all awards 

over $100,000. This award amount is the agency threshold for contracts that must 

follow formal contract award procedures. The clause notifies contractors of the 

responsibility to include minorities and women in their workforce and advises of 

remediation action the FDIC may take if it is determined the contractor has failed 

to do so. OMWI developed the Contractor Workforce Review Process (CWRP) in 

collaboration with ASB and the Legal Division to assess a contractor’s good faith 

efforts. The CWRP encompasses existing FDIC procurement policies and practices 

that support the requirements of section 342(c) of DFA.

The CWRP is the FDIC’s procedural framework to verify that contractors that do 

business with the FDIC are making good faith efforts to include minorities and women 

in their workforce. Good faith efforts are defined as actions contractors undertake to 

identify, and, if present, remove barriers to employment or expansion of employment 

opportunities for women and minorities. Contractors that seek to do business with 

the FDIC must provide a written statement, known as the Fair Inclusion Certification, 

stating their commitment to making a good faith effort. To verify their commitment, 

agency contractors, upon written request from the FDIC, are asked to provide 

documentation that supports the actions they have undertaken to demonstrate 

their good faith effort to ensure the fair inclusion of minorities and women in their 

workforce.

In 2016, OMWI continued implementation of the CWRP in collaboration with ASB 

and the Legal Division. Contract files for all new awards were reviewed for the Fair 

Inclusion clause and to verify receipt of the contractor’s written certification. In 

March 2016, FDIC was approved under the PRA to collect good faith effort support 

documentation from agency contractors. 

During 2016, OMWI requested support documentation from 40 contractors. Thirtyfive of the 40 contractors responded and/or provided good faith effort support 

documentation, which included a copy of their affirmative action plan, demographic 

data, and/or other documentation for review. All contractors reviewed had made, or 

were making, good faith efforts to include women and minorities in their workforces. 

The five remaining contractors were still under review.

OIG Review of FDIC’s Efforts to Provide Equal Opportunity 

and Achieve Senior Management Diversity

In 2014, the Ranking Member and Minority Members of the United States House of 

Representatives Committee on Financial Services requested that the FDIC Office of 

Inspector General (OIG) perform work related to the FDIC’s efforts to increase senior 
34 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

OTHER ACTIVITIES

management diversity. The Members referenced the 2013 GAO report that concluded, 

among other things, that management-level representation of minorities and women 

among the federal financial regulatory agencies had not changed substantially from 

2007 through 2011, despite the senior management diversity provisions in the DFA. 

The Members requested that the OIG determine whether agency internal operations 

and personnel practices were systematically disadvantaging minorities and women 

from obtaining senior management positions.

Based on their review of the FDIC human resources processes and related efforts 

to achieve diversity and fairness, the OIG observed that the FDIC faces challenges 

to increasing workforce diversity overall and at the senior management level due 

to issues that are difficult for the FDIC to control, including low turnover of existing 

managers and executives, underrepresentation of women and minorities in internal 

candidate pools, and competition from the private sector for diverse candidates. The 

OIG observed that the FDIC has:

§ developed processes that consider diversity in recruiting, hiring, and promotions;

§ implemented robust training and leadership development programs;

§ established controls in its performance management and recognition programs to 

ensure fairness;

§ provided employees with several options for appealing personnel decisions and 

reporting discrimination;

§ monitored employee separation and termination statistics and reasons for leaving 

the agency; and

§ initiated succession planning efforts.

The OIG also observed that there were areas for improvement and made nine 

recommendations related to recruitment, leadership training, the EOI Program, 

analysis of performance results, the reliability of diversity data, and relevant EEO 

policies. The FDIC accepted all nine OIG recommendations and worked throughout 

2015 and 2016 to implement recommended actions. The FDIC instituted several 

initiatives to address the recommendations to include:

1. formalizing strategic recruiting procedures to better ensure consistent and 

comprehensive outreach to diverse populations;

2. establishing processes to measure the success of recruiting efforts;

3. establishing procedures to track participation rates by gender, race, and ethnicity 

in the FDIC leadership development programs; 
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 35

OTHER ACTIVITIES

4. developing policies and procedures for the FDIC EOI program, as well as 

establishing a process to track EOI application and selection rates by gender, race, 

and ethnicity; and,

5. enhancing controls to ensure the reliability of the data reported in the FDIC’s 

Federal Agency Annual EEO Program Status Report by creating and implementing 

a data validation and verification plan.

During 2016, the FDIC continued to refine and implement strategic actions in response 

to the recommendations. All of the recommendations have now been incorporated in 

the FDIC human resources and diversity programs and activities.

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. The FDIC’s work during 2016 

dealt primarily with young people because of the Financial Literacy and Education 

Commission’s emphasis on the Starting Early for Financial Success program.

Money Smart for Young People, a standards-aligned curriculum designed to involve 

teachers, students, and parents/caregivers in the learning process about money, was 

downloaded more than 26,000 times during 2016, its first full year of production. Also, 

189 educators at eight school locations received professional development training 

to assist them in using Money Smart for Young People as part of a pilot project to 

gain feedback. Input from stakeholders was considered to enhance the curriculum, 

including making it available to download on a lesson-by-lesson basis. 

The Teacher Online Resource Center, the gateway for helpful resources from the FDIC 

and the CFPB for youth financial education, was enhanced through the addition of 

five new videos that overview the key features of the curriculum. There were more 

than 30,000 visits to the site during the year. The FDIC continued to collaborate with 

strategic partners to increase awareness of free resources. For example, more than 

600 people participated in four conference calls/webinars held in collaboration with the 

Jump$tart Coalition to make educators feel more comfortable in using the curriculum. 

The FDIC also completed a report on key lessons from the Youth Savings Pilot 

Program, which was aimed at identifying and highlighting promising approaches to 

offering financial education tied to the opening of safe, low-cost savings accounts 

for school-aged children. The FDIC in 2017 will issue this report, developed from the 

experiences of the 21 banks that participated in the two-year pilot that will define 
36 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

OTHER ACTIVITIES

a range of models that offer banks flexibility to adapt to varying opportunities to 

promote youth savings. The final report will be a resource for banks, schools, and 

others interested in enhancing youth financial education efforts through opportunities 

for young people to open savings accounts. 

The FDIC also developed and began to implement strategies to improve financial 

education and access to mainstream financial services for youth participating in youth 

employment programs funded through the Workforce Investment Opportunity Act 

(WIOA). For workforce providers and their partners teaching financial education, the 

FDIC developed a tool to map Money Smart to WIOA’s financial education element 

and drafted a Money Smart supplement to prepare youth to open their first accounts. 

The FDIC also led three webinars in collaboration with the U.S. Department of Labor to 

increase awareness of Money Smart by some of the organizations that receive federal 

funding for youth employment. In addition, the FDIC participated in three regional 

events in collaboration with the Department of Labor and Federal Reserve System to 

strengthen the capacity of workforce development organizations to work with financial 

institutions on financial capability initiatives. 

Also, the FDIC and CFPB worked on an enhanced version of Money Smart for Older 

Adults, a free financial education curriculum first released in 2013 to help prevent elder 

financial exploitation. The enhancements which were issued in March 2017, include 

updates to the material based on input from trainers and technical updates. The 

newly updated resource includes an expanded discussion on common types of elder 

financial exploitation such as tax, charity, debt collection, and grandchild imposter 

scams. The resource also incorporates other newer federal resources that can be 

helpful on topics such as how to research an investment advisor.

In 2016, the FDIC provided professional guidance and technical assistance to banks and 

community organizations through outreach activities and events designed to foster 

understanding and practical relationships between financial institutions and other 

community development and economic inclusion stakeholders. The events focused on 

economic inclusion, community development and Community Reinvestment Act (CRA) 

events linking bank and community partners with opportunities to address community 

credit and development needs. A particular emphasis was on low- and moderateincome consumers, including providing access to mortgage credit in underserved 

markets and small businesses development-related events.

In 2016, OMWI and DCP conducted Money Smart workshops at several events that 

hosted large populations of Black American, Hispanic American, Asian American, and 

Native American students and adults. In addition, OMWI conducted six Money Smart 

for Small Business workshops at the Reservation Economic Summit (RES) sponsored 

by the National Center for American Indian Enterprise Development. RES is the largest 

economic event designed to assist, support, and provide resources to American Indian 

businesses and entrepreneurs.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 37

OTHER ACTIVITIES

Also, the FDIC’s Advisory Committee on Economic Inclusion held meetings in 2016. 

The Committee continued to provide the FDIC with advice and recommendations 

on important initiatives focusing on expanding access to banking services for 

underserved populations. A number of initiatives designed to promote economic 

inclusion have been conducted in consultation with the Committee, including pilot 

programs to study safe banking accounts and an affordable small-dollar loan program.

Minority Depository Institution Activities

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

for the FDIC. In 2016, the FDIC continued to advocate for MDI and Community 

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

strategies included: increasing collaboration between MDI and CDFI bankers; 

partnering to share costs, raising capital, or pooling loans; and making innovative use 

of federal programs. The FDIC supports these efforts by providing technical assistance 

to MDI and CDFI bankers.

The FDIC also continues to pursue ways to improve communication and interaction 

with MDIs and to respond to the concerns of minority bankers. The FDIC 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 assist bank management in understanding and 

implementing examination recommendations. These return visits, normally conducted 

90 to 120 days after the examination, provide recommendations or feedback for 

improving operations, not to identify new issues. The FDIC’s website encourages and 

provides contact information for any MDI to request technical assistance at any time. 

In 2016, the FDIC sponsored a discussion between trade groups representing 

MDIs and CDFIs and representatives of potential bank partners, focusing on CRA 

partnerships. In addition, the FDIC provided technical assistance to a group seeking 

to develop a private equity fund to invest in MDIs. The FDIC’s assistance addressed 

how the proposed structure might be considered under the Basel Capital rules as 

well as the CRA. 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 2016, the FDIC, OCC, and FRB co-hosted a webinar on strategic planning attended by 

approximately 50 MDIs, and began planning the 2017 Interagency MDI and CDFI Bank 

Conference, which the agencies will co-sponsor. The conference will be held in Los 

Angeles where there is a significant concentration of MDIs. The conference will feature 
38 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

OTHER ACTIVITIES

an interactive panel with the FDIC Chairman, a Federal Reserve Board Governor, and 

the Comptroller of the Currency. 

In 2016, the FDIC provided 135 individual technical assistance sessions on 

approximately 60 risk management and compliance topics, including:

§ Accounting

§ Bank Secrecy Act and Anti-Money 

Laundering

§ Basel III Capital Rules

§ Brokered Deposits/Waivers

§ Capital Planning

§ Commercial Real Estate Concentrations

§ Community Reinvestment Act

§ Funding and Liquidity

§ Global Cash Flow

§ High Volatility Commercial Real Estate

§ Information Technology Risk 

Management and Security

§ Interest Rate Risk

§ Loan Underwriting and Administration 

§ Qualified Mortgage Rules

§ Strategic Planning

§ Third-Party Risk Management

The FDIC regional offices also held outreach, training, and educational programs 

for MDIs through conference calls and regional banker roundtables. In 2016, topics 

of discussion for these sessions included many of those listed above, as well as the 

FDIC’s National MDI Program, the FDIC’s Community Banking Initiative, and the 

availability of technical assistance videos on corporate governance, strategic planning, 

director responsibilities, community banking initiatives, compliance guidance, 

concentration risk management, and bank merger and acquisition.
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 39

CONCLUSION

During 2016, the FDIC made progress enhancing the diversity of its workforce and 

business practices. 

The racial, ethnic, and gender diversity of the FDIC workforce continues a steady 

increase since the passage of DFA section 342. Both the percentages for minorities (28.2 

percent) and women (45.1 percent) in the FDIC’s permanent workforce grew over the 

past five years. The FDIC continues to focus on attracting, hiring, 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.

With regard to increasing MWOB participation in contracting, the FDIC continued 

to focus on opportunities for MWOBs in its non-financial recurring services and 

implemented 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, conducting technical assistance events, and hosting forums on the 

FDIC’s Owned Assets Marketplace and Auctions Program that resulted in 188 new 

MWOBs being added to the FDIC Contractor Resource List. Despite the decrease 

in bank resolution activities, which has been the major source for contracting 
40 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

CONCLUSION

opportunities and outside legal counsel work, the FDIC has been successful at 

identifying opportunities for MWOBs and MWOLF participation. 

In partnership with the OMWI Directors and staff of the OCC, NCUA, FRB, CFPB, and 

SEC, the FDIC remained fully engaged in fulfilling the requirements of DFA section 342 

by finalizing the Interagency Policy Statement Establishing Joint Standards for Assessing 

the Diversity Policies and Practices of Entities Regulated by the Agencies, seeking 

approval to collect information from regulated institutions, and developing resources 

to assist institutions in responding to the Policy Statement. Furthermore, OMWI 

implemented the remaining requirements of section 342 regarding the good faith efforts 

of contractors to include women and minorities in their workforce, and the development 

of standards for considering race, gender and ethnicity in the FDIC’s workforce. 

In every respect, the FDIC’s accomplishments during 2016 are in concert with the 

requirements of DFA section 342. 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 2016 Report to Congress 41

APPENDICES
42 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

APPENDICES

Appendix A

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

2012 2013 2014 2015 2016

Total awards $1,041.7 100.0% $572.8 100.0% $686.8 100.0% $858.4 100.0% $508.8 100.0%

Minority-owned 

or women-owned 

business totals

$308.0 29.6% $198.7 34.7% $239.9 34.9% $211.6 24.7% $93.9 18.5%

Minority-owned $261.1 25.1% $158.5 27.7% $143.7 20.9% $145.2 16.9% $56.5 11.%

Women-owned $90.7 8.7% $66.1 11.5% $132.6 19.3% $104.2 12.1% $47.4 9.3%

Both minorityowned and 

women-owned

$43.8 4.2% $25.9 4.5% $36.4 5.3% $37.8 4.3% $10.0 1.9%

Asian American $92.6 8.9% $38.0 6.7% $27.1 4.0% $51.8 6.0% $25.0 4.9%

Black American $105.6 10.1% $32.2 5.6% $21.3 3.1% $30.7 3.6% $9.4 1.9%

Hispanic 

American $50.0 4.8% $85.3 14.9% $66.1 9.6% $43.2 5.0% $20.6 4.0%

Native American $9.3 0.9% $ - 0.0% $0.8 0.1% $ - 0.0% $0.1 0.0%

Other minority $3.6 0.4% $3.0 0.5% $28.4 4.1% $19.5 2.3% $1.4 0.3%

FDIC Payments to MWOBs, Five-Year Trend (in millions)

2012 2013 2014 2015 2016

Total Contract 

Payments $660.0 100.0% $553.7 100.0% $491.6 100.0% $507.2 100.0% $415.2 100.0%

Minority-owned $117.7 17.8% $102.9 18.6% $89.3 18.2% $89.3 17.6% $56.0 13.5%

Women-owned $70.1 10.6% $63.7 11.5% $63.6 12.9% $83.2 16.4% $66.8 16.1%

Both minorityowned and 

women-owned

$26.4 4.0% $26.0 4.7% $24.7 5.0% $30.0 5.9% $11.3 2.8%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 43

APPENDICES

Appendix B

FDIC 2016 Contract Awards by Top Ten NAICS Codes

NAICS NAICS Description Dollar Amount of 

All Awards

Dollar Amount of 

MWOB Awards

% of Dollars 

to MWOBs

541519 Other Computer Related Services $109,900,311.59 $17,479,314.05 15.9%

541611 Administrative Management and 

General Management Consulting 

Services

 $77,084,578.46 $11,890,064.81 15.4%

531311 Residential Property Managers $44,262,909.00 $11,214,105.00 25.3%

531320 Offices of Real Estate Appraisers $26,653,981.95 $5,486,292.95 20.6%

423430 Computer and Computer Peripheral 

Equipment and Software Merchant 

Wholesalers

 $25,227,802.58 $217,753.60 0.9%

541511 Custom Computer Programming 

Services

 $25,196,191.27 $5,159,074.94 20.5%

541512 Computer Systems Design Services $20,804,416.35 $16,637,123.35 80.0%

561320 Temporary Help Services $18,505,394.16 $4,840,000.00 26.2%

493190 Other Warehousing and Storage $17,883,278.80 $- 0.0%

561110 Office Administrative Services $17,500,000.00 $- 0.0%

Total $383,018,864.16 $72,923,728.70 19.0%
44 Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress

APPENDICES

Appendix C

FDIC Total, Permanent, and Executive Manager Workforce, Five-Year Trend

Total Workforce (Permanent and Non-Permanent)

2012 2013 2014 2015 2016 Change

Minority 27.8% 27.5% 28.1% 28.2% 28.0% +0.2%

Non-Minority 72.2% 72.5% 71.9% 71.8% 72.0% -0.2%

Men 56.3% 56.3% 55.5% 55.3% 55.2% -1.1%

Women 43.7% 43.7% 44.5% 44.7% 44.8% +1.1%

Permanent Workforce

2012 2013 2014 2015 2016 Change

Minority 26.9% 27.3% 27.6% 28.0% 28.2% +1.3%

Non-Minority 73.1% 72.7% 72.4% 72.0% 71.8% -1.3%

Men 55.7% 55.2% 55.0% 54.8% 54.9% -0.8%

Women 44.3% 44.8% 45.0% 45.2% 45.1% +0.8%

Total Workforce - Executive Manager (Permanent and Non-Permanent)

2012 2013 2014 2015 2016 Change

Minority 18.3% 15.7% 14.1% 18.0% 18.8% +0.5%

Non-Minority 81.7% 84.3% 85.9% 82.0% 81.2% -0.5%

Men 72.5% 68.6% 64.1% 66.9% 63.2% -9.3%

Women 27.5% 31.4% 35.9% 33.1% 36.8% +9.3%
Section 342 Dodd-Frank Wall Street Reform and Consumer Protection Act 2016 Report to Congress 45

APPENDICES

Appendix D 

2016 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 Men Women Men Women Men Women Men Women Men Women Men Women Men Women

Economist (0110)

# 68 44 24 1 0 41 19 0 2 2 3 0 0 0 0

% 100 64.7 35.3 1.5 0.0 60.3 27.9 0.0 2.9 2.9 4.4 0.0 0.0 0.0 0.0

CLF 100% 67.1% 32.9% 3.3% 1.9% 55.8% 25.2% 2.8% 2.7% 4.4% 2.7% 0.2% 0.1% 0.6% 0.4%

Financial Administration 

and Program (0501)

# 185 102 83 4 2 77 35 12 38 6 6 1 2 2 0

% 100 55.1 44.9 2.2 1.1 41.6 18.9 6.5 20.5 3.2 3.2 0.5 1.1 1.1 0.0

CLF 100% 43.8% 56.3% 4.0% 5.8% 32.5% 38.6% 4.7% 7.5% 1.7% 3.1% 0.3% 0.4% 0.6% 1.0%

Accountants and 

Auditors (0510/0511) 

# 97 47 50 0 0 35 21 8 23 2 6 0 0 2 0

% 100 48.5 51.5 0.0 0.0 36.1 21.6 8.2 23.7 2.1 6.2 0.0 0.0 2.1 0.0

CLF 100% 39.9% 60.1% 2.2% 3.9% 31.8% 44.2% 2.4% 5.6% 3.0% 5.4% 0.1% 0.3% 0.4% 0.7%

Financial Institution 

Examining (0570) 

# 2761 1705 1056 70 31 1445 798 113 164 51 45 9 7 17 11

% 100 61.8 38.2 2.5 1.1 52.3 28.9 4.1 5.9 1.8 1.6 0.3 0.3 0.6 0.4

CLF 100% 54.8% 45.2% 3.1% 3.7% 44.1% 28.3% 3.4% 8.4% 3.5% 3.7% 0.1% 0.2% 0.6% 1.0%

Attorney (0905) 

# 370 215 155 7 5 187 123 11 14 5 11 2 1 3 1

% 100 58.1 41.9 1.9 1.4 50.5 33.2 3.0 3.8 1.4 3.0 0.5 0.3 0.8 0.3

CLF 100% 66.7% 33.3% 2.5% 1.9% 59.7% 26.7% 2.1% 2.5% 1.7% 1.6% 0.1% 0.1% 0.6% 0.6%

General Business and 

Industry (1101)

# 372 237 135 10 3 197 101 13 22 11 8 1 0 5 1

% 100 63.7 36.3 2.7 0.8 53.0 27.2 3.5 5.9 3.0 2.2 0.3 0.0 1.3 0.3

CLF 100% 36.7% 63.3% 2.9% 5.9% 27.1% 43.8% 3.6% 8.8% 2.4% 3.3% 0.2% 0.4% 0.6% 1.1%
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