FR2100_20200819_omb

Supporting Statement for the
Joint Standards for Assessing the Diversity Policies and Practices of
Entities Regulated by the Agencies
(FR 2100; OMB No. 7100-0368)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the interagency Joint Standards for Assessing the Diversity Policies and Practices of
Entities Regulated by the Agencies (Policy Statement) (FR 2100; OMB No. 7100-0368). Section
342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)1
requires the Board, Office of the Comptroller of the Currency, Federal Deposit Insurance
Corporation, National Credit Union Administration, Bureau of Consumer Financial Protection,
and Securities and Exchange Commission (collectively, the agencies) each to establish an Office
of Minority and Women Inclusion (OMWI) to be responsible for all matters of the respective
agency relating to diversity in management, employment, and business activities. Section 342
requires each OMWI Director to develop standards for “assessing the diversity policies and
practices of entities regulated by the agency.”2 The Policy Statement, published jointly by the
agencies in June 2015, contains these standards (Joint Standards).3
The Policy Statement contains a “collection of information” within the meaning of the
Paperwork Reduction Act (PRA). The Policy Statement includes a standard entitled “Practices to
Promote Transparency of Organizational Diversity and Inclusion,” which encourages a regulated
entity to be transparent about its diversity and inclusion activities by voluntarily disclosing
certain information available to the public annually on its websites or through other appropriate
communication methods, in a manner reflective of the entity’s size and other characteristics
(Transparency Standard). In addition, the Policy Statement includes a standard entitled “Entities’
Self-Assessment,” which encourages a regulated entity, in a manner reflective of its size and
other characteristics, to voluntarily conduct a self-assessment of its diversity policies and
practices and to report information pertaining to its self-assessment to the OMWI Director of its
primary federal financial regulator, as well as to publish information pertaining to its efforts with
respect to the Joint Standards (Self-Assessment Standard).
In order to facilitate the provision of self-assessment information to the Board that is
contemplated in the Self-Assessment Standard, the Board developed a voluntary reporting
template entitled “Diversity Self-Assessment Template” for use by institutions regulated by the
Board (reporting template). The Board has revised the language in the “Use of Information”
section of the reporting template regarding the designation of information as confidential by
respondents. The Board also eliminated the “Yes/No” check boxes under Section 5 (Institution’s
Self-Assessment) of the reporting template and ask for a more detailed description of the
institution’s practices during the annual self-assessment period. Additionally, the FR 2100

1

Section 342 of the Dodd-Frank Act is codified at 12 U.S.C. § 5452.
Id.
3
The Policy Statement was published at 80 FR 33016 (June 10, 2015).
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includes a disclosure provision for respondent institutions. The Board revised the FR 2100
information collection to account for this disclosure provision.
The Board’s share of the estimated total annual burden for the FR 2100 is 1,000 hours,
and would remain unchanged with the revisions. The self-assessment template is available on the
Board’s public website at https://www.federalreserve.gov/aboutthefed/omwi-regulated-entitiesself-assessments.htm.
Background and Justification
Section 342(b)(2)(C) of the Dodd-Frank Act requires the OMWI Director of each of the
respective agencies to develop standards for assessing the diversity policies and practices of
entities regulated by their agency. To promote consistency, the agencies worked together to
jointly develop the Joint Standards for assessing diversity policies and practices, and these Joint
Standards were announced through the interagency Policy Statement.
The Board (on its own or in conjunction with the other agencies) may use the information
provided by regulated entities to monitor progress and trends in the financial services industry
with regard to diversity and inclusion in employment and contracting activities, as well as to
identify and highlight those policies and practices that have been successful. The Board (on its
own or in conjunction with the other agencies) may publish information disclosed by regulated
entities, such as leading practices, in any form that does not identify a particular entity or
individual or disclose confidential business information.
Description of Information Collection
The Policy Statement’s Joint Standards include a Transparency Standard, which
encourages a regulated entity to be transparent about its diversity and inclusion activities by
voluntarily making certain information available to the public annually on its websites or through
other appropriate communications methods, in a manner reflective of the entity’s size and other
characteristics. The specific information referenced in this standard is (a) the entity’s diversity
and inclusion strategic plan, (b) its policy on its commitment to diversity and inclusion, (c) its
progress toward achieving diversity and inclusion in its workforce and procurement activities
(which may include the entity’s current workforce and supplier diversity demographic profiles),
and (d) opportunities available at the entity that promote diversity (e.g., current employment and
procurement opportunities; forecasts of potential employment and procurement opportunities;
and the availability of mentorship and developmental programs for employees and contractors).
The individual entity would determine the type and extent of information that demonstrates its
progress toward achieving diversity and inclusion. The disclosure of information associated with
the Transparency Standard is voluntary and no specific information is required to be disclosed to
the public by the agencies. In addition, the Policy Statement’s Joint Standards include a SelfAssessment Standard, which encourages a regulated entity, in a manner reflective of its size and
other characteristics, to voluntarily (a) conduct an annual self-assessment of its diversity policies
and practices, (b) monitor and evaluate its performance under its diversity policies and practices
on an ongoing basis, (c) provide information pertaining to its self-assessment to the OMWI

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Director of its primary federal financial regulator, and (d) publish information pertaining to its
efforts with respect to the Joint Standards.
In 2016, in collaboration with the agencies, the Board supplied a reporting template that
Board-regulated entities could opt to use to assist with reporting information to address the
“Entities’ Self-Assessment” standard. The reporting template (1) asks for general information
about a respondent, (2) includes a checklist of the standards set forth in the Policy Statement,
(3) seeks additional diversity data, and (4) provides an opportunity for a respondent to provide
other information regarding or comment on the self-assessment of its diversity policies and
practices. The Board added this reporting template to the voluntary information collections
associated with the Policy Statement previously approved by OMB,4 and the use of it is
voluntary.
Respondent Panel
The respondent panel comprises all financial institutions regulated by the Federal
Reserve.
Revisions to the FR 2100
With respect to the reporting template, the Board clarified the confidentiality language in
the “Use of Information” section by stating that if a regulated entity submits confidential
commercial information that is both customarily and actually treated as private by the entity, the
entity should separately designate such information as “confidential commercial information,” as
appropriate, and that the Board will treat such designated information as confidential to the
extent permitted by law, including the Freedom of Information Act (5 U.S.C. § 552). The Board
also deleted the Yes/No boxes in Section 5 (Institution’s Self-Assessment) and to ask the
institution to describe its practices during the assessment year. The Yes/No boxes are not
necessary as Section 5 of the reporting template already requests a description of the programs
that are proving successful as well as the challenges institutions are facing with their diversity
programs.
Time Schedule for Information Collection
The Board encourages its regulated institutions to provide their diversity policies and
practices, as well as information related to their self-assessments, to the Board and disclose such
information to the public on an annual basis.
Public Availability of Data
The agencies may publish information disclosed to them, such as best practices, in any
form that does not identify a particular entity or individual or disclose confidential business
information. Entities are encouraged to disclose their diversity policies and practices, as well as
information related to their self-assessments, to the public.
4

See 81 FR 66275, 66276 (September 27, 2016); 81 FR 89463, 89464 (December 12, 2016).

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Legal Status
The information collections contained within the Policy Statement, as well as the selfassessment reporting template, are authorized by section 342 of the Dodd-Frank Act (12 U.S.C. §
5452), which requires the Board’s OMWI Director to develop standards for assessing regulated
entities’ diversity policies and practices. The information collections associated with the Policy
Statement are voluntary, as is the use of the self-assessment reporting template.
The Transparency Standard, and a portion of the Self-Assessment Standard, call for
regulated entities to provide information to the public, so confidentiality is not an issue with
respect to those aspects of the Policy Statement. A regulated entity may provide self-assessment
material to the Board (including through use of the reporting template) that contains confidential
commercial information protected by exemption 4 of the Freedom of Information Act (5 U.S.C.
§ 552(b)(4)). If a regulated entity submits confidential commercial information, which is both
customarily and actually treated as private by the entity, the entity should separately designate
such information as “confidential commercial information,” as appropriate, and the Board will
treat such designated information as confidential to the extent permitted by law, including the
Freedom of Information Act (5 U.S.C. § 552). As noted in the Policy Statement, an entity’s
primary federal regulator may share information obtained from regulated entities with other
agencies, but the agencies will only publish information disclosed to them in a form that does not
identify a particular entity or individual or disclose confidential business information.
Consultation Outside the Agency
The agencies worked together to develop standards for assessing the diversity policies
and practices of their regulated entities. The Board will continue to reach out to the regulated
entities and other interested parties to discuss diversity and inclusion in the financial services
industry and share leading practices. The primary federal financial regulator will share
information with other agencies, when appropriate, to support coordination of efforts and to
avoid duplication.
Public Comments
On March 2, 2020, the Board published an initial notice in the Federal Register
(85 FR 12296) requesting public comment for 60 days on the extension, with revision, of the
FR 2100. The comment period for this notice expired on May 1, 2020. The Board did not receive
any comments. On June 29, 2020, the Board published a final notice in the Federal Register
(85 FR 38894).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2100 is 1,000
hours, and would remain unchanged with the revisions. The number of respondents is based on
the average number of FR 2100 reports received in the past two years. The FR 2100 includes a
disclosure provision for respondent institutions. The Board revised the FR 2100 information

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collection to account for this disclosure provision. These reporting and disclosure provisions
represent less than 1 percent of the Board’s total paperwork burden.
Estimated
Annual
number of
frequency
respondents5
125
1

Estimated
average hours
per response
8

Estimated
annual burden
hours
1,000

7
1

Total

875
125
1,000

Change

0

FR 2100
Current
Proposed
Reporting
Disclosure

125
125

1
1

The estimated total annual cost to the public for this information collection is
$57,750.6
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System is negligible.

5

Of these respondents, 2 are considered small entities as defined by the Small Business Administration (i.e., entities
with less than $600 million in total assets), https://www.sba.gov/document/support--table-size-standards. There are
no special accommodations given to mitigate the burden on small institutions.
6
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $20, 45% Financial Managers at
$71, 15% Lawyers at $70, and 10% Chief Executives at $93). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2019, published March 31, 2020, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

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