CFPB's Review of Diversity & Inclusion - Letters Issued

March 21, 2019 – Earlier this month, the CFPB reportedly sent letters to several financial institutions, 'inviting them' to provide self-assessments to report upon their progress surrounding Diversity & Inclusion (D&I).  This is according to a piece appearing in the National Law Review, written by  Dee Spagnuolo, a partner at the Ballard Spahr LLP national law firm.

You can find the full text of the news article HERE.

Essential Highlights:

  1.  Some of Ballard Spahr's own clients confirmed receiving the letters.
  2.  Letters were issued from the CFPB’s Office of Minority and Women Inclusion (OMWI).
  3.  Letters also requested contact information for the individuals leading their D&I efforts.
  4.  The letters reference the D&I standards issued in June 2015 by the CFPB’s OMWI and the OMWIs of the other federal financial regulatory agencies to implement Section 342 of the Dodd-Frank Act.

According to the Spagnuolo, contents of the CFPB’s letters appear to be consistent with the standards, the D&I self-assessment is voluntary and is also OUTSIDE of the supervisory process, and the intended use shall be to share industry best practices.

Using Vendor Surf to Quickly Find D&I Vendors

Vendor Surf, the first and ORIGINAL vendor search engine across mortgage and credit union ecosystems, makes finding ALL of your potential vendor partners simple and easy, especially D&I vendors.

For each and every vendor category on Vendor Surf, there is a 'Certifications' section for filtering your selections.  Within these certifications, as it relates to D&I, we modeled our filters to resemble designations cited by the American Mortgage Diversity Council.   The organization develops and provides tools and strategies to create an understanding and appreciation of individual differences in thought, experience, race, ethnicity, culture, religion, style, sexual orientation and gender identity.  You should check out all of their guides and reference materials.  Membership opportunities also available.

Such D&I filters on Vendor Surf include:

  • Small Business Enterprise (SBE); Certified by SBA
  • LGBT-Owned Business Enterprise certified
  • Woman or Minority Owned Enterprise (MWBE)
  • 8(a) Business Development program
  • Historically Underutilized Business Zones 

Vendor Surf also has the following search filters for veteran-owned businesses:

  • Veteran Business Enterprise (VBE)
  • Disabled Veteran Business – Owned Enterprise (DVBE)
  • Service-Disabled Veteran-Owned Small Business (SDVOSB)

Supplier diversity is important far beyond ensuring you give respective regulatory bodies a decent 'scorecard' on your progress.  Instead, you stand to gain a much-needed variety of thought and perspective, expanding across a broader population.  That often translates into innovation and new product or service offerings.  This country runs on, and thrives because of, small and diverse businesses.

According to DiversityInc.'s 2016 ranking, many of the world’s largest companies – including Accenture, AT&T, and Walmart – are heavily investing in the power of minority-owned, women-owned, veteran-owned, LGBT-owned, and SBA-defined small-business vendors.

Finally, research shows that companies that embrace diversity are more profitable than companies that don’t:

"On average, supplier diversity programs add $3.6 million to the bottom line for every $1 million in procurement operation costs,” writes Lindsay Clark, referencing a 2015 study by The Hackett Group. “The high return on investment is undeniable... A positive ROI that boosts socially conscious reputation should push supplier diversity to the forefront of business strategy."

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