Last week, the Office of Inspector General published its findings following an audit assessing the CFPB’s human resources-related operations and other efforts for equal employment. The audit, which was conducted in response to a congressional request for information on the CFPB’s activities related to diversity and inclusion (D&I), analyzed the CFPB’s efforts to ensure equal opportunities for minorities and women to obtain senior management positions and to increase racial, ethnic, and gender diversity in the workforce. The CFPB is subject to certain federal employment provisions, including those contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). Specifically, Dodd-Frank required that the CFPB establish an Office of Minority and Women to handle all management, employment, and business diversity issues.
In its audit, the Inspector General noted that the CFPB has taken steps since July 2011 to instill a diverse and inclusive workforce, including elevating the Office of Minority and Women Inclusion and the Office of Equal Employment Opportunity to the Office of the Director; holding sessions with employees to identify and address fairness, equality, and inclusion issues; and creating an internal advisory council and working groups to consider D&I issues. Notwithstanding those efforts, the Office of the Inspector General recommended the following improvements:
- Make D&I training mandatory for CFPB employees, supervisors, and senior managers;
- Strengthen data quality in tracking spreadsheets for equal employment opportunity complaints and negotiate grievances and analyze data related to performance management for trends that could be indicative of potential D&I issues;
- Finalize a D&I strategic plan and strengthen supervisors’ and senior managers’ accountability for implementing D&I initiatives and human resources-related policies; and
- Develop a formal succession planning process to help ensure that the CFPB will have a diverse pool of candidates for senior management positions.
The Office of Inspector General circulated a draft report containing recommendations to the CFPB prior to issuing the final report. In response to the draft report, the CFPB outlined planned, ongoing, and completed initiatives designed to analyze performance management data and performance management training and to track equal employment opportunity (and non-equal employment opportunity) complaints. The Inspector General also noted that the CFPB has approved standard operating procedures to address several of its recommendations and is in the process of developing a new performance management system.
Our Diversity Group is working with clients to be sure that they do not have any similar problems.