The CFPB’s Office of Minority and Women Inclusion (OMWI) provided its annual report to Congress covering the agency’s efforts in 2023. Section 342 of the Dodd-Frank, Wall Street Reform, and Consumer Protection Act (Dodd-Frank) mandates that the OMWI agency provide an annual report to Congress regarding the successes achieved, challenges, and other findings.

In 2023, the CFPB engaged in a year-long internal strategic planning effort to further mature diversity, equity, inclusion and accessibility (DEIA). The report highlights the agency’s efforts in carrying out the duties under Section 342 of Dodd-Frank to:

  • Increase workforce diversity and build a more inclusive environment within its workplace;
  • Ensure fair and inclusive business practices in procurements, contracting, and other business activities; and
  • Assess the diversity policies and procedures and practices of entities regulated by the CFPB.

CFPB

The report indicates that in 2023 the CFPB increased minority representation at the executive level to 51 percent (a 5 percent increase from 2022) and women in executive positions equaled 49 percent. Women employees equal 50.4 percent of the agency’s total workforce. Over the past five years, the representation of women employees at the CFPB has remained consistently around 50 percent; however, the representation of minorities has increased from 40 percent to 43 percent.

Contractors & Suppliers

In 2023, minority and women owned businesses earned and received over 40 percent of the agency’s total competitive dollars spent. Both the CFPB’s OMWI and Office of Procurement and Finance has increased minority and women owned business spending from less than 10 percent in 2017 to 41.1 percent in 2023. The Executive Branch has set a goal of 50 percent of Federal procurement dollars to go to small and minority contractors.

Industry

As part of the report, the OMWI collects voluntary self-assessment forms from regulated entities. The report notes that large, non-bank entities were the least likely to submit the self-assessment form. The OMWI analyzes the data provided in the self-assessment forms by industry group, institution size, and responses to questions. Every entity that submitted a self-assessment form engaged in the following activities:

  • Included diversity and inclusion considerations in both employment and contracting as an important part of its strategic plan for recruiting and hiring, as well as for promotion and retention;
  • Had a diversity and inclusion policy that is approved and supported by senior leadership, including senior management and the board of directors;
  • Provided regular DEIA relevant progress reports to the board and senior management;
  • Regularly conducted training and provided educational opportunities on equal employment aspects as well as diversity and inclusion;
  • Took proactive steps to promote diverse candidates in recruiting, hiring, promotion, and retention efforts, as well as in its selection of board members, senior management, and other senior leadership positions;
  • Implemented policies and practices related to workforce diversity and inclusion in a manner that complies with all applicable laws;
  • Conducted outreach to educational institutions servicing significant minority and women student populations;
  • Utilized both quantitative and qualitative measurements to assess workforce diversity and inclusion efforts;
  • Publicized its policy on commitment to diversity and inclusion;
  • Prioritized its policy on its commitment to diversity and inclusion;
  • Prioritized transparency about its progress toward achieving diversity and inclusion in its workforce and procurement activities, which may include the entity’s current workforce and supplier demographic profiles;
  • Publicized its opportunities to promote diversity, which may include current employment and procurement opportunities as well as use of mentorship and developmental programs for employees and contractors;
  • Conducted a self-assessment of its diversity policies and practices annually; and
  • Monitored and evaluated its performance under its diversity policies and practices on an ongoing basis.

In 2023, the OMWI conducted outreach to the largest non-bank mortgage originators and servicers to encourage self-assessment. During this outreach, the OMWI observed that some entities were unwilling to submit a self-assessment but had robust DEIA programs in place. In 2024, the OMWI intends to focus its outreach efforts on auto financing entities and debt collectors.

The OMWI continues to explore methods to improve the self-submission process.

Ballard’s DEI Counseling team advises clients across industries on the development, implementation, and enhancement of DEI programs. Our attorneys perform assessments, develops strategic plans, advise on existing programs, develop policies and communication materials, conduct training, and facilitate the implementation of DEI programs.