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In December 2013, CDIA wrote to the CFPB to comment on the Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies (“Proposed Policy Statement” or “Statement”).
The proposal was issued by the OCC, the Board of Governors of the Federal Reserve System, the FDIC, the NCUA, the CFPB, and the SEC.
CDIA’s comment makes several points. First, we thank the Bureau and the other Agencies for preventing the Proposed Policy Statement from creating new EEO law and for not imposing any new legal requirements on regulated entities. Second, CDIA and its members recognize the value of a diverse workforce and we welcome the spirit of policies that promote diversity. Third, while the Dodd-Frank Act sets a clear prohibition on the Agencies from enforcing civil rights laws, this full prohibition is not but should be completely recognized in the Proposed Policy Statement.
CDIA’s letter added that there is a difference between not using the Proposed Policy Statement in the “examination or supervision process” (as in the Statement) and not “enforce[ing] statutes, regulations, or executive orders pertaining to civil rights” (as in the Dodd-Frank Act). The Proposed Policy Statement should fully reflect the limits imposed by the Dodd-Frank Act to make clear that not only will the Agencies not use the examination or supervision process in connection with these proposed standards, but that the Agencies will also not enforce statutes, regulations, or executive orders pertaining to civil rights.
A final policy was issued in June 2015.