Survey. Of the 1,567 CFPB employees surveyed, 1,372 (almost 87.6%) responded to the 2016 survey. We were pleased to see that the survey results appear to show that the CFPB has made progress in improving its work environment. In particular, in response to the question “what progress has the CFPB made in creating a workforce experience where everyone feels included, valued and empowered to do their best work,” 88.4% of the respondents found that the CFPB had made some degree of progress, ranging from “goal achieved” to “limited progress,” and of those respondents, 63% found that either “substantial progress” or “some progress” had been made.
Strategic Plan. The plan takes guidance from Section 342 of the Dodd-Frank Act and other federal initiatives and regulations focused on advancing diversity and inclusion. As released in November 2015, the plan was built around five pillars: workforce diversity, workforce inclusion, sustainability, minority- and women-owned businesses, and the transparency of diversity practices of regulated entities.
The updated plan adds a sixth pillar: employment practices of CFPB contractors. The plan states that through its Office of Minority and Women Inclusion, the CFPB will “use good faith effort (GFE) standards developed under Dodd-Frank Act to determine efforts of Bureau contractors to utilize women and minorities in their workforces.”
The final diversity and inclusion standards adopted by the CFPB, the federal banking agencies and other federal agencies in June 2015 include standards directed at the promotion of contractor diversity by regulated entities. However, those standards emphasize increased outreach to minority-owned and women-owned businesses. The Strategic Plan takes a broad view of the standards to address not only the diversity of the owners of CFPB contractors but also the diversity of a contractor’s workforce. The addition of this sixth pillar is likely an indication that the CFPB expects regulated entities to similarly consider not only the ownership of their contractors but also their contractors’ efforts “to utilize women and minorities in their workforces.”
Ballard Spahr’s Diversity Team advises clients on the design and implementation of diversity and inclusion programs and counsels CFPB-supervised entities on developing and implementing diversity programs.