The FDIC is urging financial institutions it supervises to voluntarily submit self-assessments of their diversity policies and practices to the agency by Oct. 31, 2024.

The agency said that the self-assessment is not an examination requirement and that the results are not shared with examiners. The results also have no impact on an institution’s safety and soundness, its consumer compliance ratings or its Community Reinvestment Act performance evaluation, the agency said.

The FDIC analyzes diversity self-assessment information detailed in the Interagency Statement pursuant to Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. With regard to the assessment of the diversity policies and practices of regulated entities, Section 342 provides that nothing regarding the development of standards for such assessments may be construed to mandate any requirement on or otherwise affect the lending policies and practices of any regulated entity, or to require any specific action based on the findings of the assessment.

The standards cover:

  • Organizational commitment to diversity and inclusion;
  • Workforce profile and employment practices;
  • Supplier diversity;
  • Practices to promote transparency of organizational diversity and inclusion; and
  • Entities’ self-assessment.

The FDIC provides users with a guide, a video and other resources intended to help institutions assess and identify ways to strengthen their diversity policies and practices in line with their size and unique characteristics.

The FDIC said it will treat all information gathered as confidential commercial information to the extent permitted by law, though in drafting self-assessments, covered entities should keep in mind that requests for disclosure of data or information will be processed in accordance with applicable law, including the Freedom of Information Act.

The diversity self-assessment form is fully automated and accessible online through the secure FDICconnect portal.

Ballard Spahr’s Diversity & Inclusion Legal Team will continue to monitor regulatory and legislative updates in this area.  The team consists of Ballard Spahr lawyers from several practice groups who regularly advise financial institutions and other organizations on conducting gap assessments and developing strategic plans to address diversity, equity, and inclusion.