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United States Government Accountability Office: 
GAO: 

Report to the Ranking Member, Committee on Financial Services, U.S. 
House of Representatives: 

April 2013: 

Diversity Management: 

Trends and Practices in the Financial Services Industry and Agencies 
after the Recent Financial Crisis: 

GAO-13-238: 

GAO Highlights: 

Highlights of GAO-13-238, a report to the Ranking Member, Committee on 
Financial Services, U.S. House of Representatives. 

Why GAO Did This Study: 

As the U.S. workforce has become increasingly diverse, many private-
and public-sector entities recognize the importance of recruiting and 
retaining minorities and women for management-level positions to 
improve their business. The 2007-2009 financial crisis has renewed 
questions about commitment within the financial services industry 
(e.g., banking and securities) to workforce diversity. The Dodd-Frank 
Act required that eight federal financial agencies and the Federal 
Reserve Banks implement provisions to support workforce and contractor 
diversity. GAO was asked to review trends and practices since the 
beginning of the financial crisis. This report examines (1) workforce 
diversity in the financial services industry, the federal financial 
agencies, and Reserve Banks, from 2007 through 2011 and (2) efforts of 
the agencies and Reserve Banks to implement workforce diversity 
practices under the Dodd-Frank Act, including contracting. GAO 
analyzed federal datasets and documents and interviewed industry 
representatives and officials from the federal financial agencies and 
Reserve Banks. 

What GAO Found: 

Management-level representation of minorities and women in the 
financial services industry and among federal financial agencies and 
Federal Reserve Banks (Reserve Banks) has not changed substantially 
from 2007 through 2011. Industry representation of minorities in 2011 
was higher in lower-level management positions—about 20 percent—
compared to about 11 percent of senior-level manager positions. 
Industry representation of women at the overall management level 
remained at about 45 percent. Agency representation of minorities at 
the senior management level in 2011 ranged from 6 percent to 17 
percent and from 0 percent to 44 percent at the Reserve Banks. Women’s 
representation ranged from 31 to 47 percent at the agencies and from 
15 to 58 percent at the Reserve Banks. Officials said the main 
challenge to improving diversity was identifying candidates, noting 
that minorities and women are often underrepresented in both internal 
and external candidate pools. 

Figure: Senior Management-Level Diversity, 2011: 

[Refer to PDF for image: stacked vertical bar graph] 

Industry: 
Men: 72%; 
Women: 28%; 
White: 89%; 
Minority: 11%. 

Agencies: 
Men: 55%; 
Women: 55%; 
White: 83%; 
Minority: 17%. 

Reserve Banks: 
Men: 62%; 
Women: 38%; 
White: 86%; 
Minority: 14%. 

Source: GAO analysis of the financial services industry EEOC data and 
agency and Reserve Banks reports. 

[End of figure] 

In response to the requirements in the Dodd-Frank Wall Street and 
Consumer Protection Act (Dodd-Frank Act), in 2011 federal financial 
agencies and Reserve Banks began to report annually on the recruitment 
and retention of minorities and women and other diversity practices. 
They all have established Offices of Minority and Women Inclusion 
(OMWI) as required. Many agencies and Reserve Banks indicated they had 
recruited from minority-serving institutions and partnered with 
organizations focused on developing opportunities for minorities and 
women, and most described plans to expand these activities. Some used 
employee surveys or recruiting metrics to measure the progress of 
their initiatives, as suggested by leading diversity practices, but 
OMWIs are not required to include this type of information in the 
annual reports to Congress. Better reporting of measurement efforts 
will provide Congress, agency officials, and other stakeholders 
additional insights on the effectiveness of diversity practices and 
demonstrate how agencies and Reserve Banks are following a leading 
diversity practice. Most federal financial agencies and Reserve Banks 
are in the early stages of implementing the contracting requirements 
required under the act. For example, most now include a provision in 
contracts for services requiring contractors to make efforts to ensure 
the fair inclusion of women and minorities in their workforce and 
subcontracted workforce and have established ways to evaluate 
compliance. The proportion of an agency’s dollars awarded or a Reserve 
Bank’s dollars paid to minority- or woman-owned businesses reported in 
2011 OMWI reports ranged between 3 percent and 38 percent. 

What GAO Recommends: 

Each agency and Reserve Bank should include in its annual OMWI report 
to Congress efforts to measure the progress of its diversity 
practices. The agencies and Reserve Banks agreed to include this 
information in the annual OMWI reports. Additionally, some agencies 
and the Reserve Banks described steps they have taken or plan to take 
to address the recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-13-238]. For more 
information, contact Daniel Garcia-Diaz at (202) 512-8678 or 
GarciaDiazD@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Industry Diversity Levels Remained about the Same from 2007 through 
2011: 

Agency and Reserve Bank Workforce Diversity Varied, and Officials 
Reported Difficulty Identifying Diverse Candidates: 

Dodd-Frank Requirements Are Being Implemented, but Enhanced Reporting 
of Efforts to Measure Progress Is Needed: 

Procedures to Meet Dodd-Frank Inclusive Contracting Requirements Are 
Largely in Place: 

Conclusion: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Additional Analysis of the Financial Services Industry: 

Appendix III: Additional Analysis of Overall Workforce Diversity at 
Agencies and Reserve Banks: 

Appendix IV: Representation of Minorities and Women at Federal 
Financial Agencies and Reserve Banks: 

Appendix V: Comments from the Consumer Financial Protection Bureau: 

Appendix VI: Comments from the Federal Reserve Banks: 

Appendix VII: Comments from the Federal Reserve Board: 

Appendix VIII: Comments from the Federal Deposit Insurance Corporation: 

Appendix IX: Comments from the Federal Housing Finance Agency: 

Appendix X: Comments from the National Credit Union Administration: 

Appendix XI: Comments from the Comptroller of the Currency: 

Appendix XII: Comments from the Securities and Exchange Commission: 

Appendix XIII: Comments from the Treasury Department: 

Appendix XIV: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Federal Financial Agencies Subject to Dodd-Frank Act Section 
342: 

Table 2: Percentage of Students Enrolled in MBA Degree Programs at 
AACSB Member Schools in the United States by Race/Ethnicity, 2007-2011: 

Table 3: OMWI Staffing Levels for Federal Financial Agencies, as of 
January 2013: 

Table 4: OMWI Staffing Levels for Reserve Banks, as of January 2013: 

Table 5: Federal Financial Agency and Reserve Bank Implementation of 
Dodd-Frank Act Section 342 Diversity Recruitment Requirements: 

Table 6: Estimated Percentages and Standard Errors for Race/Ethnicity 
in Management Positions in the Financial Services Industry Using the 
Current Population Survey (CPS), 2007-2011: 

Table 7: Percentage of Minorities among Senior Management-Level 
Employees at Seven Federal Financial Agencies, 2007-2011: 

Table 8: Percentage of Minorities among Senior Management-Level 
Employees at the 12 Reserve Banks, 2007-2011: 

Table 9: Percentage of Women among Senior Management-Level Employees 
at Seven Federal Financial Agencies, 2007-2011: 

Table 10: Percentage of Women among Senior Management-Level Employees 
at the 12 Reserve Banks, 2007-2011: 

Table 11: Percentage of Minorities among All Employees at Seven 
Federal Financial Agencies, 2007-2011: 

Table 12: Percentage of Minorities among All Employees at the 12 
Reserve Banks, 2007-2011: 

Table 13: Percentage of Women among All Employees at Seven Federal 
Financial Agencies, 2007-2011: 

Table 14: Percentage of Women among All Employees at the 12 Reserve 
Banks, 2007-2011: 

Figures: 

Figure 1: Percentage of White and Minority Managers in the Financial 
Services Industry, 2007-2011: 

Figure 2: Percentage of Whites and Minorities in First-and Mid-Level 
Management and Senior Management Positions in the Financial Services 
Industry, 2007-2011: 

Figure 3: Percentage of Specific Races/Ethnicities in the Financial 
Services Industry in Overall Management Positions, 2007-2011: 

Figure 4: Percentage of Specific Races/Ethnicities in the Financial 
Services Industry at Various Management Levels, 2007-2011: 

Figure 5: Percentage of Men and Women in Management Positions in the 
Financial Services Industry, 2007-2011: 

Figure 6: Percentage of White and Minority Men and White and Minority 
Women in Management Positions in the Financial Services Industry, 2007-
2011: 

Figure 7: Percentage of Women in the Financial Services Industry by 
Management Level and Race/Ethnicity, 2007-2011: 

Figure 8: Percentage of Whites/Minorities and Men/Women at Financial 
Services Firms of Different Sizes, 2007-2011: 

Figure 9: Percentage of Whites/Minorities and Men/Women in Various 
Financial Services Industry Workforce Positions, 2007-2011: 

Figure 10: Percentage of Minorities among Senior Management-Level 
Employees at Six Federal Financial Agencies, 2007-2011: 

Figure 11: Percentage of Minorities among Senior Management-Level 
Employees at the 12 Reserve Banks, 2007-2011: 

Figure 12: Percentage of Women among Senior Management-Level Employees 
at Six Federal Financial Agencies, 2007-2011: 

Figure 13: Percentage of Women among Senior Management-Level Employees 
at the 12 Reserve Banks, 2007-2011: 

Figure 14: Dollar Amount and Percentage of Total Awarded to Minority-
and Women-Owned Businesses (MWOB) by Agency, 2011: 

Figure 15: Dollar Amount and Percentage of Total Paid to Minority-and 
Women-Owned Businesses (MWOB) by Reserve Bank, 2011: 

Figure 16: Percentage of Minority Women and Minority Men in Various 
Industry Workforce Positions in the Financial Services Industry, 2007-
2011: 

Figure 17: Percentage of Whites/Minorities and Men/Women in Various 
Sectors of the Financial Services Industry, 2007-2011: 

Figure 18: Percentage of Minorities among All Employees at Seven 
Federal Financial Agencies, 2007-2011: 

Figure 19: Percentage of Women among All Employees at Seven Federal 
Financial Agencies, 2007-2011: 

Figure 20: Percentage of Minorities among All Employees at the 12 
Reserve Banks, 2007-2011: 

Figure 21: Percentage of Women among All Employees at the 12 Reserve 
Banks, 2007-2011: 

Abbreviations: 

AACSB: Association to Advance Collegiate Schools of Business: 

CFPB: Bureau of Consumer Financial Protection, known as the Consumer 
Financial Protection Bureau: 

CPS: Current Population Survey: 

Dodd-Frank Act: Dodd-Frank Wall Street Reform and Consumer Protection 
Act: 

EEO: equal employment opportunity: 

EEO-1: Employer Information Report: 

EEOC: Equal Employment Opportunity Commission: 

FAR: Federal Acquisition Regulation: 

FDIC: Federal Deposit Insurance Corporation: 

Federal Reserve Board: Board of Governors of the Federal Reserve 
System: 

FHFA: Federal Housing Finance Agency: 

FSOC: Financial Stability Oversight Council: 

HERA: Housing and Economic Recovery Act of 2008: 

MWOB: minority- and women-owned business: 

MBA: Master of Business Administration: 

MD-715: EEOC Management Directive 715: 

NAICS: North American Industry Classification System: 

NCUA: National Credit Union Administration: 

NPO: National Procurement Office: 

OCC: Office of the Comptroller of the Currency: 

OMWI: Office of Minority and Women Inclusion: 

Reserve Banks: Federal Reserve Banks: 

SBA: Small Business Administration: 

SBS: security-based swap: 

SEC: Securities and Exchange Commission: 

Treasury: Departmental Offices of the Department of the Treasury: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

April 16, 2013: 

The Honorable Maxine Waters: 
Ranking Member: 
Committee on Financial Services: 
House of Representatives: 

Dear Ms. Waters: 

As the U.S. workforce has become increasingly diverse, many private 
and public-sector organizations have recognized the importance of 
recruiting and retaining minorities and women for key positions to 
improve their business or organizational performance. Studies have 
associated a diversity of perspectives in organizations with 
innovation. However, congressional hearings have raised questions 
about diversity in the workforce of the financial services industry, 
which provides services that are essential to the continued growth and 
economic recovery of the country. During hearings on the financial 
services industry between 2004 and 2010, congressional members and 
witnesses expressed concern about the level of inclusion of women and 
minorities in the industry, particularly in key management-level 
positions.[Footnote 1] The 2007-2009 financial crisis has renewed 
concerns about commitment within the financial services industry to 
workforce diversity and the number of federal contracting 
opportunities available to minority- and women-owned businesses. The 
Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank 
Act) included provisions requiring selected federal financial agencies 
and Federal Reserve Banks (Reserve Banks) each to establish an Office 
of Minority and Women Inclusion (OMWI).[Footnote 2] The act required 
that these agencies and Reserve Banks establish the new diversity and 
inclusion offices to replace existing diversity programs by January 
2011 and to begin addressing a number of other requirements in the 
act. [Footnote 3] 

This report updates our previous work by discussing changes in 
management-level diversity or diversity practices used in this 
industry since the beginning of the financial crisis in 2007. It also 
reviews the implementation of requirements in section 342 of the Dodd-
Frank Act on workforce diversity. Specifically, our objectives were to 
discuss (1) what available data show about how the diversity of the 
financial services industry workforce and how diversity practices by 
the industry have changed from 2007 through 2011; (2) what available 
data show about how diversity in the workforces of the federal 
financial agencies and the Reserve Banks has changed from 2007 through 
2011; (3) how these federal financial agencies and Reserve Banks are 
implementing workforce diversity practices under section 342 of the 
Dodd-Frank Act, including the extent to which their workforce 
diversity practices have changed since the financial crisis; and (4) 
the status of federal financial agencies’ and Reserve Banks’ 
implementation of the contracting provisions of the Dodd-Frank Act 
related to the inclusion of women and minorities. 

To describe how diversity in the financial services industry and how 
the diversity practices it uses have changed from 2007 through 2011, 
we analyzed 2007-2011 workforce data from the Equal Employment 
Opportunity Commission’s (EEOC) Employer Information Report (EEO-1) 
and from the Current Population Survey (CPS) produced by the Bureau of 
the Census and the Bureau of Labor Statistics. Through a review of 
documentation, electronic testing, and interviews with knowledgeable 
officials, we found these data sufficiently reliable for our use. We 
conducted a literature review to identify academic and industry 
studies on financial services workforce diversity, and we interviewed 
10 industry representatives on these issues. 

To review changes to the representation of women and minorities in the 
workforces of the agencies and Reserve Banks, we analyzed data the 
agencies submitted to EEOC from 2007 through 2011 in annual Equal 
Employment Opportunity Program Status Reports required by EEOC’s MD-
715 and analyzed EEO-1 reports provided by the 12 Reserve Banks. 
[Footnote 4] We assessed the reliability of these data by conducting 
electronic testing, reviewing agency documentation, and interviewing 
agency officials. We determined that the data were sufficiently 
reliable for our use. We reviewed agency and Reserve Bank 
documentation of efforts to respond to the Dodd-Frank Act 
requirements, including annual OMWI reports to Congress. Additionally, 
we interviewed agency and Reserve Bank officials on changes in the 
inclusion of women and minorities in their workforces and any changes 
in the practices they used to further workforce diversity goals. 

To determine the extent to which agencies and Reserve Banks are 
implementing the requirements of the Dodd-Frank Act regarding the 
inclusion of women and minorities in contracting, we reviewed annual 
OMWI reports submitted to Congress and interviewed officials on their 
efforts in this area. We collected and reviewed agency documentation 
of procedures developed to address the act’s requirements, such as 
policy manuals, contract provisions related to promoting a diverse 
workforce, process workflows, and technical assistance materials. 

We conducted this performance audit from January 2012 through April 
2013 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

The financial services industry is a major source of employment in the 
United States. EEOC data we obtained and analyzed showed that 
financial services firms we reviewed for this work employed more than 
2.9 million people in 2011. We defined the financial services industry 
to include the following sectors: 

* depository credit institutions, which include commercial banks, 
thrifts (savings and loan associations and savings banks), and credit 
unions; 

* holdings and trusts, which include investment trusts, investment 
companies, and holding companies; 

* nondepository credit institutions, which extend credit in the form 
of loans and include federally sponsored credit agencies, personal 
credit institutions, and mortgage bankers and brokers; 

* the securities sector, which is composed of a variety of firms and 
organizations that bring together buyers and sellers of securities and 
commodities, manage investments, and offer financial advice; and: 

* the insurance sector, including carriers and insurance agents that 
provide protection against financial risks to policyholders in 
exchange for the payment of premiums. 

Financial Services Industry and Diversity: 

We previously conducted work on the challenges faced in the financial 
sector for promoting and retaining a diverse workforce, focusing on 
private-sector firms.[Footnote 5] In 2010, we reported that overall 
diversity at the management level in the financial services industry 
did not change substantially from 1993 through 2008 and that diversity 
in senior positions was limited. We also found that without a 
sustained commitment among financial services firms to overcoming 
challenges to recruiting and retaining minority candidates and 
obtaining "buy-in" from key employees, limited progress would be 
possible in fostering a more diverse workplace. 

In a 2005 report, we defined diversity management as a process 
intended to create and maintain a positive work environment that 
values individuals' similarities and differences, so that all can 
reach their potential and maximize their contributions to an 
organization's strategic goals and objectives.[Footnote 6] We also 
identified a set of nine leading diversity management practices that 
should be considered when an organization is developing and 
implementing diversity management. They are (1) commitment to 
diversity as demonstrated and communicated by an organization's top 
leadership; (2) the inclusion of diversity management in an 
organization's strategic plan; (3) diversity linked to performance, 
making the case that a more diverse and inclusive work environment 
could help improve productivity and individual and organizational 
performance; (4) measurement of the impact of various aspects of a 
diversity program; (5) management accountability for the progress of 
diversity initiatives; (6) succession planning; (7) recruitment; (8) 
employee involvement in an organization's diversity management; and 
(9) training for management and staff about diversity management. 

Diversity Requirements under Section 342 of the Dodd-Frank Act: 

Section 342 of the Dodd-Frank Act required specific federal financial 
agencies and Reserve Banks each to establish, by January 21, 2011, an 
OMWI, responsible for matters relating to diversity in management, 
employment, and business activities.[Footnote 7] Table 1 describes the 
affected agencies. 

Table 1: Federal Financial Agencies Subject to Dodd-Frank Act Section 
342: 

Agency: Bureau of Consumer Financial Protection (CFPB); 
Function: Commonly known as the Consumer Financial Protection Bureau, 
writes rules to implement federal consumer financial law across banks 
and nonbanks; supervises for consumer protection purposes banks, 
thrifts, and credit unions with over $10 billion in assets and their 
affiliates, as well as nonbank mortgage-related firms, private student 
lenders, payday lenders, and certain other larger consumer financial 
companies; and enforces federal consumer financial law with respect to 
supervised entities and other nonbank entities. 

Agency: Federal Deposit Insurance Corporation (FDIC); 
Function: Regulates FDIC-insured state-chartered banks that are not 
members of the Federal Reserve System, as well as federally insured 
state savings banks and thrifts; insures the deposits of all banks and 
thrifts that are approved for federal deposit insurance; and resolves 
all failed insured banks and thrifts and may resolve certain bank 
holding companies and nonbank financial companies. 

Agency: Federal Housing Finance Agency (FHFA); 
Function: Supervises and regulates Fannie Mae, Freddie Mac, and the 12 
Federal Home Loan Banks and their Office of Finance. Acts as 
conservator for Fannie Mae and Freddie Mac. 

Agency: Board of Governors of the Federal Reserve System (Federal 
Reserve Board); 
Function: Regulates state-chartered banks that opt to be members of 
the Federal Reserve System, bank holding companies and certain 
subsidiaries, thrift holding companies, securities holding companies, 
Edge and agreement corporations, U.S. branches of foreign banks, any 
firm that is designated as systemically significant by the Financial 
Stability Oversight Council (FSOC), and payment, clearing, and 
settlement systems designated as systemically significant by FSOC, 
unless regulated by SEC or the Commodity Futures Trading Commission. 

Agency: National Credit Union Administration (NCUA); 
Function: Charters and supervises federally chartered or insured 
credit unions and operates the National Credit Union Share Insurance 
Fund, which insures savings in federal and most state-chartered credit 
unions. 

Agency: Office of the Comptroller of the Currency (OCC); 
Function: Charters and regulates national banks and federal thrifts 
and U.S. federal branches of foreign banks. 

Agency: Securities and Exchange Commission (SEC); 
Function: Regulates securities exchanges, broker-dealers, investment 
companies, investment advisers, nationally recognized statistical 
rating organizations, security-based swap (SBS) dealers, major SBS 
participants, and SBS execution facilities. 

Agency: Departmental Offices of the Department of the Treasury 
(Treasury); 
Function: The Department of the Treasury is organized into two major 
components: the departmental offices and the operating bureaus. The 
departmental offices are primarily responsible for the formulation of 
policy and management of the department as a whole, and include 
domestic finance, economic policy, international affairs, and others. 

Source: GAO review of agency documentation. 

[End of table] 

The act's diversity provisions also apply to the Reserve Banks. The 
Federal Reserve System consists of a central governmental agency, the 
Board of Governors, in Washington, D.C., and 12 regional Reserve 
Banks. The 12 Reserve Banks are each responsible for a particular 
geographic area or district of the United States. They are located in 
Atlanta, Boston, Chicago, Cleveland, Dallas, Kansas City, Minneapolis, 
New York, Philadelphia, Richmond, San Francisco, and St. Louis. Unlike 
the Federal Reserve Board, the Reserve Banks are not federal agencies. 
Each Reserve Bank is a federally chartered corporation with a board of 
directors and member banks who are stockholders in the Reserve Bank. 
Under the Federal Reserve Act, Reserve Banks are subject to the 
general supervision of the Federal Reserve Board.[Footnote 8] 

The act's diversity provisions require the director of each OMWI to 
develop standards for (1) equal employment opportunity and the racial, 
ethnic and gender diversity of the workforce and senior management for 
the agency; (2) increased participation of minority-and women-owned 
businesses in the programs and contracts of the agency, including 
standards for coordinating technical assistance to such businesses; 
and (3) assessing the diversity policies and practices of entities 
regulated by the agency. It also provides that each OMWI director 
advise his or her agency on the impact of agency policies and 
regulations on minority-and women-owned businesses.[Footnote 9] 

The act also outlines steps the specific agencies and Reserve Banks 
should take to seek workforce diversity at all levels of their 
organizations. Among other things, these steps include recruiting from 
colleges serving primarily minority populations, sponsoring and 
recruiting at job fairs in urban communities, and advertising 
positions in newspapers and magazines oriented toward minorities and 
women. 

In addition, the act provides that each OMWI director develop and 
implement standards and procedures to ensure, to the maximum extent 
possible, the fair inclusion and utilization of minorities, women, and 
minority-and women-owned businesses in all business and activities of 
the agency at all levels, including in procurement, insurance, and all 
types of contracts. Agency procedures for reviewing and evaluating 
applicable contract proposals and for hiring service providers should 
include a component that gives consideration to applicant diversity, 
to the extent consistent with applicable laws.[Footnote 10] 
Additionally, the act mandates that the OMWI director develop 
procedures to determine whether contractors, or subcontractors when 
applicable, have made a good faith effort to include minorities and 
women in their workforces. It requires that each OMWI director 
recommend that contracts be terminated if they determine that an 
agency contractor, and as applicable, a subcontractor has failed to 
make a good faith effort to include minorities and women in their 
workforce. Upon receipt of such a recommendation, the head of an 
agency may terminate the contract, make a referral to an office in the 
Department of Labor, or take other appropriate action. 

Finally, the act requires each OMWI to submit to Congress an annual 
report detailing the actions taken by the agency and the OMWI to 
comply with the provisions in section 342. The annual reports are 
required to include, among other things, annual amounts paid to 
contractors, including the percentage of the amounts that were paid to 
minorities, women, and minority-and women-owned businesses; any 
challenges in contracting with qualified minority-and women-owned 
businesses; any challenges in hiring qualified minority and women 
employees; and any other information, findings, conclusions, and 
recommendations for legislative or agency action as the OMWI director 
determines appropriate. 

Industry Diversity Levels Remained about the Same from 2007 through 
2011: 

Diversity has remained about the same at the management level in terms 
of the representation of both minorities and women, while industry 
representatives noted the continued use of leading diversity practices 
and some challenges. According to EEOC data, the representation of 
minorities at the management level stood at 19 percent in 2011. The 
representation of women in management remained at about 45 percent, 
according to EEOC data. The nine leading diversity practices that we 
previously identified in 2005 remain relevant today, according to 
industry representatives with whom we spoke. Industry representatives 
also noted some challenges, such as the difficulty in recruitment 
because of a limited supply of diverse candidates. 

Diversity in the Financial Services Industry Remained about the Same 
at the Management Level from 2007 through 2011: 

At the overall management level, the representation of minorities 
increased from 17.3 percent to 19 percent from 2007 through 2011 
according to EEOC data we obtained, which are reported by financial 
services firms (see figure 1).[Footnote 11] While this is not a 
substantial increase, it shows a continued upward trend from our 2006 
report, in which data showed that management-level representation by 
minorities increased from 11.1 percent to 15.5 percent from 1993 
through 2004.[Footnote 12] 

Figure 1: Percentage of White and Minority Managers in the Financial 
Services Industry, 2007-2011: 

[Refer to PDF for image: multiple line graph] 

Year: 2007; 
White EEOC: 82.7%; 
Minority EEOC: 17.3%. 

Year: 2008; 
White EEOC: 82.1%; 
Minority EEOC: 17.9%. 

Year: 2009; 
White EEOC: 82.1%; 
Minority EEOC: 17.9%. 

Year: 2010; 
White EEOC: 81.6%; 
Minority EEOC: 18.4%. 

Year: 2011; 
White EEOC: 81%; 
Minority EEOC: 19%. 

Source: GAO analysis of EEOC data. 

[End of figure] 

The representation of minorities varied among management positions, 
which EEOC splits into two categories: (1) first-and mid-level 
officials and managers and (2) senior-level officials and managers. In 
2011, the representation of minorities among first-and mid-level 
managers stood at 20.4 percent, about 1 percentage point higher to the 
representation of minorities among all management positions, according 
to EEOC data (see figure 2). In contrast, at the senior management 
level, representation of minorities was 10.8 percent in 2011, about 8 
percentage points below their representation among all management 
positions; yet representation of minorities in first-and mid-level 
management positions consistently increased from 18.7 percent to 20.4 
percent over the 5-year period. First-and mid-level management 
positions may serve as an internal pipeline in an organization through 
which minority candidates could move into senior management positions. 

Figure 2: Percentage of Whites and Minorities in First-and Mid-Level 
Management and Senior Management Positions in the Financial Services 
Industry, 2007-2011: 

[Refer to PDF for image: multiple line graph] 

Year: 2007; 
White senior: 89.4%; 
White senior first- and mid-level: 81.3%; 
Minority senior level: 10.6%; 
Minority first- and mid-level: 18.7%. 

Year: 2008; 
White senior: 89.5%; 
White senior first- and mid-level: 80.8%; 
Minority senior level: 10.5%; 
Minority first- and mid-level: 19.2%. 

Year: 2009; 
White senior: 90%; 
White senior first- and mid-level: 80.7%; 
Minority senior level: 10%; 
Minority first- and mid-level: 19.3%. 

Year: 2010; 
White senior: 89.9%; 
White senior first- and mid-level: 80.2%; 
Minority senior level: 10.1%; 
Minority first- and mid-level: 19.8%. 

Year: 2011; 
White senior: 89.2%; 
White senior first- and mid-level: 79.6%; 
Minority senior level: 10.8%; 
Minority first- and mid-level: 20.4%. 

Source: GAO analysis of EEOC data. 

[End of figure] 

Similar to the total representation of minorities across all 
management positions, specific races/ethnicities have not changed 
significantly, but EEOC data show slight variations of representation 
for specific races/ethnicities. For example, the representation of 
African Americans decreased from 6.5 percent in 2007 to 6.3 percent in 
2011, according to EEOC data (see figure 3). In contrast, 
representation of most other races/ethnicities increased, and the 
highest increase was in the representation of Asians, from 5.4 percent 
to 6.5 percent over the same time period. 

Figure 3: Percentage of Specific Races/Ethnicities in the Financial 
Services Industry in Overall Management Positions, 2007-2011: 

[Refer to PDF for image: multiple line graph] 

Year: 2007; 
African-American: 6.5%; 
Hispanics: 4.8%; 
Asian: 5.4%; 
Other: 0.6%; 
Total Minority: 17.3%. 

Year: 2008; 
African-American: 6.5%; 
Hispanics: 4.8%; 
Asian: 5.7%; 
Other: 0.8%; 
Total Minority: 17.9%. 

Year: 2009; 
African-American: 6.4%; 
Hispanics: 4.8%; 
Asian: 5.8%; 
Other: 0.9%; 
Total Minority: 17.9%. 

Year: 2010; 
African-American: 6.3%; 
Hispanics: 5%; 
Asian: 6.1%; 
Other: 0.9%; 
Total Minority: 18.4%. 

Year: 2011; 
African-American: 6.3%; 
Hispanics: 5.2%; 
Asian: 6.5%; 
Other: 1%; 
Total Minority: 19%. 

Source: GAO analysis of EEOC data. 

[End of figure] 

From 2007 to 2011, the representation of African Americans went down 
in both management levels, while the representation of other specific 
races/ethnicities either increased or remained stable (see figure 4). 
At the senior management level, the representation of Asians remained 
stable at about 4.1 percent from 2007 through 2011. However, the 
representation of African Americans in senior management positions 
decreased from 3.1 percent to 2.7 percent, and the representation of 
Hispanics increased from 3 percent to 3.3 percent. Among first-and mid-
level management positions, the representation of Asians increased 
from 5.6 percent to 6.9 percent and the representation of Hispanics 
increased from 5.2 percent to 5.5 percent, while the representation of 
African Americans decreased from 7.2 percent to 6.9 percent. 

Figure 4: Percentage of Specific Races/Ethnicities in the Financial 
Services Industry at Various Management Levels, 2007-2011: 

[Refer to PDF for image: multiple line graph] 

Year: 2007; 
African-American senior level: 3.1%; 
Hispanic senior level: 3%; 
Asian senior level: 4.1%; 
Other senior level: 0.4%; 
Total minority senior level: 10.6%; 
African-American first- and mid-level: 7.2%; 
Hispanic first- and mid-level: 5.2%; 
Asian first- and mid-level: 5.6%; 
Other first- and mid-level: 0.6%; 
Total minority first- and mid-level: 18.7%. 

Year: 2008; 
African-American senior level: 3%; 
Hispanic senior level: 3.1%; 
Asian senior level: 3.8%; 
Other senior level: 0.6%; 
Total minority senior level: 10.5%; 
African-American first- and mid-level: 7.2%; 
Hispanic first- and mid-level: 5.2%; 
Asian first- and mid-level: 6.1%; 
Other first- and mid-level: 0.8%; 
Total minority first- and mid-level: 19.2%. 

Year: 2009; 
African-American senior level: 2.9%; 
Hispanic senior level: 2.8%; 
Asian senior level: 3.7%; 
Other senior level: 0.7%; 
Total minority senior level: 10.0%; 
African-American first- and mid-level: 7.1%; 
Hispanic first- and mid-level: 5.2%; 
Asian first- and mid-level: 6.1%; 
Other first- and mid-level: 0.9%; 
Total minority first- and mid-level: 19.3%. 

Year: 2010; 
African-American senior level: 2.7%; 
Hispanic senior level: 2.9%; 
Asian senior level: 3.8%; 
Other senior level: 0.7%; 
Total minority senior level: 10.1%; 
African-American first- and mid-level: 6.9%; 
Hispanic first- and mid-level: 5.3%; 
Asian first- and mid-level: 6.5%; 
Other first- and mid-level: 1%; 
Total minority first- and mid-level: 19.8%. 

Year: 2011; 
African-American senior level: 2.7%; 
Hispanic senior level: 3.3%; 
Asian senior level: 4.1%; 
Other senior level: 0.7%; 
Total minority senior level: 10.8%; 
African-American first- and mid-level: 6.9%; 
Hispanic first- and mid-level: 5.5%; 
Asian first- and mid-level: 6.9%; 
Other first- and mid-level: 1.1%; 
Total minority first- and mid-level: 20.4%. 

Source: GAO analysis of EEOC data. 

[End of figure] 

Over the same 5-year period, the representation of women at the 
management level remained at about 45 percent in EEOC data, which show 
a slight decrease from 45.1 percent to 44.7 percent (see figure 5). In 
2006, we reported an increase with representation of women at about 
42.9 percent in 1993 to about 45.8 percent in 2004.[Footnote 13] 

Figure 5: Percentage of Men and Women in Management Positions in the 
Financial Services Industry, 2007-2011: 

[Refer to PDF for image: stacked vertical bar graph] 

Year: 2007; 
Female: 45.1%; 
Male: 54.9%. 

Year: 2008; 
Female: 45.3%; 
Male: 54.7%. 

Year: 2009; 
Female: 45.3%; 
Male: 54.7%. 

Year: 2010; 
Female: 45%; 
Male: 55%. 

Year: 2011; 
Female: 44.7%; 
Male: 55.3%. 

Source: GAO analysis of EEOC data. 

[End of figure] 

Among all women in management positions, EEOC data showed that the 
representation of minority women increased, from 20.4 percent to 22 
percent over the same 5-year period (see figure 6). In addition, EEOC 
data show that the representation of minority men increased from 14.8 
percent to 16.6 percent. 

Figure 6: Percentage of White and Minority Men and White and Minority 
Women in Management Positions in the Financial Services Industry, 2007-
2011: 

[Refer to PDF for image: 2 multiple line graphs] 

Men: 

Year: 2007; 
Minority men: 14.8%; 
White men: 85.2%. 

Year: 2008; 
Minority men: 15.3%; 
White men: 84.7%. 

Year: 2009; 
Minority men: 15.3%; 
White men: 84.7%. 

Year: 2010; 
Minority men: 16%; 
White men: 84%. 

Year: 2011; 
Minority men: 16.6%; 
White men: 83.4%. 

Women: 

Year: 2007; 
Minority Women: 20.4%; 
White women: 79.6%. 

Year: 2008; 
Minority Women: 20.9%; 
White women: 79.1%. 

Year: 2009; 
Minority Women: 21%; 
White women: 79%. 

Year: 2010; 
Minority Women: 21.4%; 
White women: 78.6%. 

Year: 2011; 
Minority Women: 22%; 
White women: 78%. 

Source: GAO analysis of EEOC data. 

[End of figure] 

Among first-and mid-level management positions, the representation of 
women has been at about 48 percent, slightly higher than the 
representation of women among all management positions. In contrast, 
women represented about 29 percent of all senior management positions 
from 2007 through 2011--about 16 percentage points below the 
representation of women for all management positions, according to 
EEOC data (see figure 7). 

Figure 7: Percentage of Women in the Financial Services Industry by 
Management Level and Race/Ethnicity, 2007-2011: 

[Refer to PDF for image: multiple line graph] 

Year: 2007; 
Women first- and mid-level: 48.2%; 
White women first- and mid-level: 78.8%; 
Minority women first- and mid-level: 21.2%; 
Women senior level: 30.0%; 
White women senior level: 86.3%; 
Minority women senior level: 13.7%. 

Year: 2008; 
Women first- and mid-level: 48.1%; 
White women first- and mid-level: 78.2%; 
Minority women first- and mid-level: 21.8%; 
Women senior level: 30.0%; 
White women senior level: 86.7%; 
Minority women senior level: 13.3%. 

Year: 2009; 
Women first- and mid-level: 48.0%; 
White women first- and mid-level: 78.1%; 
Minority women first- and mid-level: 21.9%; 
Women senior level: 29.9%; 
White women senior level: 87.4%; 
Minority women senior level: 12.6%. 

Year: 2010; 
Women first- and mid-level: 47.7%; 
White women first- and mid-level: 77.7%; 
Minority women first- and mid-level: 22.3%; 
Women senior level: 28.4%; 
White women senior level: 87.6%; 
Minority women senior level: 12.4%. 

Year: 2011; 
Women first- and mid-level: 47.5%; 
White women first- and mid-level: 77.1%; 
Minority women first- and mid-level: 22.9%; 
Women senior level: 28.4%; 
White women senior level: 86.5%; 
Minority women senior level: 13.5%. 

Source: GAO analysis of EEOC data. 

[End of figure] 

Based on EEOC data, minority women had greater representation at the 
first and mid levels of management compared to the senior level over 
the 5-year period. As shown in figure 7, among female senior managers, 
representation of minority women remained at about 13 percent over the 
5-year period. In contrast, among female first-and mid-level managers, 
the proportion of minority women increased during the same period from 
21.2 percent to 22.9 percent. 

The representation of minorities increases for both women and men as 
the firm size increases (see figure 8). For example, in 2011 the 
representation of minorities at firms with 100%-249 employees was 
about 18 percent among women and about 12 percent among men, while at 
firms with more than 1,000 employees, the representation of minorities 
was about 23 percent among women and about 17 percent among men. For 
additional analysis of EEOC data by workforce position and industry 
sector, see appendix II. 

Figure 8: Percentage of Whites/Minorities and Men/Women at Financial 
Services Firms of Different Sizes, 2007-2011: 

[Refer to PDF for image: 2 combined vertical bar and line graphs] 

Firm size: 100%-249 employees: 

Year: 2007; 
Minority men: 11.9%; 
White men and women: 88.1%; 
Minority women: 16.6%; 
White women: 83.4%. 

Year: 2008; 
Minority men: 11.9%; 
White men and women: 88.1%; 
Minority women: 17%; 
White women: 83%. 

Year: 2009; 
Minority men: 11.5%; 
White men and women: 88.5%; 
Minority women: 16.8%; 
White women: 83.2%. 

Year: 2010; 
Minority men: 11.9%; 
White men and women: 88.1%; 
Minority women: 16.9%; 
White women: 83.1%. 

Year: 2011; 
Minority men: 12.3%; 
White men and women: 87.7%; 
Minority women: 17.7%; 
White women: 82.3%. 

Firm size: 250-999 employees: 

Year: 2007; 
Minority men: 13.7%; 
White men and women: 86.3%; 
Minority women: 19.1%; 
White women: 80.9%. 

Year: 2008; 
Minority men: 13.6%; 
White men and women: 86.4%; 
Minority women: 18.8%; 
White women: 81.2%. 

Year: 2009; 
Minority men: 14.4%; 
White men and women: 85.6%; 
Minority women: 20.2%; 
White women: 79.8%. 

Year: 2010; 
Minority men: 14.4%; 
White men and women: 85.6%; 
Minority women: 20.3%; 
White women: 79.7%. 

Year: 2011; 
Minority men: 15.1%; 
White men and women: 84.9%; 
Minority women: 21.2%; 
White women: 78.8%. 

Firm size: more than 1,000 employees: 

Year: 2007; 
Minority men: 15.3%; 
White men and women: 84.7%; 
Minority women: 21.1%; 
White women: 78.9%. 

Year: 2008; 
Minority men: 16%; 
White men and women: 84%; 
Minority women: 21.7%; 
White women: 78.3%. 

Year: 2009; 
Minority men: 16%; 
White men and women: 84%; 
Minority women: 21.7%; 
White women: 78.3%. 

Year: 2010; 
Minority men: 16.7%; 
White men and women: 83.3%; 
Minority women: 22.2%; 
White women: 77.8%. 

Year: 2011; 
Minority men: 17.3%; 
White men and women: 82.7%; 
Minority women: 22.7%; 
White women: 77.3%. 

Source: GAO analysis of EEOC data. 

[End of figure] 

A survey of the general population shows some similar trends in the 
representation of both women and minorities in the financial services 
industry. The CPS is administered by the Bureau of the Census for the 
Bureau of Labor Statistics and is a monthly survey of about 60,000 
households across the nation. The CPS is used to produce official 
government figures on total employment and unemployment issued each 
month. According to the CPS data, from 2007 through 2011 the 
representation of women at the management level decreased from an 
estimated 49.1 percent to 47.3 percent. In addition, CPS data show a 
smaller increase from an estimated 14.1 percent to 15.1 percent in the 
representation of minorities in management over the same 5-year 
period.[Footnote 14] 

Leading Diversity Practices Remain Relevant but Challenges Exist 
Regarding Recruitment and Other Issues: 

The nine leading diversity practices that we previously identified in 
2005 are still relevant today, according to industry representatives 
with whom we spoke.[Footnote 15] Some industry representatives 
highlighted practices among these nine that they considered the most 
important to foster diversity and inclusion in their organizations. 
For example, top leadership commitment drives the other eight leading 
diversity practices, according to 9 of 10 industry representatives. In 
addition, accountability helps to promote the implementation of the 
other leading diversity practices because an issue is more likely to 
be addressed if it is tracked, according to 2 industry 
representatives. Moreover, creating awareness of the benefits of 
diversity for an organization among management and employees is 
important because it increases commitment to further the diversity 
goals of the organization, according to 7 industry representatives 
whom we interviewed.[Footnote 16] However, 1 industry representative 
told us there are still some firms that do not see the importance of 
diversity. In addition, 2 industry representatives said these 9 
leading diversity practices should be expanded beyond workforce 
management to include, for example, an organization's contracting 
efforts. 

Some industry representatives also noted that measuring the impact of 
various diversity practices is an important practice but that it can 
also be challenging; for example, it can be difficult to link specific 
practices to diversity outcomes and it can be a long-term process. 
According to some industry representatives, financial services 
organizations may measure the effectiveness of their diversity 
practices by assessing attrition, recruiting, and promotion rates, 
which are similar to measures we had previously reported.[Footnote 17] 
For example, a financial services organization may measure the 
proportion of certain minority groups or women in its workforce or 
among its promotions to determine the effectiveness of its practices. 
Further, financial services firms may use surveys to gather employee 
perspectives on workforce diversity issues in the organization, such 
as perceived fairness in the promotion process or factors that affect 
an employee's decision to remain with the firm, among other topics. 

Additional diversity practices identified by some industry 
representatives that can support the leading diversity practices 
include the following: 

* Sponsor individuals. Sponsorship of women within an organization 
where an executive acts as a guide to help women navigate the 
organization and expand their networks is an important diversity 
practice, according to three industry representatives. This 
sponsorship practice goes beyond the mentoring programs we previously 
reported in 2006, as a sponsor acts as an advocate to help the 
individual advance within the organization.[Footnote 18] 

* Address biased perceptions. One industry representative told us 
about an effort to combat unconscious bias in promotions. They 
described a promotion system designed to address biased perceptions, 
such as a view of leaders as being typically male. According to the 
industry representative, the firm that employed this diversity 
practice gathered complete and objective evaluations of employees and 
trained its managers to recognize and address these perceptions. The 
result was that the firm promoted greater numbers of women into 
management. 

* No industry representatives that we contacted reported changes to 
diversity practices as a result of the challenges faced by many firms 
during the financial crisis. Although representation of minorities and 
women has remained about the same from 2007 through 2011, according to 
some industry representatives, the industry continues to be focused on 
diversity. However, three industry representatives did cite specific 
instances where funding was scaled back as a result of the recent 
financial crisis. One industry representative told us that investment 
in training programs was reduced across the organization, but when a 
measurable impact on employees was identified at this organization, 
steps were taken to address the impact. 

* Some industry representatives cited challenges to achieving a 
diverse workforce in general. We have previously reported some of 
these challenges, which can affect some of the leading diversity 
practices.[Footnote 19] Six industry representatives said that 
diversity recruitment is difficult because the supply (or "pipeline") 
of minority and women candidates is limited. This has been a 
consistent challenge that we previously reported in 2006 and 2010. 
[Footnote 20] Available data indicate that for the internal pool of 
potential candidates for some management positions, representation of 
women varied, while representation of minorities was higher in every 
nonmanagement category compared to management positions (see figure 
9). For example, in 2011 the representation of women was greater in 
professional positions (about 51 percent) compared to sales positions 
(about 38 percent). In addition, the representation of minorities was 
higher in all nonmanagement positions than at the management level in 
2011, but especially higher in technical and clerical positions at 
more than 29 percent in both types of positions. Further analysis of 
diversity in various workforce positions can be found in appendix II. 

Figure 9: Percentage of Whites/Minorities and Men/Women in Various 
Financial Services Industry Workforce Positions, 2007-2011: 

[Refer to PDF for image: 8 stacked vertical bar graphs] 

Total workforce: 

Year: 2007; 
Minority: 29%; 
White: 71%; 
Women: 60%; 
Men: 40%. 

Year: 2008; 
Minority: 29.1%; 
White: 70.9%; 
Women: 59.9%; 
Men: 40.1%. 

Year: 2009; 
Minority: 28.8%; 
White: 71.2%; 
Women: 59.8%; 
Men: 40.2%. 

Year: 2010; 
Minority: 28.7%; 
White: 71.3%; 
Women: 59.1%; 
Men: 40.9%. 

Year: 2011; 
Minority: 29%; 
White: 71%; 
Women: 58.6%; 
Men: 41.4%. 

Source: GAO analysis of EEOC data. 

Senior level: 

Year: 2007; 
Minority: 10.6%; 
White: 89.4%; 
Women: 30%; 
Men: 70%. 

Year: 2008; 
Minority: 10.5%; 
White: 89.5%; 
Women: 30%; 
Men: 70%. 

Year: 2009; 
Minority: 10%; 
White: 90%; 
Women: 29.9%; 
Men: 70.1%. 

Year: 2010; 
Minority: 10.1%; 
White: 89.9%; 
Women: 28.4%; 
Men: 71.6%. 

Year: 2011; 
Minority: 10.8%; 
White: 89.2%; 
Women: 28.4%; 
Men: 71.6%. 

First- and mid-level: 

Year: 2007; 
Minority: 18.7%; 
White: 81.3%; 
Women: 48.2%; 
Men: 51.8%. 

Year: 2008; 
Minority: 19.2%; 
White: 80.8%; 
Women: 48.1%; 
Men: 51.9%. 

Year: 2009; 
Minority: 19.3%; 
White: 80.7%; 
Women: 48%; 
Men: 52%. 

Year: 2010; 
Minority: 19.8%; 
White: 80.2%; 
Women: 47.7%; 
Men: 52.3%. 

Year: 2011; 
Minority: 20.4%; 
White: 79.6%; 
Women: 47.5%; 
Men: 52.5%. 

Professional level: 

Year: 2007; 
Minority: 24.6%; 
White: 75.4%; 
Women: 52.5%; 
Men: 47.5%. 

Year: 2008; 
Minority: 25%; 
White: 75%; 
Women: 52.7%; 
Men: 47.3%. 

Year: 2009; 
Minority: 24.6%; 
White: 75.4%; 
Women: 52.6%; 
Men: 47.4%. 

Year: 2010; 
Minority: 24.5%; 
White: 75.5%; 
Women: 51.9%; 
Men: 48.1%. 

Year: 2011; 
Minority: 25%; 
White: 75%; 
Women: 51.4%; 
Men: 48.6%. 

Technical level: 

Year: 2007; 
Minority: 27.2%; 
White: 72.8%; 
Women: 45.7%; 
Men: 54.3%. 

Year: 2008; 
Minority: 28.4%; 
White: 71.6%; 
Women: 45.9%; 
Men: 54.1%. 

Year: 2009; 
Minority: 28.8%; 
White: 71.2%; 
Women: 47.3%; 
Men: 52.7%. 

Year: 2010; 
Minority: 28.9%; 
White: 71.1%; 
Women: 45.6%; 
Men: 54.4%. 

Year: 2011; 
Minority: 30%; 
White: 70%; 
Women: 45.6%; 
Men: 54.4%. 

Sales level: 

Year: 2007; 
Minority: 27.6%; 
White: 72.4%; 
Women: 40.1%; 
Men: 59.9%. 

Year: 2008; 
Minority: 23.4%; 
White: 76.6%; 
Women: 38.9%; 
Men: 61.1%. 

Year: 2009; 
Minority: 22.5%; 
White: 77.5%; 
Women: 38.5%; 
Men: 61.5%. 

Year: 2010; 
Minority: 21.9%; 
White: 78.1%; 
Women: 38.2%; 
Men: 61.8%. 

Year: 2011; 
Minority: 22.5%; 
White: 77.5%; 
Women: 38.4%; 
Men: 61.6%. 

Clerical level: 

Year: 2007; 
Minority: 37.5%;
White: 62.5%; 
Women: 78%; 
Men: 22%. 

Year: 2008; 
Minority: 38.1%; 
White: 61.9%; 
Women: 77.3%; 
Men: 22.7%. 

Year: 2009; 
Minority: 36.8%; 
White: 63.2%; 
Women: 76.8%; 
Men: 23.2%. 

Year: 2010; 
Minority: 36.8%; 
White: 63.2%; 
Women: 76.4%; 
Men: 23.6%. 

Year: 2011; 
Minority: 36.4%; 
White: 63.6%; 
Women: 76.1%; 
Men: 23.9%. 

Other: 

Year: 2007; 
Minority: 36.8%; 
White: 63.2%; 
Women: 35.3%; 
Men: 64.7%. 

Year: 2008; 
Minority: 37.2%; 
White: 62.8%; 
Women: 40.1%; 
Men: 59.9%. 

Year: 2009; 
Minority: 36.8%; 
White: 63.2%; 
Women: 40.2%; 
Men: 59.8%. 

Year: 2010; 
Minority: 36.8%; 
White: 63.2%; 
Women: 37.5%; 
Men: 62.5%. 

Year: 2011; 
Minority: 36.4%; 
White: 63.6%; 
Women: 36.2%; 
Men: 63.8%. 

Source: GAO analysis of EEOC data. 

Note: The following are descriptions of the job categories in EEO-1 
data from EEOC: (1) "Executive/Senior Level Officials and Managers," 
includes individuals who reside in the highest levels of organizations 
and plan, direct, and formulate policies, set strategy, and provide 
the overall direction of enterprises/organizations for the development 
and delivery of products or services, within the parameters approved 
by boards of directors or other governing bodies; (2) "First/Mid-Level 
Officials and Managers," includes individuals who receive directions 
from Executive/Senior Level management, and oversee and direct the 
delivery of products, services, or functions at group, regional, or 
divisional levels of organizations; (3) "professionals" include 
occupations requiring either college graduation or experience of such 
kind and amount as to provide a comparable background; (4) 
"technicians" include occupations requiring a combination of basic 
scientific knowledge and manual skill that can be obtained through 2 
years of post-high school education; (5) "sales workers" include 
occupations engaging wholly or primarily in direct selling; (6) 
"office and clerical" includes all clerical-type work regardless of 
level of difficulty, where the activities are predominantly nonmanual; 
and (7) the category "other" includes craft workers, operatives, 
laborers, and service workers. 

[End of figure] 

In recent years, representation in business graduate programs, a 
potential source of future managers in the financial industry, has 
remained stable for women and has increased slightly for minorities, 
but representation is still low for both women and minorities when 
compared to the overall representation of students in the university 
system.[Footnote 21] To assess one possible external pool of 
candidates for financial services firms, we obtained data from the 
Association to Advance Collegiate Schools of Business (AACSB) on the 
number of students enrolled in Master of Business Administration (MBA) 
degree programs in AACSB member schools in the United States from 2007 
through 2011 as well as the number of students in the university 
system.[Footnote 22] According to AACSB data, the representation of 
women remained constant over this period, while the representation of 
minorities increased. For example, the representation of women among 
MBA students remained at about 37 percent over the 5-year period, 
while representation of women was slightly higher in the overall 
university system at about 41 percent. In contrast, as table 2 shows, 
the representation of minorities increased among MBA students from 
about 26 percent in 2007 to about 29 percent in 2011. However, when 
compared to the university system, representation of minorities in the 
overall university system was slightly higher from about 29 percent in 
2007 to 34 percent in 2011. 

Table 2: Percentage of Students Enrolled in MBA Degree Programs at 
AACSB Member Schools in the United States by Race/Ethnicity, 2007-2011: 

Year: 2007; 
Total enrolled: 100%; 
White: 74%; 
Total minority: 26%; 
African American: 7%; 
Hispanic: 6%; 
Asian: 12%; 
Other: 0%. 

Year: 2008; 
Total enrolled: 100%; 
White: 7%3; 
Total minority: 27%; 
African American: 8%; 
Hispanic: 6%; 
Asian: 12%; 
Other: 0. 

Year: 2009; 
Total enrolled: 100%; 
White: 73%; 
Total minority: 27%; 
African American: 8%; 
Hispanic: 7%; 
Asian: 12%; 
Other: 0. 

Year: 2010; 
Total enrolled: 100%; 
White: 72%; 
Total minority: 28%; 
African American: 9%; 
Hispanic: 7%; 
Asian: 11%; 
Other: 1%. 

Year: 2011; 
Total enrolled: 100%; 
White: 71%; 
Total minority: 29%; 
African American: 9%; 
Hispanic: 7%; 
Asian: 11%; 
Other: 2%. 

Source: GAO analysis of AACSB International data. 

Note: The "other" category includes Native American, and updated race/ 
ethnicity categories implemented in 2011 to include "two or more 
races" and "Native Hawaiian or Other Pacific Islander." Percentages 
may not always add exactly due to rounding. In addition, these ratios 
only represent MBA enrolled students for whom race/ethnicity was 
indicated. 

[End of table] 

Some industry representatives stated that the negative perception of 
the industry could also limit the external pipeline of potential 
candidates, which can make recruitment challenging. Multiple industry 
representatives discussed the need to take a new approach to diversity 
recruiting as a result of the negative image many potential candidates 
may have about the financial services industry following the recent 
financial crisis. For example, to counter negative perceptions that 
may have resulted from the foreclosure crisis or the Occupy Wall 
Street movement, one industry representative told us that it explains 
to prospective employees the social contributions financial services 
firms make through microfinance or economic and community development. 

In addition to these difficulties with recruiting, two industry 
representatives highlighted maintaining accountability as a particular 
challenge for financial services firms.[Footnote 23] For example, an 
industry representative said it is difficult to promote results in 
diversity by linking diversity management with managers' performance 
ratings because this practice may not provide enough incentive to many 
managers. Another industry representative told us that recognizing and 
compensating managers and employees for their diversity efforts can 
result in increased commitment to foster workforce diversity and an 
increase in diversity at firms. 

Agency and Reserve Bank Workforce Diversity Varied, and Officials 
Reported Difficulty Identifying Diverse Candidates: 

Since the financial crisis, senior management-level minority and 
gender diversity at the federal financial agencies and Reserve Banks 
has varied across individual entities.[Footnote 24] The representation 
of minorities at the senior management-level increased slightly 
overall at both the agencies and Reserve Banks. In addition, the 
representation of women at the senior management-level increased 
slightly overall for both the agencies and Reserve Banks. Agency and 
Reserve Bank officials identified key challenges to increasing 
workforce diversity overall and at the senior management-level, 
including limited representation of minorities and women among 
internal and external candidate pools. 

Senior Management-Level Representation of Minorities and Women Varied 
at Agencies and Reserve Banks, with Slight Changes Overall: 

Senior management-level representation of minorities and women varied 
across individual federal financial agencies and the 12 Reserve Banks. 
The agencies included FDIC, the Federal Reserve Board, NCUA, OCC, and 
Treasury. Complete data for this period were not available for CFPB, 
FHFA, and SEC, and we excluded these agencies from our analysis of 
changes in senior management-level diversity from 2007 through 2011, 
but provide recent data when available. Data for each agency are 
provided in appendix IV. CFPB assumed responsibility for certain 
consumer financial protection functions in July 2011 and has not yet 
reported workforce information to EEOC.[Footnote 25] However, we 
received recent employment profile data from CFPB as of May 2012. 
[Footnote 26] FHFA, which was established in July 2008, started 
reporting workforce data for 2010; while our analysis provides 2010 
and 2011 data for FHFA, our analysis across the agencies excludes FHFA 
from aggregated totals. SEC reported data for 2007 through 2011, but 
revised how it reported officials and managers during the 5-year 
period; while our analysis provides 2011 senior management-level data 
for SEC, we excluded SEC from our senior management-level trend 
analysis. 

In our review of agency reports, we found that from 2007 through 2011, 
the representation of minorities among senior management-level 
employees, when aggregated across FDIC, the Federal Reserve Board, 
NCUA, OCC, and Treasury, increased slightly, from 16 to 17 percent for 
the agencies combined (see figure 10).[Footnote 27] From 2007 through 
2011, three agencies--FDIC, the Federal Reserve Board, and Treasury--
showed an increase in the representation of minorities at the senior 
management-level, by between 1 and 3 percentage points. Two agencies--
NCUA and OCC--experienced no percentage point change in their 
representation of minorities at the senior management-level from 2007 
through 2011.[Footnote 28] In 2011, the representation of minorities 
among senior management-level employees of these agencies, FHFA, and 
SEC ranged from 11 percent at SEC to 24 percent at FHFA. Additionally, 
CFPB employment data showed about 28 percent representation of 
minorities among senior officials as of May 2012.[Footnote 29] 

Figure 10: Percentage of Minorities among Senior Management-Level 
Employees at Six Federal Financial Agencies, 2007-2011: 

[Refer to PDF for image: Interactive graphic with 7 multiple line 
graphs] 

Click the mouse on the graphs: see appendix IV for more information. 

Source: GAO analysis of agency reports. 

Notes: Percentages are rounded to the nearest percent. 

For our analysis, we reviewed the numbers of employees the agencies 
reported according to race/ethnicity and gender in table A3 of their 
MD-715 reports from 2007 through 2011. These data are based on 
information self-reported by employees to each agency and there were 
some differences in reporting across the agencies. In some years, some 
agencies reported all employees--permanent and temporary--in their A3 
tables while others reported permanent employees only. We considered 
employees reported by agencies in the category "Executive/Senior 
Level" as senior management-level employees. Though the MD-715 report 
guidelines instruct agencies to identify employees Grades 15 and above 
who have supervisory responsibility in this category, agencies have 
discretion to include employees who have significant policymaking 
responsibilities but do not supervise employees. As a result, the 
composition of the "Executive/Senior Level" category may vary among 
the different agencies and does not necessarily involve the same set 
of managers at each agency. 

[A] Our trend analysis for "all agencies" excludes CFPB, FHFA, and 
SEC. CFPB assumed responsibility for certain consumer financial 
protection functions in July 2011 and has not yet reported workforce 
information to EEOC. FHFA was established in 2008 and started 
reporting workforce data for 2010. SEC revised how it reported 
officials and managers between 2007 and 2011. While our analysis 
includes 2011 management-level data for SEC, we excluded SEC from our 
trend analysis. 

[End of figure] 

In our review of EEO-1 reports provided by the Reserve Banks, we found 
that the representation of minorities among senior management-level 
employees in aggregate across the 12 Reserve Banks increased from 11 
percent to 14 percent from 2007 through 2011 (see figure11).[Footnote 
30] The population of senior management-level employees at each bank 
in 2011 ranged from 9 employees at the Reserve Banks of Chicago, 
Dallas, and Minneapolis, to 59 employees at the Reserve Bank of New 
York, and the population of minority senior management-level employees 
at each bank ranged from zero employees at the Reserve Bank of 
Cleveland to 7 employees at the Reserve Bank of New York. Specific 
information on each Reserve Bank is provided in appendix IV. 

Figure 11: Percentage of Minorities among Senior Management-Level 
Employees at the 12 Reserve Banks, 2007-2011: 

[Refer to PDF for image: Interactive graphic with 1 multiple line 
graph] 

Click the mouse on the graph: see appendix IV for more information. 

Source: GAO analysis of EEC-1 reports provided by Reserve Banks. 

Notes: Data are rounded to the nearest percent. 

Reserve Bank data are presented in aggregate because the population of 
senior management-level employees at most Reserve Banks is generally 
small and the gain or loss of one employee can result in a large 
percentage point change in the representation of minorities. Specific 
information on each Reserve Bank is provided in appendix IV. 

[End of figure] 

In general, the representation of women at the senior management-level 
increased slightly since the beginning of the financial crisis in 2007 
at agencies, but representation percentages varied for each entity. In 
our review of agency reports, we found that from 2007 through 2011, 
the representation of women at the senior management-level increased 
slightly from 34 to 36 percent across FDIC, the Federal Reserve Board, 
NCUA, OCC, and Treasury, in aggregate (see figure 12). Changes varied 
by agency, from a decrease of 5 percentage points at OCC to an 
increase of 5 percentage points at NCUA. Four of the five agencies--
FDIC, the Federal Reserve Board, NCUA, and Treasury--showed an 
increase of between 3 and 5 percentage points in the representation of 
women at the senior management-level from 2007 through 2011. In 2011, 
the representation of women among senior management-level employees 
ranged among the agencies from 31 percent at FDIC to 47 percent at 
FHFA. Additionally, CFPB employment data showed the representation of 
women among senior officials at about 35 percent as of May 2012. 

Figure 12: Percentage of Women among Senior Management-Level Employees 
at Six Federal Financial Agencies, 2007-2011: 

[Refer to PDF for image: Interactive graphic with 7 stacked vertical 
bar graphs] 

Click the mouse on the graphs: see appendix IV for more information. 

Source: GAO analysis of agency reports. 

Notes: Percentages are rounded to the nearest percent. 

For our analysis, we reviewed the numbers of employees the agencies 
reported according to race/ethnicity and gender in table A3 of their 
MD-715 reports from 2007 through 2011. These data are based on 
information self-reported by employees to each agency and there were 
some differences in reporting across the agencies. In some years, some 
agencies reported all employees--permanent and temporary--in their A3 
tables while others reported permanent employees only. We considered 
employees reported by agencies in the category "Executive/Senior 
Level" as senior management-level employees. Though the MD-715 report 
guidelines instruct agencies to identify employees Grades 15 and above 
who have supervisory responsibility in this category, agencies have 
discretion to include employees who have significant policymaking 
responsibilities but do not supervise employees. As a result, the 
composition of the "Executive/Senior Level" category may vary among 
the different agencies and does not necessarily involve the same set 
of managers at each agency. 

[A] Our trend analysis for "all agencies" excludes CFPB, FHFA, and 
SEC. CFPB assumed responsibility for certain consumer financial 
protection functions in July 2011 and has not yet reported workforce 
information to EEOC. FHFA was established in 2008 and started 
reporting workforce data for 2010. SEC revised how it reported 
officials and managers between 2007 and 2011. While our analysis 
includes 2011 management-level data for SEC, we excluded SEC from our 
trend analysis. 

[End of figure] 

In our review of EEO-1 reports provided by the Reserve Banks, we found 
that from 2007 through 2011, the representation of women at the senior 
management-level increased from 32 percent to 38 percent for the 
Reserve Banks, in aggregate (see figure 13). As mentioned previously, 
the population of senior management-level employees at each bank in 
2011 ranged from nine employees at the Reserve Banks of Chicago, 
Dallas, and Minneapolis, to 59 employees at the Reserve Bank of New 
York. The population of women among senior management-level employees 
at each bank in 2011 ranged from two employees at the Reserve Bank of 
Boston to 25 employees at the Reserve Bank of New York. Specific 
information on each Reserve Bank is provided in appendix IV. 

Figure 13: Percentage of Women among Senior Management-Level Employees 
at the 12 Reserve Banks, 2007-2011: 

[Refer to PDF for image: Interactive graphic with 1 stacked vertical 
bar graph] 

Click the mouse on the graph: see appendix IV for more information. 

Source: GAO analysis of Reserve Bank reports. 

Notes: Data are rounded to the nearest percent. 

Reserve Bank data are presented in aggregate because the population of 
senior management-level employees at most Reserve Banks is generally 
small and the gain or loss of one employee can result in a large 
percentage point change in the representation of women. Specific 
information on each Reserve Bank is provided in appendix IV. 

[End of figure] 

Several agencies reported on existing diversity practices related to 
retaining and promoting employees to build management-level diversity. 
For example, according to agency reports, some Treasury offices 
conduct formal mentoring programs, and the Federal Reserve Board has 
customized mentoring programs within its divisions, which in 
conjunction with a leadership exchange program sponsored by the 
Federal Reserve System, provide employees opportunities to develop new 
skills and experiences. Further, OCC reported having development 
programs for employees within its bank supervision division that 
provide leadership and development opportunities to staff, and agency-
sponsored employee network groups implemented mentoring circles to 
assist in the career development and retention of the agency's 
workforce. 

Several Reserve Banks identified practices targeted to improve 
management-level diversity, including changes to hiring practices and 
mentoring programs. For example, officials from several Reserve Banks 
we contacted said their organizations revised their hiring policies to 
open all management-level positions to external applicants in addition 
to current employees as a way to build management-level diversity by 
hiring diverse, experienced candidates from outside the organization. 
Additionally, the Reserve Banks of Dallas and New York began piloting 
new mentoring programs in 2011, and each planned to expand its program 
based on initial feedback its OMWI had received. These banks and 
several others with existing mentoring programs reported that 
mentoring programs were important to retaining and developing 
minorities and women within their organizations. Later in this report, 
we provide additional information on the agencies' and Reserve Banks' 
recruitment practices as part of their efforts to implement section 
342 of the Dodd-Frank Act.[Footnote 31] 

Total Workforce Minorities and Women Representation Varied but 
Decreased Slightly Overall: 

Based on our analysis of minority and gender diversity at all levels 
from 2007 through 2011, workforce diversity varied at the federal 
financial agencies and Reserve Banks, with slight decreases in 
aggregate. Specifically, the representation of minorities decreased 
slightly from 31 percent to 30 percent from 2007 through 2011 across 
FDIC, the Federal Reserve Board, NCUA, OCC, SEC, and Treasury, in 
aggregate. Additionally, CFPB employment data showed the 
representation of minorities of all agency employees at about 33 
percent as of May 2012. Three agencies--NCUA, OCC, and SEC--showed a 1 
percentage point or greater increase in the overall representation of 
minorities during the 5-year period, according to agency reports. In 
2011, the representation of minorities at the agencies ranged from 25 
percent at NCUA to 44 percent at the Federal Reserve Board. Our 
analysis of EEO-1 reports provided by the Reserve Banks for 2007 
through 2011 showed that the representation of minorities across the 
Reserve Banks declined slightly in aggregate, from 38 percent to 36 
percent. The Reserve Banks of Minneapolis and New York showed a 2 
percentage point increase in the overall representation of minorities 
working at Reserve Banks, the Reserve Bank of Boston showed no 
percentage point change, and the remaining nine banks showed decreases 
of 1 to 8 percentage points. In 2011, the representation of minorities 
at the Reserve Banks ranged from 16 percent at the Reserve Bank of 
Kansas City to 53 percent at the Reserve Bank of San Francisco. 

Similarly, we found that overall gender diversity varied at individual 
agencies and Reserve Banks, and generally declined slightly from 2007 
through 2011. The overall representation of women in the workforce 
aggregated across FDIC, the Federal Reserve Board, NCUA, OCC, SEC, and 
Treasury declined slightly from 47 percent to 45 percent over the 5-
year period. Additionally, CFPB employment data showed the 
representation of women of all agency employees at about 49 percent as 
of May 2012. Two agencies--NCUA and SEC--showed no percentage point 
change in the representation of women during the 5-year period; OCC 
showed a decrease of about 1 percentage point, and the other three 
agencies--FDIC, the Federal Reserve Board, and Treasury--experienced 
decreases of 2 percentage points. In 2011, the representation of women 
among all employees at the agencies ranged from 42 percent at FDIC to 
48 percent at SEC and Treasury. The overall representation of women 
across the Reserve Banks, in aggregate, declined from 49 percent to 45 
percent from 2007 through 2011. All Reserve Banks showed declines in 
the representation of women among all employees during the 5-year 
period, ranging from a 1 percentage point decrease at the Reserve Bank 
of New York to a 7 percentage point decrease at the Reserve Bank of 
Cleveland. For example, in 2007, 827 of the Reserve Bank of 
Cleveland's 1,568 employees were women, and in 2011, 500 of the bank's 
1,094 employees were women; the bank's workforce changed from having 
around 53 percent women employees to about 46 percent women employees. 
In 2011, the overall representation of women at Reserve Banks ranged 
from 40 percent at the Reserve Banks of Philadelphia and Richmond to 
53 percent at the Reserve Bank of Minneapolis. See appendix III for 
additional information on the overall workforce representation for the 
agencies and Reserve Banks. 

According to officials from five Reserve Banks and the Federal Reserve 
Board, consolidation of check processing and other operations, some of 
which occurred since the financial crisis, had eliminated many 
administrative and service worker positions. Since these positions are 
often held by minorities and women, these consolidations affected 
overall employment diversity at affected Reserve Banks. In response to 
declines in the use of paper checks and greater use of electronic 
payments, the Reserve Banks took steps beginning in 2003 to reduce the 
number of locations where paper checks were processed. In 2001, the 
Federal Reserve System employed around 5,500 people in check 
processing functions across 45 locations, and in 2008, around 2,800 
employees supported check processing functions across 18 locations. By 
2010, one paper check processing site remained in Cleveland, along 
with an electronic check processing site in Atlanta. As of January 
2013, approximately 480 employees supported check processing functions 
across the Federal Reserve System. The Federal Reserve System is 
projected to complete its consolidation of check processing functions 
in 2013. 

Officials Reported Difficulty Identifying Diverse Candidates as the 
Main Challenge to Building Workforce Diversity: 

OMWI officials described challenges to building workforce diversity 
both at the management level and overall. Four agencies--FDIC, the 
Federal Reserve Board, FHFA, and OCC--and three Reserve Banks--the 
Reserve Banks of Chicago, Minneapolis, and St. Louis--cited 
underrepresentation of minorities and women within internal candidate 
pools as a challenge to building management-level diversity, as many 
management-level positions are filled through promotions or internal 
hiring processes. Additionally, the Reserve Banks of Dallas, 
Minneapolis, Philadelphia, and San Francisco said low turnover was a 
challenge to increasing their management-level diversity profiles 
because it limited opportunities to increase organizational diversity 
through hiring and promotion. 

Federal financial agencies and Reserve Banks identified other 
challenges to building workforce diversity generally. The Reserve 
Banks of Atlanta, Boston, Chicago, Kansas City, and St. Louis cited 
competition from the private sector for recruiting diverse candidates 
as a challenge. In addition, FHFA and the Reserve Banks of Cleveland, 
Philadelphia, and San Francisco cited limited representation of 
minorities within external candidate pools as another challenge. The 
Federal Reserve Board and the Reserve Banks of Chicago and Kansas City 
reported that the availability of external candidates could be an 
issue in particular for hiring certain specialized positions, such as 
economists, which would involve a small candidate pool with limited 
representation of minorities. Additionally, three Reserve Banks 
identified geographic impediments to their national recruitment 
efforts, explaining that it is difficult to attract candidates from 
outside their region. For example, the Reserve Banks of Kansas City 
and St. Louis said it was difficult to recruit candidates lacking ties 
to the central United States, and the Reserve Bank of San Francisco 
cited difficulty recruiting from the eastern United States. Further, 
several agencies and Reserve Banks identified other challenges to 
building workforce diversity. For example, Treasury cited budget 
constraints on hiring and the Reserve Bank of Cleveland cited time 
constraints on recruitment practices as challenges. Additionally, NCUA 
cited as a challenge establishing tracking systems to help identify 
barriers to recruiting, hiring, and retaining minorities. 

Dodd-Frank Requirements Are Being Implemented, but Enhanced Reporting 
of Efforts to Measure Progress Is Needed: 

Federal financial agencies and Reserve Banks have begun implementing 
key requirements of section 342 of the Dodd-Frank Act. First, all 
agencies and Reserve Banks have established OMWIs. Most agencies and 
all of the Reserve Banks used existing policies to establish standards 
for equal employment opportunity required by the act. Although many 
agencies and Reserve Banks had been using recruitment practices 
required by the act prior to its enactment, the majority of OMWIs have 
expanded these or initiated other practices. In addition to meeting 
requirements regarding their diversity policies, the federal financial 
agencies have taken preliminary steps to develop procedures for 
assessing the diversity policies and practices of entities they 
regulate, as required under the act. Finally, nearly all the agencies 
and all of the Reserve Banks are reporting annually on their diversity 
practices. While many OMWIs have implemented or are planning efforts 
to measure and evaluate the progress of their diversity and inclusion 
activities, information on such efforts is not yet reported 
consistently across the OMWI annual reports. Such information could 
enhance their efforts to report on measuring outcomes and the progress 
of their diversity practices. 

Agencies and Reserve Banks Have Established Offices of Minority and 
Women Inclusion and Diversity Standards: 

All federal financial agencies and all Reserve Banks have established 
an OMWI. Six of the seven agencies that existed when the Dodd-Frank 
Act was enacted established OMWIs by January 2011, pursuant to the 
time frame established in the act. Additionally, SEC formally 
established its OMWI in July 2011, following House and Senate 
Appropriations Committees' approvals of the agency's request to create 
an OMWI.[Footnote 32] SEC selected an OMWI director in December 2011, 
who officially joined the office in January 2012. CFPB, which assumed 
responsibility for certain consumer financial protection functions in 
July 2011, established its OMWI in January 2012 and its OMWI director 
officially joined the agency in April 2012.[Footnote 33] 

Many agencies and most of the Reserve Banks established their OMWIs as 
new, separate offices. Four of eight agencies and 9 of 12 Reserve 
Banks established their OMWIs separate from other offices, including 
four banks that refocused existing diversity offices as their OMWIs. 
Three agencies--FDIC, the Federal Reserve Board, and OCC--and three 
banks--the Reserve Banks of Atlanta, Kansas City, and Philadelphia--
established their OMWIs within existing offices of equal employment 
opportunity (EEO) or diversity. FHFA established its OMWI and then 
merged its EEO function into that office. OMWI officials from several 
agencies with separate OMWIs said their staff worked with their EEO 
offices to address agency diversity issues. Similarly, many agency and 
Reserve Bank OMWI officials said they coordinated with other offices 
across their organizations, such as human resources, recruiting, 
procurement, and management, to support ongoing diversity and 
inclusion efforts organizationwide. 

Federal financial agencies and Reserve Banks all have taken steps to 
staff their OMWIs. As of January 2013, the agencies had allocated 
between 3 and 40 full-time equivalent positions to their OMWIs (see 
table 3), and all agencies had open positions they planned to fill 
among these allocated positions. FDIC had allocated 40 full-time 
equivalent positions to its combined OMWI/EEO office as of January 
2013. Many of FDIC's OMWI staff, including eight EEO specialists, 
support the office's EEO functions, and OCC and FHFA also reported EEO 
specialists among their staff. The agency OMWIs included directors and 
analysts among their staff, as well as some positions specific to 
certain functions of the OMWIs. For example, four of the agencies--
CFPB, FDIC, NCUA, and SEC--had allocated staff specifically to 
recruitment and outreach functions, and four of the agencies--NCUA, 
OCC, SEC, and Treasury--had allocated staff specifically to business 
and supplier diversity. Four agencies--the Federal Reserve Board, 
FHFA, NCUA, and OCC--had each allocated a position to help implement 
the Dodd-Frank Act requirement to review the diversity practices of 
regulated entities. Additionally, two of the agencies--CFPB and SEC--
had attorney positions among their OMWI staff. 

Table 3: OMWI Staffing Levels for Federal Financial Agencies, as of 
January 2013: 

Agency: CFPB; 
Allocated: 4; 
Filled: 3. 

Agency: Federal Reserve Board[A]; 
Allocated: 3; 
Filled: 2. 

Agency: FDIC[A]; 
Allocated: 40; 
Filled: 35. 

Agency: FHFA[A,B]; 
Allocated: 9; 
Filled: 8. 

Agency: NCUA; 
Allocated: 6; 
Filled: 5. 

Agency: OCC[A]; 
Allocated: 12; 
Filled: 11. 

Agency: SEC[C]; 
Allocated: 9; 
Filled: 8. 

Agency: Treasury; 
Allocated: 11; 
Filled: 8. 

Source: GAO analysis of federal financial agency information. 

[A] Totals for FDIC, FHFA, and OCC include EEO staff, as the OMWI 
offices for these agencies include both functions. The Federal Reserve 
Board also established its OMWI within an existing office, but it 
provided information for OMWI staff only and excluded the office's 
director position, as agency officials said additional funds for the 
director position were not allocated because the director's primary 
duties included overseeing EEO compliance, diversity, and inclusion. 

[B] Totals for FHFA include part-time staff. 

[C] In addition to these staff, SEC's OMWI is supported by two full-
time contract positions, a program analyst and a recruitment 
coordinator. 

[End of table] 

The Reserve Banks had allocated between three and seven full-time 
equivalent positions to their OMWIs as of January 2013 (see table 4). 
Ten of the 12 Reserve Banks had filled all of these positions, while 
the Reserve Banks of Cleveland and St. Louis each had one open 
position. The Reserve Bank OMWIs included directors and analysts among 
their staff. Few Reserve Banks designated specific OMWI functions to 
certain positions. Three banks, the Reserve Banks of Atlanta, Boston, 
and St. Louis, had each allocated one position to supplier or business 
diversity, and two other banks, the Reserve Banks of Chicago and 
Cleveland, had each allocated one position to help carry out the 
reporting functions of the OMWIs. 

Table 4: OMWI Staffing Levels for Reserve Banks, as of January 2013: 

Reserve Bank: Atlanta[A]; 
Allocated: 4.5; 
Filled: 4.5. 

Reserve Bank: Boston; 
Allocated: 5; 
Filled: 5. 

Reserve Bank: Chicago; 
Allocated: 7; 
Filled: 7. 

Reserve Bank: Cleveland; 
Allocated: 4; 
Filled: 3. 

Reserve Bank: Dallas[B]; 
Allocated: 4; 
Filled: 4. 

Reserve Bank: Kansas City[B]; 
Allocated: 5; 
Filled: 5. 

Reserve Bank: Minneapolis[B]; 
Allocated: 3; 
Filled: 3. 

Reserve Bank: New York; 
Allocated: 5; 
Filled: 5. 

Reserve Bank: Philadelphia[B]; 
Allocated: 3; 
Filled: 3. 

Reserve Bank: Richmond; 
Allocated: 5; 
Filled: 5. 

Reserve Bank: San Francisco; 
Allocated: 3; 
Filled: 3. 

Reserve Bank: St. Louis; 
Allocated: 5; 
Filled: 4. 

Source: GAO analysis of Reserve Bank information. 

[A] Totals for the Reserve Bank of Atlanta include part-time staff. 

[B] Totals for the Reserve Banks of Dallas, Kansas City, Minneapolis, 
and Philadelphia include full-time employees with shared duties that 
help support the OMWI. 

[End of table] 

Perspectives on the role of OMWIs varied across some Reserve Bank 
officials with whom we spoke. While several Reserve Bank officials 
said their OMWIs were involved in policy development with a commitment 
to improving the Reserve Bank's diversity efforts over time, officials 
from one Reserve Bank said their OMWI was compliance-focused and 
primarily analyzed the banks' human capital resources and recruiting 
functions for compliance with Dodd-Frank Act requirements. Reserve 
Bank of Dallas officials told us they considered the OMWI staff 
members as objective critics of the Reserve Bank's recruitment, 
procurement, and financial education efforts, and that bank management 
is responsible for fostering diversity and inclusion across the 
organization. 

The act also required federal financial agency and Reserve Bank OMWIs 
to develop standards for equal employment opportunity and the racial, 
ethnic, and gender diversity of the workforce and senior management. 
[Footnote 34] Six of eight agencies and most Reserve Banks indicated 
either their previously established equal employment opportunity 
standards or MD-715 requirements for agencies helped satisfy the Dodd-
Frank Act requirement to establish equal employment opportunity 
standards with minimal changes, while two agencies and one Reserve 
Bank were still determining how to respond to the requirement. 
Treasury and CFPB planned to develop benchmarks of best practices as 
standards for diversity and inclusion. For example, Treasury officials 
said they planned to identify qualitative measures or indicators for 
assessing workforce diversity practices. Additionally, the Reserve 
Banks of Kansas City and San Francisco revised their diversity and 
inclusion policies pursuant to Dodd-Frank Act requirements. One agency 
established new standards separate from its existing equal employment 
opportunity policies as standards for the diversity of the workforce 
and senior management. Specifically, NCUA developed a diversity and 
inclusion strategic plan in response to a government-wide executive 
order that provides diversity standards and goals, which officials 
said the agency used to help establish expectations for staff. 
[Footnote 35] 

Agencies and Reserve Banks Are Implementing Recruitment Practices: 

OMWI Annual Reports to Congress and officials we contacted indicated 
that federal financial agencies and Reserve Banks have implemented 
various practices pursuant to the Dodd-Frank Act's requirements 
regarding diversity recruiting, outlined in table 5. Most agency and 
Reserve Bank OMWIs indicated that they had been conducting various 
diversity recruitment practices prior to the enactment of the Dodd-
Frank Act--such as partnering with organizations focused on developing 
opportunities for minorities and women. 

Table 5: Federal Financial Agency and Reserve Bank Implementation of 
Dodd-Frank Act Section 342 Diversity Recruitment Requirements: 

Section: Sec. 342(f)(1); 
Requirement: Recruiting at historically black colleges and 
universities, Hispanic-serving institutions, women's colleges, and 
colleges that typically serve majority minority populations; 
Agency and Reserve Bank implementation efforts: Seven of eight 
agencies and all Reserve Banks reported on efforts to recruit from 
historically black colleges and universities and other minority-
serving institutions. Additionally, a few Reserve Banks reported on 
regional diversity recruitment efforts that included recruiting from 
two California State University locations that serve Latino 
communities. 

Section: Sec. 342(f)(2); 
Requirement: Sponsoring and recruiting at job fairs in urban 
communities; 
Agency and Reserve Bank implementation efforts: All agencies and all 
Reserve Banks participated in diversity job fairs sponsored by 
minority-serving groups. These practices included participating in 
national job fairs sponsored by the National Urban League, National 
Black MBA Association, National Association of Black Accountants, 
National Society of Hispanic MBAs, Association of Latino Professionals 
in Finance and Accounting, Society for Women Engineers, National 
Association of Asian MBAs, and the Pacific Asian Consortium in 
Employment. 

Section: Sec. 342(f)(3); 
Requirement: Placing employment advertisements in newspapers and 
magazines oriented toward minorities and women; 
Agency and Reserve Bank implementation efforts: Five agencies and all 
Reserve Banks reported on efforts to place advertisements in minority-
and women-serving publications. These included posting jobs in 
IMDiversity, Hispanic Business, EOE Journal, Diversity Life, Diversity 
Women, and Hispanic Life magazines. 

Section: Sec. 342(f)(4); 
Requirement: Partnering with organizations focused on developing 
opportunities for minorities and women to place talented young 
minorities and women in industry internships, summer employment, and 
full-time positions; 
Agency and Reserve Bank implementation efforts: Seven agencies and all 
Reserve Banks have partnerships with organizations for internship 
programs, including the Hispanic Association of Colleges and 
Universities, Washington Internships for Native Students, and INROADS, 
a nonprofit organization that trains and develops minority students 
for careers in business and industry. 

Section: Sec. 342(f)(6); 
Requirement: Any other mass media communications that the OMWI 
determines necessary; 
Agency and Reserve Bank implementation efforts: Two agencies and all 
Reserve Banks identified additional mass media communications to 
support their diversity recruiting efforts, including using social 
media networking sites such as Facebook and Twitter to reach diverse 
candidates. For example, CFPB created a recruitment website based on 
the agency's review of best practices for developing diverse applicant 
pools, and the Federal Reserve System (the Board and all the Reserve 
Banks) maintains a presence on the LinkedIn networking website. 

Source: GAO summary of Dodd-Frank Act section 342 and information 
provided by federal financial agencies and Reserve Banks. 

Note: Sec. 342(f)(5) pertains to partnering with inner-city high 
schools, girls' high schools, and majority-minority population high 
schools to establish or enhance financial literacy programs and 
provide mentoring and is not included in this list or addressed in 
this report. 

[End of table] 

The majority of agencies and Reserve Banks focused their recruitment 
efforts on attending job fairs and maintaining partnerships with 
minority-serving institutions and organizations. According to Federal 
Reserve Board and Reserve Bank officials, they collectively 
participate in and fund recruitment activities, including national 
career fairs, advertisements in diverse publications, and social media 
initiatives. The Reserve Bank of Chicago coordinates the Federal 
Reserve System's participation in national diversity recruitment 
events and oversees an internal training initiative aimed at 
developing and retaining employees within the Federal Reserve System. 
In addition to participating in these efforts, Reserve Banks conduct 
some activities independently. 

Some OMWIs indicated their diversity activities had changed due in 
part to recent efforts to satisfy section 342 requirements as well as 
broadening their approaches to diversity and inclusion. For example, 
some OMWIs indicated the scope of their diversity and inclusion 
practices had broadened to include persons with disabilities as well 
as the lesbian, gay, bisexual, and transgender community. Further, the 
majority of OMWIs reported on plans to improve or expand existing 
practices. For example, many OMWIs described plans to pursue new or 
further develop existing partnerships with organizations focused on 
developing opportunities for minorities and women, and some OMWIs 
described recent efforts to expand internship opportunities for 
minority students. 

Some OMWI officials identified practices targeted to improve 
organizationwide diversity, which could eventually help build 
management-level diversity. These included targeted recruitment to 
attract minorities and women, training for hiring managers and other 
employees on diversity hiring practices, and expanded internship 
programs as a way to hire a greater number of female and minority 
interns. 

* Targeted recruitment. All agencies and Reserve Banks with whom we 
spoke had participated in career fairs or partnerships with minority-
serving organizations, as outlined in section 342 of the Dodd-Frank 
Act, to target diversity recruitment, and in several cases bolster 
recruitment of particular populations, such as Hispanics. The OMWIs at 
FDIC, FHFA, and SEC work with the agencies' hiring and recruitment 
staff to identify strategies for recruiting diverse candidates. 
Additionally, the Federal Reserve Board OMWI reported that including 
hiring managers at diversity career fairs had made their targeted 
recruitment activities more effective. 

* Training for hiring managers. Some OMWIs reported they implemented 
practices to educate supervisors and hiring managers on diversity 
hiring practices. For example, the Reserve Bank of New York designed a 
training course to enhance cross-cultural interviewing skills of 
recruitment staff. OCC also provides diversity recruitment training to 
the agency's recruitment staff, and CFPB planned to provide its hiring 
managers a toolkit with tips on diversity hiring practices. 

* Internship programs. Many agencies and Reserve Banks implemented 
internship programs to build employment diversity by developing a more 
diverse pipeline of potential entry-level candidates. For example, the 
Reserve Bank of San Francisco reported that it expanded its internship 
program to support more interns and leveraged partnerships with 
organizations representing minorities and women to increase the 
diversity of the bank's internship program applicant pool. 

Agencies Have Taken Preliminary Steps to Develop Procedures to Assess 
Diversity Policies and Practices of Regulated Entities: 

In response to section 342 of the Dodd-Frank Act, seven federal 
financial agencies have taken preliminary steps to respond to the 
requirement to develop standards for assessing the diversity policies 
and practices of entities they oversee. While these agencies have made 
initial progress, it is too soon to evaluate how effectively the 
agencies are responding to this requirement. The affected agencies 
include CFPB, FDIC, FHFA, the Federal Reserve Board, NCUA, OCC, and 
SEC.[Footnote 36] In addition to this requirement under the Dodd-Frank 
Act, FHFA is also subject to the Housing and Economic Recovery Act of 
2008 (HERA), under which it must assess its regulated entities' 
diversity activities and meet other provisions similar to those in 
section 342.[Footnote 37] 

In 2010, FHFA developed an agency regulation implementing HERA 
requirements, in part, to ensure that diversity is a component of all 
aspects of its regulated entities' business activities. The agency's 
regulated entities include Fannie Mae, Freddie Mac, Federal Home Loan 
Banks, and the Federal Home Loan Bank System's Office of Finance. HERA 
requires the agency's regulated entities to develop diversity policies 
and procedures, staff an OMWI, and report annually to FHFA on their 
OMWI activities, among other requirements.[Footnote 38] In addition, 
FHFA has enforcement authority under HERA and FHFA's promulgated 
regulation to ensure its regulated entities have diversity standards 
in place. According to FHFA OMWI officials, the agency's response to 
HERA also satisfies the section 342 requirement. 

According to OMWI officials, other agencies reviewed FHFA's regulation 
as a possible option for responding to the section 342 requirement; 
however, the enforcement authority included in FHFA's regulation is 
unique to the agency. They said that under the Dodd-Frank Act their 
agencies do not have enforcement authority to require regulated 
entities to implement diversity standards and practices.[Footnote 39] 
Officials from the affected agencies also told us their OMWIs 
collaborated on initial steps to determine how to respond to these 
requirements by meeting periodically as a group, meeting with members 
of Congress, and performing outreach to industry participants and 
advocacy groups. 

The agency OMWI directors began meeting periodically in 2011 and began 
in 2012 to explore the possibility of developing a uniform set of 
standards that agencies could use as a baseline for developing 
standards for assessing the diversity practices of their regulated 
entities. Agency OMWI officials said the working group aimed to 
develop a set of standards for review and feedback from industry 
participants. As part of these efforts, some OMWI directors of the 
affected agencies participated in meetings with members of Congress to 
explore issues involving collection and analysis of workforce 
diversity data. Some members of the working group also held meetings 
with industry and advocacy groups to understand industry views on 
developing standards for assessing diversity policies and practices. 
One OMWI reported that industry representatives discussed options for 
evaluating diversity with respect to a regulated entity's size, 
complexity, and market area. 

OMWI officials told us responding to the requirement was a challenge 
for several reasons. Specifically, differences across regulated 
entities in terms of size, complexity, and market area made it 
challenging to develop a uniform standard. Determining the process and 
format for developing standards was also a challenge. OMWI officials 
also said they want to minimize adding a new regulatory burden to meet 
this provision. Therefore, the agencies would like to leverage 
existing information sources--data that regulated entities already 
provide--in evaluating the diversity activities of regulated entities. 
For example, to find ways to avoid duplicating existing data-
collection efforts, CFPB and NCUA were working with EEOC for access to 
EEO-1 data for regulated entities. OCC officials said OCC had also 
considered using EEO-1 data, but some regulated entities had concerns 
about maintaining proprietary information, given the potential for 
Freedom of Information Act requests.[Footnote 40] 

Efforts to Report on Measuring Outcomes and Progress Could Be Enhanced: 

In addition to establishing an OMWI, the act required federal 
financial agencies and Reserve Banks to report annually on their 
diversity practices, and nearly all of the agencies and all the 
Reserve Banks have begun reporting annually on their diversity 
practices. As discussed earlier, the act required each OMWI to submit 
to Congress an annual report on the actions taken pursuant to section 
342, including information on the percentage of amounts paid to 
minority-and women-owned contractors and successes and challenges in 
recruiting and hiring qualified minority and women employees, and 
other information as the OMWI director determines appropriate. 
Including more information on the outcomes and progress of their 
diversity practices could enhance the usefulness of these annual 
reports. Seven of eight agencies and all Reserve Banks issued annual 
reports in 2011. CFPB, which was created in July 2010 and assumed 
responsibility for certain consumer financial protection functions in 
July 2011, issued an agencywide semiannual report for 2011. Its OMWI 
planned to issue an annual report for 2012 at the same time as the 
other agencies, in March 2013. 

In their 2011 Annual OMWI Reports to Congress, several agencies and 
Reserve Banks reported on efforts to measure outcomes and progress of 
various diversity practices, which provide examples of the types of 
outcomes and measures of progress that could be helpful for OMWIs to 
include in their annual reports. Although the act requires information 
on successes and challenges, it does not specifically require 
reporting on effectiveness; however, the act provides some leeway to 
the federal financial agencies and the Reserve Banks to include "any 
other information, findings, conclusions, and recommendations for 
legislative or agency action, as the Director determines appropriate." 
[Footnote 41] Measurement of diversity practices is one of the nine 
leading diversity management practices we previously identified. We 
have reported that quantitative measures--such as tracking employment 
demographic statistics--and qualitative measures--such as evaluating 
employee feedback survey results--could help organizations translate 
their diversity aspirations into tangible practice.[Footnote 42] 

The Federal Reserve Board reported that it tracks job applicant 
information to assess the diversity of applicant pools, candidates 
interviewed, and employees hired as a result of diversity recruiting 
efforts, and FDIC reported that it monitors participation and 
attrition rates and diversity characteristics of participants in a 
development program. SEC reported plans to develop standards for 
assessing its ongoing diversity and inclusion efforts and include them 
in a strategic plan. The Reserve Banks of Chicago, Philadelphia, 
Richmond, and San Francisco reported on the number of internships each 
bank supported and the ethnic and gender diversity of the interns. The 
Reserve Bank of Chicago also reported on the number of job offers 
extended and candidates hired from its internship program, as well as 
on the number of candidates successfully hired from a diversity career 
expo. Further, the Reserve Bank of Cleveland identified reporting 
tools developed to monitor the bank's inclusion in contracting 
efforts. In addition to using these measures, some OMWI officials said 
they used annual employee surveys as a measurement tool to gather 
information about the progress of their diversity practices, including 
retention practices. For example, FDIC's annual employee survey 
includes specific questions related to diversity, and the agency uses 
responses to assess the effectiveness of policies and programs and 
outline action steps for improvement. OCC officials told us the 
government-wide federal employee viewpoint survey provided information 
on employee perspectives about diversity, and the agency measured its 
results against government-wide scores. Further, OMWI officials from 
the Reserve Bank of Minneapolis said exit surveys and employee 
declination surveys provided additional information for evaluating 
their retention and recruiting programs. 

Federal financial agencies and Reserve Banks have focused their 
initial OMWI efforts on implementing section 342 of the Dodd-Frank 
Act. While many OMWIs have implemented or are planning efforts to 
measure and evaluate the progress of their diversity and inclusion 
activities, which is consistent with the leading diversity management 
practices, information on such efforts is not yet reported 
consistently across the OMWI annual reports. According to OMWI 
officials as well as industry representatives we interviewed, 
measuring the progress of diversity recruitment and retention 
practices is a challenging, long-term process. For example, NCUA 
officials told us measuring the progress of certain recruiting 
practices could be a challenge, as access to demographic information 
about job applicants might be limited. Additionally, FHFA officials 
told us that while measuring the progress of diversity practices was 
needed to identify best practices, such measurement needs to be 
efficient and meaningful. However, without knowledge of OMWI efforts 
to measure outcomes and the progress of their diversity practices, 
Congress lacks information that would help hold OMWIs accountable for 
achieving desired outcomes. In addition, increased attention to 
evaluation and measurement through annual reporting of these efforts 
could help the OMWIs improve management of their diversity practices. 
Reporting such information would provide an opportunity for the 
agencies and Reserve Banks to learn from others' efforts to measure 
their progress and indicate areas for improvement. 

Procedures to Meet Dodd-Frank Inclusive Contracting Requirements Are 
Largely in Place: 

Section 342 of the Dodd-Frank Act requires federal financial agencies 
and Reserve Banks to develop procedures to ensure, to the maximum 
extent possible, the fair inclusion and utilization of women and 
minorities in contracting. Specifically, the act requires agency and 
Reserve Bank actions to ensure that its contractors are making efforts 
to include women and minorities in their workforce. Also, the act has 
requirements for actions to increase contracting opportunities for 
minority-and women-owned businesses (MWOB).[Footnote 43] Most agencies 
and Reserve Banks have developed and included a provision in contracts 
for services requiring their contractors to make efforts to ensure the 
fair inclusion of women and minorities in their workforce and 
subcontracted workforces. The extent to which these agencies and 
Reserve Banks have contracted with MWOBs varied widely. These entities 
reported multiple challenges to increasing contracting opportunities 
for MWOBs and used various technical assistance practices to address 
these challenges. 

Most Agencies and Reserve Banks Are Implementing Requirements Related 
to Inclusiveness in Contractor Workforces: 

To address the act's requirement to ensure the fair inclusion of women 
and minorities, to the maximum extent possible, in contracted 
workforces, agencies either have developed or are in the process of 
developing fair inclusion provisions in their contracts for services, 
and all Reserve Banks have done so. In addition, some agencies and all 
Reserve Banks have developed procedures to assess contractors' efforts 
for workforce inclusion of women and minorities. 

Fair Inclusion Provision in Contracts: 

Five agencies--FDIC, FHFA, NCUA, OCC, and the Federal Reserve Board--
and all Reserve Banks have created a fair inclusion provision and are 
using it in contracts for services. Section 342 of the Dodd-Frank Act 
requires agencies and Reserve Banks to develop procedures for review 
and evaluation of contract proposals for services and for hiring 
service providers that include a written statement that the 
contractor, and as applicable subcontractors, shall ensure, to the 
maximum extent possible, the fair inclusion of women and minorities in 
the workforce of the contractor and, as applicable, subcontractors. 
The act does not specify the elements to be included in the written 
statement and provides that each OMWI director prescribe the form and 
content of the statement. 

CFPB, SEC, and Treasury are each in the process of developing a fair 
inclusion provision. CFPB is developing procurement procedures to 
address the requirements of the act and required more time because its 
OMWI office was established in January 2012. SEC is subject to the 
Federal Acquisition Regulation (FAR) and is currently developing its 
inclusive contract provision.[Footnote 44] While CFPB and SEC develop 
inclusion statements pursuant to the act, both agencies have been 
using the equal employment opportunity statement contained in the FAR 
in executed contracts. Treasury has developed its fair inclusion 
provision to add to future contracts. It has issued a notice of 
proposed rulemaking in the Federal Register for public comments on 
this change to its contracting procedures as required under the law. 
The comment period ended on October 22, 2012. Treasury received eight 
comments which included, among other things, suggestions to make the 
fair inclusion provision applicable to all contracts regardless of the 
dollar amount of the contract and to better specify the documentation 
required of contractors to demonstrate that they have met the 
requirements of the fair inclusion provision. Treasury is currently 
reviewing the public comments and considering changes to the proposed 
rule. 

The fair inclusion provisions we reviewed contained the following: 

* Equal employment opportunity statement: Fair inclusion provisions 
include a commitment by the contractor to equal opportunity in 
employment and contracting and, to the maximum extent possible 
consistent with applicable law, the fair inclusion of women and 
minorities in the contractor's workforce. 

* Documentation: To enforce the fair inclusion provision, agencies 
require contractors to provide documentation of their efforts to 
include women and minorities in the contractor's workforce, such as a 
written affirmative action plan; documentation of the number of 
employees by race, ethnicity, and gender; information on subcontract 
awards, including whether the subcontractor is an MWOB; and any other 
actions describing the contractor's efforts toward the inclusion of 
women and minorities. 

* Contract amount threshold: Agencies apply the fair inclusion 
provision to contracts exceeding a certain dollar amount. For two 
agencies subject to the act, this threshold is any amount over 
$150,000. For three agencies subject to the act, this threshold is any 
amount over $100%,000. The Reserve Bank fair inclusion provisions we 
reviewed did not generally include a dollar-amount threshold. 

None of the officials from five agencies that have implemented a fair 
inclusion provision required by the act described to us receiving an 
adverse reaction from contractors, but officials from a majority of 
the Reserve Banks we spoke with described resistance or concerns from 
some contractors. OCC stated that smaller businesses had expressed 
confusion about the requirement because the businesses are too small 
to report workforce demographics to EEOC. Eight Reserve Banks 
described contractors expressing some disagreement or concern at the 
inclusion of the language in contracts. According to some Reserve Bank 
officials, contractors were concerned that accepting the fair 
inclusion provision would trigger other federal requirements for their 
businesses, or subject the contractor to meeting hiring or 
subcontracting targets.[Footnote 45] Some Reserve Banks described 
explaining the limited scope of the provision to concerned 
contractors. Other Reserve Banks described modifying the language in 
the fair inclusion provision, for example, in one case, changing a 
phrase regarding the contractor's efforts to include women and 
minorities from "to the maximum extent possible" to read "to the 
maximum extent required by law." Other Reserve Banks described 
occurrences where, in response to a contractor's concern, they 
excluded the fair inclusion language from contracts for a procurement 
with a small dollar amount or because the vendor provided a service 
critical to the Reserve Bank and alternate vendors were not 
available.[Footnote 46] Finally, one Reserve Bank described declining 
a contract and seeking an alternate vendor that accepted the provision. 

Procedures to Assess Contractors' Inclusion Efforts: 

Some agencies and all Reserve Banks have developed procedures to 
assess contractors' efforts toward workforce inclusion of women and 
minorities. Section 342 of the Dodd-Frank Act requires the 8 federal 
financial agencies in the act and 12 Reserve Banks to develop 
procedures to determine whether a contractor and, as applicable, a 
subcontractor, has failed to make a good faith effort to include 
minorities and women in their workforces. Good faith efforts include 
any actions intended to identify and remove barriers to employment or 
to expand employment opportunities for minorities and women in the 
workplace, according to the policies some agencies have developed. For 
example, recruiting minorities and women or providing these groups job 
training may be considered good faith efforts for diversity inclusion. 
Contractors must certify that they have made a good faith effort to 
include women and minorities in their workforces, according to most 
policies we reviewed. At the same time, contractors may provide 
documentation of their inclusion efforts such as workforce 
demographics, subcontract recipients, and the contractor's plan to 
ensure that women and minorities have opportunities to enter and 
advance within its workforce. Agencies and Reserve Banks plan to 
conduct a review of each contractor's certifications and documentation 
annually, once in a 2-year period, or at other times deemed necessary, 
such as when contracts are executed or renewed, to make a 
determination of whether the contractor made a good faith effort to 
include women and minorities in its workforce. Failure to make a good 
faith effort may result in termination of the contract, referral to 
the Office of Federal Contract Compliance Programs, or other 
appropriate action.[Footnote 47] Four agencies and all Reserve Banks 
have established good faith effort determination procedures, and four 
agencies have yet to implement such procedures. 

Levels of Contracting with Minority-and Women-Owned Businesses Varied 
by Agency and Reserve Bank: 

In 2011, the proportion of a federal financial agency's contracting 
dollars awarded to businesses owned by minorities or women varied, 
ranging between 12 percent and 38 percent according to the OMWI 
reports of the agencies (see figure 14).[Footnote 48] Seven federal 
financial agencies awarded a total of about $2.4 billion for 
contracting for external goods and services in fiscal year 2011, with 
FDIC awarding about $1.4 billion of this amount. 

Figure 14: Dollar Amount and Percentage of Total Awarded to Minority-
and Women-Owned Businesses (MWOB) by Agency, 2011: 

[Refer to PDF for image: vertical bar graph] 

Federal financial agency: OCC; 
Percent to minority- and women-owned businesses: 38.44%; 
Percent to minority-owned businesses: 37.15%; 
Percent to women-owned businesses: 5.13%; 
MWOB dollar amount awarded: $66.7 million. 

Federal financial agency: FDIC; 
Percent to minority- and women-owned businesses: 28.9%; 
Percent to minority-owned businesses: 21.7%; 
Percent to women-owned businesses: 10.8%; 
MWOB dollar amount awarded: $416.4 million. 

Federal financial agency: FHFA; 
Percent to minority- and women-owned businesses: 27.55%; 
Percent to minority-owned businesses: 27.05%; 
Percent to women-owned businesses: 3.3%; 
MWOB dollar amount awarded: $17.3 million. 

Federal financial agency: Treasury; 
Percent to minority- and women-owned businesses: 21.06%; 
Percent to minority-owned businesses: 19.67%; 
Percent to women-owned businesses: 10.73%; 
MWOB dollar amount awarded: $56.3 million. 

Federal financial agency: SEC; 
Percent to minority- and women-owned businesses: 18.%9; 
Percent to minority-owned businesses: 15.7%; 
Percent to women-owned businesses: 6.5%; 
MWOB dollar amount awarded: $45.6 million. 

Federal financial agency: NCUA; 
Percent to minority- and women-owned businesses: 13.75%; 
Percent to minority-owned businesses: 2.74%; 
Percent to women-owned businesses: 12.09%; 
MWOB dollar amount awarded: $6.8 million. 

Federal financial agency: FRB; 
Percent to minority- and women-owned businesses: 12.3%; 
Percent to minority-owned businesses: 8.9%; 
Percent to women-owned businesses: 5.1%; 
MWOB dollar amount awarded: $15.4 million. 

Source: GAO review of agency Office of Minority and Women Inclusion 
reports. 

Note: CFPB was not required to issue an OMWI report to Congress in 
2011. Percentages of dollar amounts awarded to minority-owned 
businesses and women-owned businesses displayed separately may not be 
mutually exclusive for all agencies and do not always total to the 
combined percent to minority-and women-owned business category. Some 
businesses are both minority-and women-owned and may be counted by 
agencies under both categories. 

[End of figure] 

Similarly, according to Reserve Bank OMWI reports, Reserve Bank 
contracting dollars paid to businesses owned by minorities or women 
ranged between 3 percent and 24 percent in 2011 (see figure 15). 
Reserve Banks paid about $897 million in fiscal year 2011 in 
contracting. 

Figure 15: Dollar Amount and Percentage of Total Paid to Minority-and 
Women-Owned Businesses (MWOB) by Reserve Bank, 2011: 

[Refer to PDF for image: vertical bar graph] 

Federal Reserve Bank of Minneapolis; 
Percent to minority- and women-owned businesses: 23.6%; 
Percent to minority-owned businesses: 18.5%; 
Percent to women-owned businesses: 5.1%; 
MWOB dollar amount paid: $7.5 million. 

Federal Reserve Bank of Kansas City; 
Percent to minority- and women-owned businesses: 12.2%; 
Percent to minority-owned businesses: 1.6%; 
Percent to women-owned businesses: 10.6%; 
MWOB dollar amount paid: $4.6 million. 

Federal Reserve Bank of Philadelphia; 
Percent to minority- and women-owned businesses: 11.18%; 
Percent to minority-owned businesses: 4.41%; 
Percent to women-owned businesses: 6.77%; 
MWOB dollar amount paid: $4.8 million. 

Federal Reserve Bank of Cleveland; 
Percent to minority- and women-owned businesses: 11.07%; 
Percent to minority-owned businesses: 2.42%; 
Percent to women-owned businesses: 8.65%; 
MWOB dollar amount paid: $3.0 million. 

Federal Reserve Bank of Dallas; 
Percent to minority- and women-owned businesses: 8.94%; 
Percent to minority-owned businesses: 3.86%; 
Percent to women-owned businesses: 5.08%; 
MWOB dollar amount paid: $5.6 million. 

Federal Reserve Bank of Chicago; 
Percent to minority- and women-owned businesses: 8.37%; 
Percent to minority-owned businesses: 5.33%; 
Percent to women-owned businesses: 3.04%; 
MWOB dollar amount paid: $4.3 million. 

Federal Reserve Bank of St. Louis; 
Percent to minority- and women-owned businesses: 7.09%; 
Percent to minority-owned businesses: 1.08%; 
Percent to women-owned businesses: 6.01%; 
MWOB dollar amount paid: $3.1 million. 

Federal Reserve Bank of San Francisco; 
Percent to minority- and women-owned businesses: 5.75%; 
Percent to minority-owned businesses: 2.88%; 
Percent to women-owned businesses: 2.87%; 
MWOB dollar amount paid: $3.2 million. 

Federal Reserve Bank of Atlanta; 
Percent to minority- and women-owned businesses: 5%; 
Percent to minority-owned businesses: 1.7%; 
Percent to women-owned businesses: 3.3%; 
MWOB dollar amount paid: $3.1 million. 

Federal Reserve Bank of Boston; 
Percent to minority- and women-owned businesses: 4.61%; 
Percent to minority-owned businesses: 1.72%; 
Percent to women-owned businesses: 2.89%; 
MWOB dollar amount paid: $1.5 million. 

Federal Reserve Bank of Richmond; 
Percent to minority- and women-owned businesses: 3.2%; 
Percent to minority-owned businesses: 1.2%; 
Percent to women-owned businesses: 2%; 
MWOB dollar amount paid: $8.0 million. 

Federal Reserve Bank of New York; 
Percent to minority- and women-owned businesses: 3%; 
Percent to minority-owned businesses: 1.5%; 
Percent to women-owned businesses: 1.5%; 
MWOB dollar amount paid: $5.7 million. 

Source: GAO review of Federal Reserve Bank Office of Minority and 
Women Inclusion reports. 

Note: Reserve Banks reported amounts paid to contractors in OMWI 
reports rather than amounts awarded as reported by agencies. 

[End of figure] 

Among federal financial agencies, OCC awarded the largest proportional 
amount of contracting dollars to MWOBs--about 38 percent (almost $67 
million). OCC officials told us that its contract needs tend to be for 
services for which there is often a pool of MWOB suppliers and most of 
OCC's 2011 contract dollars were spent on computer related services. 
The Federal Reserve Board awarded the smallest proportion of its 
contracting dollars to MWOBs, with about 12 percent going to such 
businesses. According to the Federal Reserve Board, a significant 
amount of its procurement is for economic data, which are generally 
not available from MWOBs. Although federal agencies are not generally 
required to report on MWOBs, most are required to report on certain 
small business contracting goals, including goals for women and small 
disadvantaged businesses (which include minority-owned businesses). 
[Footnote 49] In a 2012 report, we found that 35 percent of funds all 
federal agencies obligated to small businesses in 2011 were obligated 
to minority-owned small businesses and 17 percent were obligated to 
women-owned businesses.[Footnote 50] 

Among Reserve Banks, the Reserve Bank of Minneapolis paid the largest 
proportion of its contracting dollars to MWOBs with about 24 percent 
going to such businesses (18.5 percent to minority-owned businesses 
and about 5 percent to women-owned businesses). According to the 
Reserve Bank of Minneapolis, almost half of its MWOB contract dollars 
were paid for software and related technology integration services 
from minority-owned firms. All other Reserve Banks paid under 13 
percent of contracting dollars to MWOBs, with the Reserve Bank of New 
York awarding the smallest percentage of its contracting dollars to 
such businesses (3 percent). The Reserve Bank of New York described 
its commitment to increasing diversity in its pool of potential 
contractors through its outreach efforts to us and in its 2011 OMWI 
report. For example, the Reserve Bank of New York held an event with 
its primary contractors and small firms to identify potential 
partnerships and an event that provided small firms consultation on 
business plans and credit applications to increase the capacity of the 
small firms. 

Agencies and Reserve Banks Report Challenges to Increasing Contracting 
Opportunities and Have Offered Technical Assistance to Minority-and 
Women-Owned Businesses: 

Seven federal financial agencies included in this report and all 12 
Reserve Banks identified challenges in increasing contracting 
opportunities for MWOBs. Section 342 of the Dodd-Frank Act requires 
federal financial agencies and Reserve Banks to include in their 
annual OMWI report a description of the challenges they may face in 
contracting with qualified MWOBs. As a new agency, CFPB has not been 
required to complete an annual OMWI report and did not identify any 
contracting challenges to us. In interviews with us and in the 2011 
OMWI reports to Congress, the remaining agencies and all Reserve Banks 
discussed a number of common challenges to increasing contracting with 
MWOBs, including the following: 

* Limited capacity of MWOBs: Some agencies and Reserve Banks stated 
that reporting or other requirements under federal contracts were 
often too great a burden for MWOBs or that MWOBs needed to build 
capacity to meet federal contracting requirements. Some agencies and 
Reserve Banks also stated that at times the need for goods or services 
is not scaled to the capacity of MWOBs. For example, some agencies and 
Reserve Banks faced challenges identifying MWOBs that can meet 
procurement needs on a national scale. 

* Developing staff or procedures to meet contracting requirements of 
the act: According to some agencies, new OMWIs require additional 
staff or staff development, or procedures to meet the requirements of 
the act, including providing technical assistance to increase 
opportunities for MWOBs, identifying qualified MWOBs in the 
marketplace, and incorporating the use of a fair inclusion provision 
in contracts and good faith effort determination processes, which we 
discussed earlier, into established procurement processes. 

* MWOB classification challenges: Multiple agencies and Reserve Banks 
described difficulty identifying and classifying suppliers as diverse 
entities. Some Reserve Banks noted that no central agency is 
responsible for certifying MWOBs. Some agencies and Reserve Banks also 
discussed a need for new procedures or information systems to identify 
and classify diverse ownership of businesses. 

* Availability: Some agencies and Reserve Banks noted that specialized 
services are often only available from a limited pool of suppliers 
that may not include MWOBs. 

* Centralized procurement: Reserve Banks may use the National 
Procurement Office (NPO), the centralized procurement office for the 
12 Reserve Banks, to contract for some goods and services.[Footnote 
51] When a Reserve Bank procures through the NPO, access to MWOBs may 
be limited because the NPO procures for volume discounts with larger 
contractors. However, the Reserve Bank of Richmond, in its 2011 OMWI 
report, described efforts to work with existing large contractors to 
increase subcontracting with smaller, diverse firms. 

* No MWOB bids: In some cases, agencies and Reserve Banks found that 
potentially eligible MWOB applicants decided not to bid without 
explanation. 

Other challenges were described on a limited basis by one agency or 
Reserve Bank. For example, NCUA explained that MWOBs are not familiar 
with the agency. According to NCUA, to address this issue it increased 
its outreach budget and attendance to MWOB events and published an 
online guide on doing business with the agency. According to FDIC, in 
some cases MWOBs do not have relationships with large federal 
contractors for subcontracting opportunities. To address this problem, 
FDIC emphasizes to larger firms the importance of subcontracting with 
MWOBs and has negotiated increases in MWOB subcontracting 
participation with large contractors. FDIC participated in procurement 
events where small and large contractors could meet and match 
capabilities. The Reserve Bank of Chicago stated that MWOBs have a 
hard time standing out in highly competitive industries, such as staff 
augmentation services. Finally, according to the Reserve Bank of 
Richmond, MWOBs may have incorrect perceptions that Reserve Banks are 
subject to federal procurement rules that they cannot meet. 

To counter challenges MWOBs may face in accessing federal contracting 
opportunities, all agencies and Reserve Banks described providing 
various specific forms of technical assistance to MWOBs, which they 
described in discussions with us and in 2011 OMWI reports to Congress. 
No agency or Reserve Bank stood out as coordinating technical 
assistance better than others, although some agencies pointed to 
longstanding efforts at FDIC to provide technical assistance to MWOBs 
as model practices. Section 342 of the Dodd-Frank Act requires federal 
financial agencies and Reserve Banks to develop standards for 
coordinating technical assistance to MWOBs. These activities included 
developing and distributing literature, such as manuals and brochures 
describing contracting procedures and resources to prospective 
contractors. Most agencies also established websites that function as 
informational portals on doing business with agencies and act as an 
agency entry point to prospective contractors. Agencies and Reserve 
Banks described outreach activities to MWOBs, including conducting 
expert panels, hosting meetings and workshops, and exhibiting at trade 
shows and procurement events. Some of these outreach activities have 
been coordinated with SBA. For example, FDIC has partnered with SBA to 
develop a technical assistance program for small businesses, including 
MWOBs, on money management. OCC worked with SBA to create a technical 
assistance workshop that they conducted in 2012 with women-owned small 
businesses. Some agencies have included SBA representatives in 
supplier diversity events they sponsor. Even prior to the passage of 
the Dodd-Frank Act, the Federal Reserve Board had participated in SBA 
procurement fairs and used SBA information and events to market its 
procurement opportunities among diverse suppliers. Treasury has 
participated in SBA outreach events and created a mentor-protégé 
program to assist small businesses with contracting opportunities. 
[Footnote 52] 

Agencies and Reserve Banks also provide one-on-one technical 
assistance, which is intended to meet the specific needs of a 
prospective MWOB contractor. According to Treasury, they coordinate 
with SBA to leverage SBA's knowledge of one-on-one technical 
assistance practices with MWOBs. FHFA and SEC have created dedicated e-
mail addresses and telephone lines for MWOBs to reach their OMWIs, and 
SEC has established monthly vendor outreach days when MWOBs can speak 
one-on-one with SEC's supplier diversity officer and small-business 
specialist. Some Reserve Banks described conducting one-on-one 
meetings with prospective contractors in 2011, some of which were held 
during procurement events. Finally, FDIC offered its database of MWOBs 
to the OMWIs and some agencies described using or planning to use it 
to identify potential contractors for outreach regarding procurement 
opportunities. According to FDIC, it sends an updated version of the 
database to the agencies each quarter. 

Conclusion: 

Across financial services firms, federal financial agencies, and 
Reserve Banks, available data showed the representation of minorities 
and women varied, and there was little overall change in workforce 
diversity from 2007 through 2011. Our findings suggest the overall 
diversity of the financial services industry has generally remained 
steady following the financial crisis. Since 2011, federal financial 
agencies and Reserve Banks have taken initial steps to respond to the 
Dodd-Frank Act's requirements to promote workforce diversity, and 
OMWIs have begun reporting on both planned and existing diversity 
practices, in addition to reporting on workforce demographic 
statistics according to EEOC requirements. While many OMWIs have 
implemented or are planning efforts to measure and evaluate the 
progress of their diversity and inclusion activities, a leading 
diversity management practice, information on these efforts is not 
reported consistently across the OMWI annual reports. Although the act 
requires information on successes and challenges, it does not 
specifically require reporting on measurement; however, the act 
provides that the federal financial agencies and the Reserve Banks can 
include additional information determined appropriate by the OMWI 
director. Measurement of diversity practices is one of the nine 
leading diversity management practices we have previously identified. 
Reporting on these efforts as part of annual OMWI reporting would 
provide Congress, other OMWIs, and the financial services industry 
with potentially useful information on the ongoing implementation of 
diversity practices. Such information could be helpful industrywide, 
as management-level diversity at federal financial agencies, Reserve 
Banks, and the broader financial services industry continues to be 
largely unchanged. Without information on OMWI efforts to report 
outcomes and the progress of diversity and inclusion practices, 
Congress lacks information that would help hold agencies accountable 
for achieving desired outcomes or whether OMWI efforts are having any 
impact. 

Recommendations for Executive Action: 

To enhance the availability of information on the progress and impact 
of agency and Reserve Bank diversity practices, we are recommending to 
CFPB, FDIC, the Federal Reserve Board, FHFA, NCUA, OCC, SEC, Treasury, 
and the Reserve Banks that each OMWI report on efforts to measure the 
progress of its employment diversity and inclusion practices, 
including measurement outcomes as appropriate, to indicate areas for 
improvement as part of their annual reports to Congress. 

Agency Comments and Our Evaluation: 

We provided drafts of this report to CFPB, the Federal Reserve Board, 
FDIC, FHFA, NCUA, OCC, SEC, Treasury, and each of the Federal Reserve 
Banks for review and comment. We received written comments from each 
of the agencies and a consolidated letter from all of the Reserve 
Banks. Their comment letters are reproduced in appendixes V through 
XIII. The agencies and Reserve Banks generally agreed with our 
recommendation. CFPB, Federal Reserve Banks, FDIC, FHFA, NCUA, OCC, 
and SEC provided technical comments, which we incorporated as 
appropriate. We also provided a draft of the report to EEOC for 
comment. EEOC is not subject to the requirements of section 342 of the 
act but did provide technical comments, which we incorporated as 
appropriate. 

With respect to our recommendation that each OMWI report on efforts to 
measure the progress of its employment diversity and inclusion 
practices, including measurement outcomes as appropriate, to indicate 
areas for improvement as part of their annual reports to Congress, all 
the federal financial agencies and Reserve Banks indicated that they 
plan to implement the recommendation: 

* the OMWI Director of CFPB explained that its OMWI was the newest of 
such offices because the agency was created with the enactment of the 
Dodd-Frank Act and that it planned to include measurement information 
in future reports; 

* the OMWI Director of the Federal Reserve Board stated that the 
recommendation was consistent with its ongoing practices and that it 
would look for additional ways to report on diversity practices; 

* FDIC's OMWI Director agreed with the recommendation and stated that 
it will include efforts to measure the progress of its diversity 
practices in its annual reports to Congress; 

* the Acting Associate Director of FHFA's OMWI stated that it would 
include measurement information in its 2013 OMWI report to Congress; 

* the Executive Director of NCUA said the agency will work toward 
reporting on its efforts to measure the progress of workforce 
diversity and practices; 

* the Comptroller of the Currency stated that OCC had a well-developed 
diversity and inclusion program through which the agency measures its 
progress and that OCC has included additional metrics in its 2013 OMWI 
report to Congress; 

* SEC's OMWI Director noted that the agency plans to incorporate 
measurement information on its diversity and inclusion practices in 
its future OMWI reports to Congress; 

* Treasury's OMWI Director agreed with our recommendation and stated 
that it was consistent with the agency's efforts to use more than 
demographic representation to measure the progress of diversity and 
inclusion efforts; and: 

* the Federal Reserve Banks' OMWI directors noted that the banks 
currently include some measurement information in annual reports and 
said that they will consider additional ways to measure and report on 
Reserve Banks' diversity practices. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution of this report 
until 30 days from the report date. At that time, we will send copies 
of this report to the appropriate congressional committees; the 
Chairman, Board of Governors of the Federal Reserve; Director, Bureau 
of Consumer Financial Protection, commonly known as the Consumer 
Financial Protection Bureau; Chair, Equal Employment Opportunity 
Commission; Chairman, Federal Deposit Insurance Corporation; Acting 
Director, Federal Housing Finance Agency; Chairman, National Credit 
Union Association; Comptroller, Office of the Comptroller of the 
Currency; Chairman, Securities and Exchange Commission; Secretary, 
Department of the Treasury; and to the Directors of the Offices of 
Minority and Women's Inclusion for the Federal Reserve Banks; and 
other interested parties. We will make copies available to others upon 
request. The report will also be available at no charge on our website 
at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-8678 or garciadiazd@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs are 
listed on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix XIV. 

Sincerely yours, 

Signed by: 

Daniel Garcia-Diaz 
Director, Financial Markets and Community Investment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

The objectives for this report were to examine (1) what available data 
show about how the diversity of the financial services industry 
workforce and how diversity practices taken by the industry have 
changed from 2007 through 2011; (2) what available data show about how 
diversity in the workforces of the federal financial agencies and the 
Federal Reserve Banks (Reserve Banks) has changed from 2007 through 
2011; (3) how these federal financial agencies and Reserve Banks are 
implementing workforce diversity practices under section 342 of the 
Dodd-Frank Act, including the extent to which their workforce 
diversity practices have changed since the financial crisis; and (4) 
the status of federal financial agencies' and Reserve Banks' 
implementation of the contracting provisions of the Dodd-Frank Act 
related to the inclusion of women and minorities. 

To describe how diversity in the financial services industry has 
changed since the beginning of the 2007-2009 financial crisis, we 
analyzed 2007-2011 workforce data from the Equal Employment 
Opportunity Commission's (EEOC) Employer Information Report (EEO-1). 
EEO-1 is data annually submitted to EEOC generally by private-sector 
firms with more than 100% employees.[Footnote 53] We obtained EEO-1 
data on October 2012, from the finance and insurance industry 
categorized under the North American Industry Classification System 
(NAICS) code 52 for these industries from 2007 through 2011. EEO-1 
data were specifically obtained from the EEOC's "officials and 
managers" category by gender, race/ethnicity, firm size, and industry 
sectors.[Footnote 54] The EEO-1 "officials and managers" category was 
further divided into two management-level categories of first-and mid-
level managers and senior-level managers and then analyzed by gender, 
race/ethnicity, and firm size.[Footnote 55] To understand the 
potential internal candidate pools available for management positions 
in the financial industry, we obtained EEO-1 data under NAICS code 52 
for all positions, including nonmanagement positions, by gender and 
race/ethnicity. To determine the reliability of the EEO-1 data that we 
received from EEOC, we interviewed knowledgeable EEOC officials and 
reviewed relevant documents provided by agency officials and obtained 
on its website. We also conducted electronic testing of the data. We 
determined that the EEO-1 data were sufficiently reliable for our 
purposes. 

To corroborate the results of the EEO-1 data, we used an additional 
source of workforce diversity data from the Current Population Survey 
(CPS), a monthly survey of households the Bureau of the Census 
administers on behalf of the Bureau of Labor Statistics. CPS data 
provide information on labor force characteristics and demographic 
data, among other topics. Similar to the EEO-1 "officials and 
managers" job category, we used the CPS "management occupations" 
category--unlike EEO-1, CPS does not split its management into two 
levels--for our discussion of management-level diversity within the 
financial services industry. However, the statistics from these two 
sources are not exactly comparable. We determined the CPS-estimated 
percentages of minorities in management positions within the financial 
services industry could not be precisely measured.[Footnote 56] See 
table 6 for the estimated percentages and standard errors. The 
standard errors for the minority percentages were greater than the 
standard errors for the white percentages, and they were relatively 
large compared to the estimated percentage for minorities. However, 
CPS minority percentages were included in this report for additional 
context. To determine the reliability of CPS data, which we obtained 
from a publicly accessible federal statistical database, we gathered 
and reviewed relevant documentation from the Bureau of the Census 
website, conducted electronic testing, and determined the standard 
errors of the CPS estimates. We determined that the CPS data were 
sufficiently reliable for our purposes. 

Table 6: Estimated Percentages and Standard Errors for Race/Ethnicity 
in Management Positions in the Financial Services Industry Using the 
Current Population Survey (CPS), 2007-2011: 

Year: 2007; 
Race/ethnicity: White; 
Percentage: 85.9%; 
Standard errors: 1.7%. 

Year: 2007; 
Race/ethnicity: Minority; 
Percentage: 14.1%; 
Standard errors: 4.5%. 

Year: 2008; 
Race/ethnicity: White; 
Percentage: 85.9%; 
Standard errors: 1.7%. 

Year: 2008; 
Race/ethnicity: Minority; 
Percentage: 14.1%; 
Standard errors: 4.5%. 

Year: 2009; 
Race/ethnicity: White; 
Percentage: 83.1%; 
Standard errors: 1.9%. 

Year: 2009; 
Race/ethnicity: Minority; 
Percentage: 16.9%; 
Standard errors: 4.5%. 

Year: 2010; 
Race/ethnicity: White; 
Percentage: 86.0%; 
Standard errors: 1.8%. 

Year: 2010; 
Race/ethnicity: Minority; 
Percentage: 14.0%; 
Standard errors: 4.7%. 

Year: 2011; 
Race/ethnicity: White; 
Percentage: 84.9%; 
Standard errors: 1.8%. 

Year: 2011; 
Race/ethnicity: Minority; 
Percentage: 15.1%; 
Standard errors: 4.6%. 

Source: GAO analysis of CPS data. 

[End of table] 

To gather information on a potential external pipeline of diverse 
candidates for management positions in the financial industry, we 
obtained demographic data on minority and female students enrolled in 
undergraduate, Master of Business Administration (MBA), and doctoral 
degree programs from 2007 through 2011 from the Association to Advance 
Collegiate Schools of Business (AACSB). We focused on MBA programs as 
a source of potential future managers and senior executives. Financial 
services firms compete for minorities in this pool with one another 
and with firms from other industries. We combined this information 
with undergraduate and doctoral degree programs to provide information 
on the overall diversity of the university system. AACSB conducts an 
annual voluntary survey called "Business School Questionnaire" of all 
its member schools. In 2011, AACSB updated its survey to include two 
additional race/ethnicity categories to include "two or more races" 
and "Native Hawaiian or Other Pacific Islander." For consistency 
purposes, we combined these two additional categories along with the 
representation of Native Americans into an "other" category. To 
determine the reliability of the AACSB data, we interviewed a 
knowledgeable AACSB official and reviewed relevant documents provided 
by the official and obtained on its website. We determined that the 
data from AACSB were sufficiently reliable for our purposes. 

To determine how diversity practices in the financial services 
industry have changed since the beginning of the financial crisis, we 
conducted a literature review of relevant studies that discussed 
diversity best practices within the financial services industry from 
2007 through 2011. In addition, we interviewed 10 selected industry 
representatives to determine whether the nine leading diversity 
practices we previously identified are relevant today and how 
diversity practices changed since 2007. We also reviewed documents 
produced by these industry representatives. These representatives were 
selected based on their participation in our previous work, 
suggestions from federal agencies we interviewed for this report, as 
well as the type of industry representative--such as an industry 
association or private firm.[Footnote 57] 

To describe diversity in the workforces of the federal financial 
agencies and Reserve Banks, we analyzed data we received from agencies 
and banks. To review changes in the representation of minorities and 
women in the workforces of federal financial agencies, we obtained 
from the agencies annual Equal Employment Opportunity Program Status 
Reports from 2007 through 2011, required under U.S. EEOC Management 
Directive 715 and known as MD-715 reports.[Footnote 58] We obtained 
data from seven of the eight federal agencies required to meet the 
workforce diversity provisions in section 342 of the Dodd-Frank Wall 
Street Reform and Consumer Protection Act (Dodd-Frank Act). These 
included the Departmental Offices of the Department of the Treasury, 
the Federal Deposit Insurance Corporation, the Federal Housing Finance 
Agency (FHFA), the Board of Governors of the Federal Reserve System, 
the National Credit Union Administration, the Office of the 
Comptroller of the Currency, and the Securities and Exchange 
Commission. The Bureau of Consumer Financial Protection, commonly 
known as the Consumer Financial Protection Bureau (CFPB), was created 
in July 2010 and assumed responsibility for certain consumer financial 
protection functions in 2011; workforce diversity data for the agency 
to show trends from 2007 through 2011 were unavailable.[Footnote 59] 
Additionally, our trend analysis excluded FHFA, as the agency was 
created in 2008 and did not report on diversity employment statistics 
for 2007, 2008, or 2009. Further, our senior management-level trend 
analysis excluded SEC, as the agency revised how it reported officials 
and managers during the 5-year period. To review changes in the 
representation of minorities and women in the workforces of Reserve 
Banks, we obtained from banks their annual EEO-1 reports from 2007 
through 2011.[Footnote 60] For agencies and Reserve Banks, we reviewed 
workplace employment data by occupational categories, distributed by 
race/ethnicity and gender.[Footnote 61] In our analyses, we considered 
all categories other than white as race/ethnic minorities and analyzed 
trends in diversity at both the senior management-level and agency-and 
bankwide.[Footnote 62] We analyzed senior management-level and overall 
diversity trends across all agencies and all Reserve Banks, as well as 
diversity trends for each agency when trend information was available. 

To assess the reliability of MD-715 and EEO-1 data we received from 
agencies and Reserve Banks, we interviewed EEOC officials on both 
types of data as well as agency officials on MD-715 data and Reserve 
Bank officials on EEO-1 data about how the data are collected and 
verified as well as to identify potential data limitations. We found 
that while agencies and banks rely on employees to provide their race 
and ethnicity information, agencies and banks had measures in place to 
verify and correct missing or erroneous data prior to reporting them 
and officials with whom we spoke generally agreed these data were 
generally accurate. Based on our analysis, we concluded that the MD-
715 and EEO-1 data were sufficiently reliable for our purposes. 

To assess how federal financial agencies and Reserve Banks are 
implementing workforce diversity practices under section 342 of the 
Dodd-Frank Act, we reviewed agency and bank documentation of efforts 
to respond to the act's requirements. Sources included annual Office 
of Minority and Women Inclusion (OMWI) reports to Congress by agencies 
and banks, annual agency MD-715 reports, and other documentation 
provided to us by agency and bank OMWI officials. Additionally, we 
gathered testimonial information from agency and Reserve Bank OMWI 
officials on changes in the inclusion of women and minorities in their 
workforces and any changes in the practices used to further workforce 
diversity goals. Through our review of agency and Reserve Bank 
documentation and interviews with OMWI officials, we assessed agency 
and Reserve Bank efforts to measure and report on the progress of 
their diversity practices, as measurement was one of the nine leading 
diversity practices we previously identified. 

To determine the extent to which agencies and Reserve Banks are 
implementing the requirements of the Dodd-Frank Act regarding the 
inclusion of women and minorities in contracting, we reviewed 2011 
OMWI reports submitted to Congress and interviewed officials on their 
efforts in this area. We also reviewed OMWI reports to determine the 
dollar amount and percentage of total contracts federal financial 
agencies reported awarding to minority-and women-owned businesses 
(MWOB), and the dollar amount and percentage of total contracts 
Reserve Banks reporting paying MWOBs in 2011. We verified these 
figures and our presentation of the information with each agency and 
Reserve Bank, and we determined that these data were sufficiently 
reliable for our purposes. We interviewed agency officials on their 
efforts to coordinate with the Small Business Administration and other 
federal agencies to provide technical assistance to minority-and women-
owned businesses. We collected and reviewed agency documentation of 
procedures developed to address the act's requirements, such as policy 
manuals, process workflows, and technical assistance materials. We 
also collected and reviewed examples of fair inclusion provisions used 
in agency and Reserve Bank contracts as required in section 342 of the 
Dodd-Frank Act. 

We conducted this performance audit from January 2012 to March 2013 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Additional Analysis of the Financial Services Industry: 

This appendix provides additional detailed analysis of EEOC data on 
the financial services industry by workforce position and industry 
sector from 2007 through 2011. 

Analysis by Workforce Positions: 

The representation of minorities by gender was below 45 percent across 
all the positions throughout the same 5-year period (see figure 16). 
For example, in sales positions, the representation of minorities was 
higher among women (about 31 percent) than among men (about 17 
percent). Similarly, at the professional level, the representation of 
minority women was about 27 percent, compared to about 23 percent for 
minority men. 

Figure 16: Percentage of Minority Women and Minority Men in Various 
Industry Workforce Positions in the Financial Services Industry, 2007-
2011: 

[Refer to PDF for image: 8 multiple line graphs] 

Total workforce: 

Year: 2007; 
Minority men: 24.6%; 
Minority women: 30.5%. 

Year: 2008; 
Minority men: 24.5%; 
Minority women: 30.7%. 

Year: 2009; 
Minority men: 24.3%; 
Minority women: 30.5%. 

Year: 2010; 
Minority men: 24.3%; 
Minority women: 30.3%. 

Year: 2011; 
Minority men: 24.7%; 
Minority women: 30.5%. 

Senior level: 

Year: 2007; 
Minority men: 9.2%; 
Minority women: 13.7%. 

Year: 2008; 
Minority men: 9.3%; 
Minority women: 13.3%. 

Year: 2009; 
Minority men: 8.9%; 
Minority women: 12.6%. 

Year: 2010; 
Minority men: 9.1; 
Minority women: 12.4%. 

Year: 2011; 
Minority men: 9.7%; 
Minority women: 13.5%. 

First- and mid-level: 

Year: 2007; 
Minority men: 16.3%; 
Minority women: 21.2%. 

Year: 2008; 
Minority men: 16.8%; 
Minority women: 21.8%. 

Year: 2009; 
Minority men: 16.9%; 
Minority women: 21.9%. 

Year: 2010; 
Minority men: 17.5%; 
Minority women: 22.3%. 

Year: 2011; 
Minority men: 18.2%; 
Minority women: 22.9%. 

Professional level: 

Year: 2007; 
Minority men: 22.5%; 
Minority women: 26.4%. 

Year: 2008; 
Minority men: 23%; 
Minority women: 26.9%. 

Year: 2009; 
Minority men: 22.6%; 
Minority women: 26.4%. 

Year: 2010; 
Minority men: 22.7%; 
Minority women: 26.2%. 

Year: 2011; 
Minority men: 23.2%; 
Minority women: 26.8%. 

Technical level: 

Year: 2007; 
Minority men: 26.9%; 
Minority women: 27.5%. 

Year: 2008; 
Minority men: 28.1%; 
Minority women: 28.8%. 

Year: 2009; 
Minority men: 28.1%; 
Minority women: 29.5%. 

Year: 2010; 
Minority men: 28.3%; 
Minority women: 29.6%. 

Year: 2011; 
Minority men: 29.4%; 
Minority women: 30.7%. 

Sales level: 

Year: 2007; 
Minority men: 21.8%; 
Minority women: 36.2%. 

Year: 2008; 
Minority men: 17.8%; 
Minority women: 32.3%. 

Year: 2009; 
Minority men: 16.9%; 
Minority women: 31.4%. 

Year: 2010; 
Minority men: 16.9%; 
Minority women: 29.9%. 

Year: 2011; 
Minority men: 17.4%; 
Minority women: 30.6%. 

Clerical level: 

Year: 2007; 
Minority men: 38.6%; 
Minority women: 37.2%. 

Year: 2008; 
Minority men: 38.4%; 
Minority women: 37.9%. 

Year: 2009; 
Minority men: 37.7%; 
Minority women: 37.8%. 

Year: 2010; 
Minority men: 37.3%; 
Minority women: 37.7%. 

Year: 2011; 
Minority men: 37.6%; 
Minority women: 38%. 

Other: 

Year: 2007; 
Minority men: 34%; 
Minority women: 41.9%. 

Year: 2008; 
Minority men: 33.8%; 
Minority women: 42.2%. 

Year: 2009; 
Minority men: 34%; 
Minority women: 41%. 

Year: 2010; 
Minority men: 33.6%; 
Minority women: 42.1%. 

Year: 2011; 
Minority men: 33.1%; 
Minority women: 42.3%. 

Source: GAO analysis of EEOC data. 

Note: The category "other" includes craft workers, operatives, 
laborers, and service workers. 

[End of figure] 

Analysis by Industry Sectors: 

Diversity remained about the same across all industry sectors in terms 
of both the representation of women and minorities.[Footnote 63] From 
2007 through 2011, the representation of women decreased slightly in 
most industry sectors and remained below 50 percent in all sectors 
(see figure 17). The "insurance carriers and related activities" 
sector was the only sector that showed an increase in the 
representation of women, from 47.7 percent to 48.2 percent. In 
contrast, the representation of minorities increased across all 
sectors. Specifically, from 2007 through 2011 the representation of 
minorities in the "monetary authorities-central bank" sector increased 
from 17 percent to 19.8 percent, and the "funds, trusts, and other 
financial vehicle" sector increased from 16 percent to 18.5 percent. 

Figure 17: Percentage of Whites/Minorities and Men/Women in Various 
Sectors of the Financial Services Industry, 2007-2011: 

[Refer to PDF for image: 5 stacked vertical bar graphs] 

521 Monetary Authorities Central Bank: 

Year: 2007; 
Minority: 17%; 
White: 83%; 
Women: 48.3%; 
Men: 51.7%. 

Year: 2008; 
Minority: 19.1%; 
White: 80.9%; 
Women: 49%; 
Men: 51%. 

Year: 2009; 
Minority: 19.6%; 
White: 80.4%; 
Women: 48.7%; 
Men: 51.3%. 

Year: 2010; 
Minority: 19%; 
White: 81%; 
Women: 47.3%; 
Men: 52.7%. 

Year: 2011; 
Minority: 19.8%; 
White: 80.2%; 
Women: 48.1%; 
Men: 51.9%. 

522 Credit Intermediation and Related Activities: 

Year: 2007; 
Minority: 19.7%; 
White: 80.3%; 
Women: 47.2%; 
Men: 52.8%. 

Year: 2008; 
Minority: 20.2%; 
White: 79.8%; 
Women: 47.3%; 
Men: 52.7%. 

Year: 2009; 
Minority: 20.5%; 
White: 79.5%; 
Women: 46.8%; 
Men: 53.2%. 

Year: 2010; 
Minority: 21.1%; 
White: 78.9%; 
Women: 46.4%; 
Men: 53.6%. 

Year: 2011; 
Minority: 21.8%; 
White: 78.2%; 
Women: 45.8%; 
Men: 54.2%. 

523 Securities Commodity Contracts and Other Financial Investments and 
Related Activities: 

Year: 2007; 
Minority: 16.2%; 
White: 83.8%; 
Women: 33.1%; 
Men: 66.9%. 

Year: 2008; 
Minority: 16.7%; 
White: 83.3%; 
Women: 34.5%; 
Men: 65.5%. 

Year: 2009; 
Minority: 17%; 
White: 83%; 
Women: 34%; 
Men: 66%. 

Year: 2010; 
Minority: 17.5%; 
White: 82.5%; 
Women: 32.8%; 
Men: 67.2%. 

Year: 2011; 
Minority: 17.9%; 
White: 82.1%; 
Women: 32.8%; 
Men: 67.7%. 

524 Insurance Carriers and Related Activities: 

Year: 2007; 
Minority: 15%; 
White: 85%; 
Women: 47.7%; 
Men: 52.3%. 

Year: 2008; 
Minority: 15.8%; 
White: 84.2%; 
Women: 47.6%; 
Men: 52.4%. 

Year: 2009; 
Minority: 15.5%; 
White: 84.5%; 
Women: 48%; 
Men: 52%. 

Year: 2010; 
Minority: 15.9%; 
White: 84.1%; 
Women: 48%; 
Men: 52%. 

Year: 2011; 
Minority: 16.4%; 
White: 83.6%; 
Women: 48.2%; 
Men: 51.8%. 

525 Funds, trusts, and other financial: 

Year: 2007; 
Minority: 16%; 
White: 84%; 
Women: 39.9%; 
Men: 60.1%. 

Year: 2008; 
Minority: 19%; 
White: 81%; 
Women: 39.5%; 
Men: 60.5%. 

Year: 2009; 
Minority: 18.3%; 
White: 81.7%; 
Women: 39.7%; 
Men: 60.3%. 

Year: 2010; 
Minority: 18%; 
White: 82%; 
Women: 40%; 
Men: 60%. 

Year: 2011; 
Minority: 18.5%; 
White: 81.5%; 
Women: 39.5%; 
Men: 60.5%. 

Source: GAO analysis of EEOC data. 

Note: Industry sector numbers are defined as follows: Sector 521, 
Monetary Authorities-Central Bank; Sector 522, Credit Intermediation 
and Related Activities; Sector 523, Securities, Commodity Contracts, 
and Other Financial Investments and Related Activities; Sector 524, 
Insurance Carriers and Related Activities; Sector 525, Funds, Trusts, 
and Other Financial Vehicles. 

[End of figure] 

[End of section] 

Appendix III: Additional Analysis of Overall Workforce Diversity at 
Agencies and Reserve Banks: 

This appendix provides information accompanying our review of changes 
in overall workforce diversity at federal financial agencies and the 
12 Reserve Banks from 2007 through 2011.[Footnote 64] Tables 11 
through 14 in appendix IV provide data supporting the figures in this 
appendix. 

According to MD-715 data, the representation of minorities in the 
overall workforce of the agencies, in aggregate, changed little from 
2007 through 2011. Percentage point changes in the representation of 
minorities at FDIC, the Federal Reserve Board, NCUA, OCC, SEC, and 
Treasury varied from a 5 percentage point decrease at Treasury to a 3 
percentage point increase at NCUA. In 2011, the representation of 
minorities in the overall workforce of the agencies and FHFA ranged 
from 25 percent at NCUA to 44 percent at the Federal Reserve Board. 

Figure 18: Percentage of Minorities among All Employees at Seven 
Federal Financial Agencies, 2007-2011: 

[Refer to PDF for image: 8 multiple line graphs] 

All agencies[A]: 

Year: 2007; 
Total minority: 31%; 
Black or African-American: 20%; 
Hispanic: 4%; 
Asian: 5%; 
Other: 2%. 

Year: 2008; 
Total minority: 31%; 
Black or African-American: 20%; 
Hispanic: 4%; 
Asian: 6%; 
Other: 1%. 

Year: 2009; 
Total minority: 31%; 
Black or African-American: 19%; 
Hispanic: 4%; 
Asian: 6%; 
Other: 1%. 

Year: 2010; 
Total minority: 30%; 
Black or African-American: 18%; 
Hispanic: 4%; 
Asian: 6%; 
Other: 2%. 

Year: 2011; 
Total minority: 30%; 
Black or African-American: 18%; 
Hispanic: 4%; 
Asian: 6%; 
Other: 1%. 

FDIC 

Year: 2007; 
Total minority: 26%; 
Black or African-American: 18%; 
Hispanic: 4%; 
Asian: 1%; 
Other: 4%. 

Year: 2008; 
Total minority: 27%; 
Black or African-American: 19%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 1%. 

Year: 2009; 
Total minority: 26%; 
Black or African-American: 17%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 1%. 

Year: 2010; 
Total minority: 27%; 
Black or African-American: 16%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 1%. 

Year: 2011; 
Total minority: 27%; 
Black or African-American: 16%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 2%. 

Federal Reserve Board: 

Year: 2007; 
Total minority: 45%; 
Black or African-American: 30%; 
Hispanic: 3%; 
Asian: 10%; 
Other: 2%. 

Year: 2008; 
Total minority: 45%; 
Black or African-American: 30%; 
Hispanic: 3%; 
Asian: 10%; 
Other: 2%. 

Year: 2009; 
Total minority: 45%; 
Black or African-American: 29%; 
Hispanic: 3%; 
Asian: 11%; 
Other: 2%. 

Year: 2010; 
Total minority: 44%; 
Black or African-American: 27%; 
Hispanic: 4%; 
Asian: 11%; 
Other: 2%. 

Year: 2011; 
Total minority: 44%; 
Black or African-American: 26%; 
Hispanic: 4%; 
Asian: 12%; 
Other: 2%. 

FHFA: 

Year: 2010; 
Total minority: 33%; 
Black or African-American: 22%; 
Hispanic: 3%; 
Asian: 8%. 

Year: 2011; 
Total minority: 32%; 
Black or African-American: 19%; 
Hispanic: 3%; 
Asian: 9%. 

NCUA: 

Year: 2007; 
Total minority: 22%; 
Black or African-American: 14%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 2%. 

Year: 2008; 
Total minority: 23%; 
Black or African-American: 14%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 1%. 

Year: 2009; 
Total minority: 25%; 
Black or African-American: 15%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 2%. 

Year: 2010; 
Total minority: 24%; 
Black or African-American: 13%; 
Hispanic: 4%; 
Asian: 5%; 
Other: 2%. 

Year: 2011; 
Total minority: 25%; 
Black or African-American: 14%; 
Hispanic: 4%; 
Asian: 5%; 
Other: 2%. 

OCC: 

Year: 2007; 
Total minority: 28%; 
Black or African-American: 17%; 
Hispanic: 5%; 
Asian: 5; 
Other: 1%. 

Year: 2008; 
Total minority: 29; 
Black or African-American: 17%; 
Hispanic: 6; 
Asian: 5; 
Other: 1%. 

Year: 2009; 
Total minority: 30%; 
Black or African-American: 17%; 
Hispanic: 6%; 
Asian: 5%; 
Other: 2%. 

Year: 2010; 
Total minority: 30%; 
Black or African-American: 17%; 
Hispanic: 6%; 
Asian: 6%; 
Other: 2%. 

Year: 2011; 
Total minority: 30%; 
Black or African-American: 16%; 
Hispanic: 6%; 
Asian: 6%; 
Other: 2%. 

SEC: 

Year: 2007; 
Total minority: 30%; 
Black or African-American: 17%; 
Hispanic: 4%; 
Asian: 8%; 
Other: 1%. 

Year: 2008; 
Total minority: 32%; 
Black or African-American: 18%; 
Hispanic: 4%; 
Asian: 9%; 
Other: 1%. 

Year: 2009; 
Total minority: 32%; 
Black or African-American: 18%; 
Hispanic: 4%; 
Asian: 9%; 
Other: 2%. 

Year: 2010; 
Total minority: 32%; 
Black or African-American: 18%; 
Hispanic: 3%; 
Asian: 9%; 
Other: 2%. 

Year: 2011; 
Total minority: 31%; 
Black or African-American: 17%; 
Hispanic: 5%; 
Asian: 9; 
Other: 1%. 

Treasury: 

Year: 2007; 
Total minority: 37%; 
Black or African-American: 28%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 1%. 

Year: 2008; 
Total minority: 36%; 
Black or African-American: 27%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 1%. 

Year: 2009; 
Total minority: 32%; 
Black or African-American: 24%; 
Hispanic: 4%; 
Asian: 4%; 
Other: 1%. 

Year: 2010; 
Total minority: 32%; 
Black or African-American: 23%; 
Hispanic: 3%; 
Asian: 5%; 
Other: 1%. 

Year: 2011; 
Total minority: 31%; 
Black or African-American: 22%; 
Hispanic: 3%; 
Asian: 5%; 
Other: 1%. 

Source: GAO analysis of agency reports. 

Note: Figures are rounded to the nearest percent. 

For our analysis, we reviewed the numbers of employees the agencies 
reported according to race/ethnicity and gender in table A3 of their 
MD-715 reports from 2007 through 2011. These data are based on 
information self-reported by employees to each agency and there were 
some differences in reporting across the agencies. In some years, some 
agencies reported all employees--permanent and temporary--in their A3 
tables while others reported permanent employees only. 

[A] Our trend analysis for "all agencies" excludes CFPB and FHFA. CFPB 
assumed responsibility for certain consumer financial protection 
functions in July 2011 and has not yet reported workforce information 
to EEOC. FHFA was established in 2008 and started reporting workforce 
data for 2010. 

[End of figure] 

Similarly, we found that the representation of women in the overall 
workforce of the agencies did not change significantly from 2007 
through 2011. Percentage point changes in the representation of women 
at the agencies from 2007 through 2011 varied from a 2 percentage 
point decrease at FDIC, the Federal Reserve Board, and Treasury to no 
percentage point change at NCUA and SEC. In 2011, the representation 
of minorities in the overall workforce of the agencies and FHFA ranged 
from 42 percent at FDIC to 48 percent at SEC and Treasury. 

Figure 19: Percentage of Women among All Employees at Seven Federal 
Financial Agencies, 2007-2011: 

[Refer to PDF for image: 8 stacked vertical bar graphs] 

All Agencies[A]: 

Year: 2007; 
Women: 47%; 
Men: 53%. 

Year: 2008; 
Women: 47%; 
Men: 53%. 

Year: 2009; 
Women: 46%; 
Men: 54%. 

Year: 2010; 
Women: 45%; 
Men: 55%. 

Year: 2011; 
Women: 45%; 
Men: 55%. 

FDIC: 

Year: 2007; 
Women: 44%; 
Men: 56%. 

Year: 2008; 
Women: 44%; 
Men: 56%. 

Year: 2009; 
Women: 43%; 
Men: 57%. 

Year: 2010; 
Women: 42%; 
Men: 58%. 

Year: 2011; 
Women: 42%; 
Men: 58%. 

Federal Reserve Board: 

Year: 2007; 
Women: 47%; 
Men: 53%. 

Year: 2008; 
Women: 47%; 
Men: 53%. 

Year: 2009; 
Women: 47%; 
Men: 53%. 

Year: 2010; 
Women: 47%; 
Men: 53%. 

Year: 2011; 
Women: 46%; 
Men: 54%. 

FHFA: 

Year: 2010; 
Women: 46%; 
Men: 54%. 

Year: 2011; 
Women: 44%; 
Men: 56%. 

NCUA: 

Year: 2007; 
Women: 45%; 
Men: 55%. 

Year: 2008; 
Women: 45%; 
Men: 55%. 

Year: 2009; 
Women: 46%; 
Men: 54%. 

Year: 2010; 
Women: 46%; 
Men: 54%. 

Year: 2011; 
Women: 45%; 
Men: 55%. 

OCC: 

Year: 2007; 
Women: 48%; 
Men: 52%. 

Year: 2008; 
Women: 48%; 
Men: 52%. 

Year: 2009; 
Women: 48%; 
Men: 52%. 

Year: 2010; 
Women: 48%; 
Men: 52%. 

Year: 2011; 
Women: 46%; 
Men: 54%. 

SEC: 

Year: 2007; 
Women: 48%; 
Men: 52%. 

Year: 2008; 
Women: 48%; 
Men: 52%. 

Year: 2009; 
Women: 48%; 
Men: 52%. 

Year: 2010; 
Women: 48%; 
Men: 52%. 

Year: 2011; 
Women: 48%; 
Men: 52%. 

Treasury: 

Year: 2007; 
Women: 50%; 
Men: 50%. 

Year: 2008; 
Women: 49%; 
Men: 51%. 

Year: 2009; 
Women: 48%; 
Men: 52%. 

Year: 2010; 
Women: 48%; 
Men: 52%. 

Year: 2011; 
Women: 48%; 
Men: 52%. 

Note: Figures are rounded to the nearest percent. 

For our analysis, we reviewed the numbers of employees the agencies 
reported according to race/ethnicity and gender in table A3 of their 
MD-715 reports from 2007 through 2011. These data are based on 
information self-reported by employees to each agency and there were 
some differences in reporting across the agencies. In some years, some 
agencies reported all employees--permanent and temporary--in their A3 
tables while others reported permanent employees only. 

[A] Our trend analysis for "all agencies" excludes CFPB and FHFA. CFPB 
assumed responsibility for certain consumer financial protection 
functions in July 2011 and has not yet reported workforce information 
to EEOC. FHFA was established in 2008 and started reporting workforce 
data for 2010. 

[End of figure] 

According to EEO-1 data provided by the Reserve Banks, the 
representation of minorities in the overall workforce of the Reserve 
Banks decreased somewhat from 2007 through 2011. The banks showed 
changes in the representation of minorities from 2007 through 2011, 
from an 8 percentage point decrease at the Reserve Bank of 
Philadelphia, to a 2 percentage point increase at the Reserve Banks of 
Minneapolis and New York. The Reserve Bank of Boston showed no 
percentage point change from 2007 through 2011. In 2011, the 
representation of minorities in the overall workforce of the Reserve 
Banks ranged from 16 percent at the Reserve Bank of Kansas City to 53 
percent at the Reserve Bank of San Francisco. 

Figure 20: Percentage of Minorities among All Employees at the 12 
Reserve Banks, 2007-2011: 

[Refer to PDF for image: 10 multiple line graphs] 

All Reserve Banks 

Year: 2007; 
Total minority: 38%; 
Black or African-American: 23%; 
Hispanic: 7%; 
Asian: 8%; 
Other: 0%. 

Year: 2008; 
Total minority: 38%; 
Black or African-American: 21%; 
Hispanic: 7%; 
Asian: 9%; 
Other: 1%. 

Year: 2009; 
Total minority: 37%; 
Black or African-American: 19%; 
Hispanic: 7%; 
Asian: 10%; 
Other: 1%. 

Year: 2010; 
Total minority: 36%; 
Black or African-American: 18%; 
Hispanic: 7%; 
Asian: 10%; 
Other: 1%. 

Year: 2011; 
Total minority: 36%; 
Black or African-American: 18%; 
Hispanic: 7%; 
Asian: 10%; 
Other: 1%. 

Atlanta: 

Year: 2007; 
Total minority: 53%; 
Black or African-American: 41%; 
Hispanic: 8%; 
Asian: 4%; 
Other: 0%. 

Year: 2008; 
Total minority: 52%; 
Black or African-American: 40%; 
Hispanic: 8%; 
Asian: 4%; 
Other: 0%. 

Year: 2009; 
Total minority: 50%; 
Black or African-American: 37%; 
Hispanic: 9%; 
Asian: 4%; 
Other: 1%. 

Year: 2010; 
Total minority: 48%; 
Black or African-American: 34%; 
Hispanic: 9%; 
Asian: 4%; 
Other: 1%. 

Year: 2011; 
Total minority: 47%; 
Black or African-American: 33%; 
Hispanic: 9%; 
Asian: 4%; 
Other: 1%. 

Boston: 

Year: 2007; 
Total minority: 31%; 
Black or African-American: 13%; 
Hispanic: 5%; 
Asian: 12%; 
Other: 0%. 

Year: 2008; 
Total minority: 31%; 
Black or African-American: 13%; 
Hispanic: 5%; 
Asian: 12%; 
Other: 0%. 

Year: 2009; 
Total minority: 30%; 
Black or African-American: 12%; 
Hispanic: 5%; 
Asian: 12%; 
Other: 0%. 

Year: 2010; 
Total minority: 29%; 
Black or African-American: 12%; 
Hispanic: 5%; 
Asian: 12%; 
Other: 0%. 

Year: 2011; 
Total minority: 31%; 
Black or African-American: 12%; 
Hispanic: 5%; 
Asian: 13%; 
Other: 0%. 

Chicago: 

Year: 2007; 
Total minority: 39%; 
Black or African-American: 26%; 
Hispanic: 6%; 
Asian: 7%; 
Other: 1%. 

Year: 2008; 
Total minority: 39%; 
Black or African-American: 24%; 
Hispanic: 7%; 
Asian: 7%; 
Other: 1%. 

Year: 2009; 
Total minority: 38%; 
Black or African-American: 22%; 
Hispanic: 8%; 
Asian: 7%; 
Other: 1%. 

Year: 2010; 
Total minority: 38%; 
Black or African-American: 20%; 
Hispanic: 8%; 
Asian: 8%; 
Other: 1%. 

Year: 2011; 
Total minority: 38%; 
Black or African-American: 19%; 
Hispanic: 9%; 
Asian: 8%; 
Other: 1%. 

Cleveland: 

Year: 2007; 
Total minority: 23%; 
Black or African-American: 20%; 
Hispanic: 1%; 
Asian: 2%; 
Other: 0%. 

Year: 2008; 
Total minority: 23%; 
Black or African-American: 19%; 
Hispanic: 1%; 
Asian: 2%; 
Other: 1%. 

Year: 2009; 
Total minority: 21%; 
Black or African-American: 17%; 
Hispanic: 1%; 
Asian: 2%; 
Other: 1%. 

Year: 2010; 
Total minority: 20%; 
Black or African-American: 16%; 
Hispanic: 1%; 
Asian: 2%; 
Other: 1%. 

Year: 2011; 
Total minority: 20%; 
Black or African-American: 15%; 
Hispanic: 1%; 
Asian: 3%; 
Other: 1%. 

Dallas: 

Year: 2007; 
Total minority: 54%; 
Black or African-American: 28%; 
Hispanic: 21%; 
Asian: 4%; 
Other: 0%. 

Year: 2008; 
Total minority: 53%; 
Black or African-American: 27%; 
Hispanic: 22%; 
Asian: 4%; 
Other: 1%. 

Year: 2009; 
Total minority: 52%; 
Black or African-American: 23%; 
Hispanic: 22%; 
Asian: 6%; 
Other: 1%. 

Year: 2010; 
Total minority: 50%; 
Black or African-American: 21%; 
Hispanic: 22%; 
Asian: 7%; 
Other: 1%. 

Year: 2011; 
Total minority: 50%; 
Black or African-American: 22%; 
Hispanic: 21%; 
Asian: 6%; 
Other: 1%. 

Kansas City: 

Year: 2007; 
Total minority: 19%; 
Black or African-American: 11%; 
Hispanic: 5%; 
Asian: 3%; 
Other: 0%. 

Year: 2008; 
Total minority: 18%; 
Black or African-American: 9%; 
Hispanic: 5%; 
Asian: 3%; 
Other: 0%. 

Year: 2009; 
Total minority: 17%; 
Black or African-American: 9%; 
Hispanic: 4%; 
Asian: 3%; 
Other: 0%. 

Year: 2010; 
Total minority: 16%; 
Black or African-American: 8%; 
Hispanic: 5%; 
Asian: 3%; 
Other: 0%. 

Year: 2011%; 
Total minority: 16%; 
Black or African-American: 8%; 
Hispanic: 5%; 
Asian: 3%; 
Other: 1%. 

Minneapolis: 

Year: 2007; 
Total minority: 16%; 
Black or African-American: 9%; 
Hispanic: 2%; 
Asian: 5%; 
Other: 0%. 

Year: 2008; 
Total minority: 16%; 
Black or African-American: 9%; 
Hispanic: 2%; 
Asian: 6%; 
Other: 0%. 

Year: 2009; 
Total minority: 16%; 
Black or African-American: 8%; 
Hispanic: 2%; 
Asian: 6%; 
Other: 1%. 

Year: 2010; 
Total minority: 17%; 
Black or African-American: 8%; 
Hispanic: 2%; 
Asian: 7%; 
Other: 1%. 

Year: 2011; 
Total minority: 18%; 
Black or African-American: 8%; 
Hispanic: 2%; 
Asian: 7%; 
Other: 1%. 

New York: 

Year: 2007; 
Total minority: 43%; 
Black or African-American: 20%; 
Hispanic: 10%; 
Asian: 14%; 
Other: 0%. 

Year: 2008; 
Total minority: 45%; 
Black or African-American: 19%; 
Hispanic: 10%; 
Asian: 16%; 
Other: 0%. 

Year: 2009; 
Total minority: 46%; 
Black or African-American: 18%; 
Hispanic: 10%; 
Asian: 17%; 
Other: 1%. 

Year: 2010; 
Total minority: 46%; 
Black or African-American: 17%; 
Hispanic: 10%; 
Asian: 18%; 
Other: 1%. 

Year: 2011; 
Total minority: 45%; 
Black or African-American: 17%; 
Hispanic: 10%; 
Asian: 18%; 
Other: 1%. 

Philadelphia: 

Year: 2007; 
Total minority: 44%; 
Black or African-American: 34%; 
Hispanic: 3%; 
Asian: 7%; 
Other: 0%. 

Year: 2008; 
Total minority: 43%; 
Black or African-American: 32%; 
Hispanic: 3%; 
Asian: 7%; 
Other: 0%. 

Year: 2009; 
Total minority: 39%; 
Black or African-American: 27%; 
Hispanic: 3%; 
Asian: 8%; 
Other: 0%. 

Year: 2010%; 
Total minority: 36%; 
Black or African-American: 24%; 
Hispanic: 3%; 
Asian: 9%; 
Other: 1%. 

Year: 2011; 
Total minority: 36%; 
Black or African-American: 22%; 
Hispanic: 4%; 
Asian: 10%; 
Other: 1%. 

Richmond: 

Year: 2007; 
Total minority: 33%; 
Black or African-American: 26%; 
Hispanic: 2%; 
Asian: 4%; 
Other: 1%. 

Year: 2008; 
Total minority: 31%; 
Black or African-American: 24%; 
Hispanic: 2%; 
Asian: 4%; 
Other: 1%. 

Year: 2009; 
Total minority: 29%; 
Black or African-American: 22%; 
Hispanic: 2%; 
Asian: 4%; 
Other: 1%. 

Year: 2010; 
Total minority: 29%; 
Black or African-American: 21%; 
Hispanic: 2%; 
Asian: 4%; 
Other: 1%. 

Year: 2011; 
Total minority: 30%; 
Black or African-American: 21%; 
Hispanic: 3%; 
Asian: 5%; 
Other: 1%. 

San Francisco: 

Year: 2007; 
Total minority: 56%; 
Black or African-American: 10%; 
Hispanic: 14%; 
Asian: 31%; 
Other: 2%. 

Year: 2008; 
Total minority: 55%; 
Black or African-American: 9%; 
Hispanic: 13%; 
Asian: 30%; 
Other: 2%. 

Year: 2009; 
Total minority: 54%; 
Black or African-American: 9%; 
Hispanic: 13%; 
Asian: 31%; 
Other: 2%. 

Year: 2010; 
Total minority: 54%; 
Black or African-American: 8%; 
Hispanic: 12%; 
Asian: 33%; 
Other: 2%. 

Year: 2011; 
Total minority: 53%; 
Black or African-American: 7%; 
Hispanic: 12%; 
Asian: 33%; 
Other: 2%. 

St. Louis: 

Year: 2007; 
Total minority: 32%; 
Black or African-American: 29%; 
Hispanic: 1%; 
Asian: 2%; 
Other: 0%. 

Year: 2008; 
Total minority: 30%; 
Black or African-American: 26%; 
Hispanic: 2%; 
Asian: 2%; 
Other: 0%. 

Year: 2009; 
Total minority: 28%; 
Black or African-American: 23%; 
Hispanic: 2%; 
Asian: 3%; 
Other: 0%. 

Year: 2010; 
Total minority: 28%; 
Black or African-American: 23%; 
Hispanic: 2%; 
Asian: 3%; 
Other: 0%. 

Year: 2011; 
Total minority: 28%; 
Black or African-American: 22%; 
Hispanic: 2%; 
Asian: 3%; 
Other: 0%. 

Source: GAO analysis of Federal Reserve Bank reports. 

Note: Figures are rounded to the nearest percent. 

[End of figure] 

In addition, we found that from 2007 through 2011, the representation 
of women in the overall workforce of the Reserve Banks also declined 
slightly according to EEO-1 data provided by the Reserve Banks. The 
Reserve Banks showed decreases in the representation of women in the 
overall workforce from 1 percentage point at the Reserve Bank of New 
York to 7 percentage points at the Reserve Bank of Cleveland. The 
representation of women in the overall workforce in 2011 ranged from 
40 percent at the Reserve Banks of Philadelphia and Richmond to 53 
percent at the Reserve Bank of Minneapolis. 

Figure 21: Percentage of Women among All Employees at the 12 Reserve 
Banks, 2007-2011: 

[Refer to PDF for image: 13 stacked vertical bar graphs] 

All reserve banks: 

Year: 2007; 
Women: 42%; 
Men: 58%. 

Year: 2008; 
Women: 42%; 
Men: 58%. 

Year: 2009; 
Women: 41%; 
Men: 59%. 

Year: 2010; 
Women: 40%; 
Men: 60%. 

Year: 2011; 
Women: 40%; 
Men: 60%. 

Atlanta: 

Year: 2007; 
Women: 42%; 
Men: 58%. 

Year: 2008; 
Women: 40%; 
Men: 60%. 

Year: 2009; 
Women: 41%; 
Men: 59%. 

Year: 2010; 
Women: 40%; 
Men: 60%. 

Year: 2011; 
Women: 44%; 
Men: 56%. 

Boston: 

Year: 2007; 
Women: 39%; 
Men: 61%. 

Year: 2008; 
Women: 40%; 
Men: 60%. 

Year: 2009; 
Women: 39%; 
Men: 61%. 

Year: 2010; 
Women: 41%; 
Men: 59%. 

Year: 2011; 
Women: 40%; 
Men: 60%. 

Chicago: 

Year: 2007; 
Women: 46%; 
Men: 54%. 

Year: 2008; 
Women: 44%; 
Men: 56%. 

Year: 2009; 
Women: 43%; 
Men: 57%. 

Year: 2010; 
Women: 39%; 
Men: 61%. 

Year: 2011; 
Women: 40%; 
Men: 60%. 

Cleveland: 

Year: 2007; 
Women: 42%; 
Men: 58%. 

Year: 2008; 
Women: 42%; 
Men: 58%. 

Year: 2009; 
Women: 40%; 
Men: 60%. 

Year: 2010; 
Women: 36%; 
Men: 64%. 

Year: 2011; 
Women: 37%; 
Men: 63%. 

Dallas: 

Year: 2007; 
Women: 37%; 
Men: 63%. 

Year: 2008; 
Women: 39%; 
Men: 61%. 

Year: 2009; 
Women: 34%; 
Men: 66%. 

Year: 2010; 
Women: 34%; 
Men: 66%. 

Year: 2011; 
Women: 34%; 
Men: 66%. 

Kansas City: 

Year: 2007; 
Women: 48%; 
Men: 52%. 

Year: 2008; 
Women: 47%; 
Men: 53%. 

Year: 2009; 
Women: 48%; 
Men: 52%. 

Year: 2010; 
Women: 45%; 
Men: 55%. 

Year: 2011; 
Women: 48%; 
Men: 52%. 

Minneapolis: 

Year: 2007; 
Women: 54%; 
Men: 46%. 

Year: 2008; 
Women: 50%; 
Men: 50%. 

Year: 2009; 
Women: 51%; 
Men: 49%. 

Year: 2010; 
Women: 49%; 
Men: 51%. 

Year: 2011; 
Women: 49%; 
Men: 51%. 

New York: 

Year: 2007; 
Women: 38%; 
Men: 62%. 

Year: 2008; 
Women: 38%; 
Men: 62%. 

Year: 2009; 
Women: 38%; 
Men: 62%. 

Year: 2010; 
Women: 38%; 
Men: 62%. 

Year: 2011; 
Women: 40%; 
Men: 60%. 

Philadelphia: 

Year: 2007; 
Women: 40%; 
Men: 60%. 

Year: 2008; 
Women: 41%; 
Men: 59%. 

Year: 2009; 
Women: 40%; 
Men: 60%. 

Year: 2010; 
Women: 38%; 
Men: 62%. 

Year: 2011; 
Women: 37%; 
Men: 63%. 

Richmond: 

Year: 2007; 
Women: 43%; 
Men: 57%. 

Year: 2008; 
Women: 42%; 
Men: 58%. 

Year: 2009; 
Women: 41%; 
Men: 59%. 

Year: 2010; 
Women: 40%; 
Men: 60%. 

Year: 2011; 
Women: 37%; 
Men: 63%. 

San Francisco: 

Year: 2007; 
Women: 41%; 
Men: 59%. 

Year: 2008; 
Women: 41%; 
Men: 59%. 

Year: 2009; 
Women: 40%; 
Men: 60%. 

Year: 2010; 
Women: 40%; 
Men: 60%. 

Year: 2011; 
Women: 40%; 
Men: 60%. 

St. Louis: 

Year: 2007; 
Women: 39%; 
Men: 61%. 

Year: 2008; 
Women: 40%; 
Men: 60%. 

Year: 2009; 
Women: 41%; 
Men: 59%. 

Year: 2010; 
Women: 42%; 
Men: 58%. 

Year: 2011; 
Women: 41%; 
Men: 59%. 

Source: GAO analysis of Federal Reserve Bank reports. 

Note: Figures are rounded to the nearest percent. 

[End of figure] 

[End of section] 

Appendix IV: Representation of Minorities and Women at Federal 
Financial Agencies and Reserve Banks: 

We reviewed agency and Reserve Bank reports and found that since the 
financial crisis, senior management-level minority and gender 
diversity at the agencies and Reserve Banks has varied across 
individual entities. We also found the representation of minorities 
and women in the overall workforce of the agencies changed little from 
2007 through 2011, while the representation of minorities and women in 
the overall workforce of the Reserve Banks declined slightly. The 
following tables provide data supporting the senior management-level 
and total workforce figures in this report. 

Table 7: Percentage of Minorities among Senior Management-Level 
Employees at Seven Federal Financial Agencies, 2007-2011: 

Senior management-level federal financial agency employees (number and 
percent): 

Race/ethnicity: All; 

Year: 2011; 
FDIC: 301; 100%; 
Federal Reserve: 343; 100%; 
FHFA[A]: 51; 100%; 
NCUA: 134; 100%; 
OCC: 251; 100%; 
SEC[B]: 125; 100%; 
Treasury: 312; 100%. 

Year: 2010; 
FDIC: 284; 100%; 
Federal Reserve: 307; 100%; 
FHFA[A]: 29; 100%; 
NCUA: 109; 100%; 
OCC: 204; 100%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 279; 100%. 

Year: 2009; 
FDIC: 258; 100%; 
Federal Reserve: 301; 100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 101; 100%; 
OCC: 201; 100%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 276; 100%. 

Year: 2008; 
FDIC: 234; 100%; 
Federal Reserve: 289; 100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 123; 100%; 
OCC: 252; 100%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 219; 100%. 

Year: 2007; 
FDIC: 203; 100%; 
Federal Reserve: 253; 100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 118; 100%; 
OCC: 229; 100%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 175; 100%. 

Race/ethnicity: White; 

Year: 2011; 
FDIC: 250; 83%; 
Federal Reserve: 277; 81%; 
FHFA[A]: 39; 76%; 
NCUA: 118; 88%; 
OCC: 207; 82%; 
SEC[B]: 111; 89%; 
Treasury: 259; 83%. 

Year: 2010; 
FDIC: 237; 83%; 
Federal Reserve: 246; 80%; 
FHFA[A]: 21; 72%; 
NCUA: 95; 87%; 
OCC: 164; 80%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 238; 85%. 

Year: 2009; 
FDIC: 218; 84%; 
Federal Reserve: 247; 82%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 90; 89%; 
OCC: 164; 82%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 236; 86%. 

Year: 2008; 
FDIC: 199; 85%; 
Federal Reserve: 237; 82%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 108; 88%; 
OCC: 207; 82%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 188; 86%. 

Year: 2007; 
FDIC: 171; 84%; 
Federal Reserve: 207; 82%; 
NCUA: 104; 88%; 
OCC: 190; 83%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 150; 86%. 

Race/ethnicity: Total minority; 

Year: 2011; 
FDIC: 51; 17% 
Federal Reserve: 66; 19%; 
FHFA[A]: 12; 24%; 
NCUA: 16; 12%; 
OCC: 44; 18%; 
SEC[B]: 14; 11%; 
Treasury: 53; 17%. 

Year: 2010; 
FDIC: 47; 17%; 
Federal Reserve: 61; 20%; 
FHFA[A]: 8; 28%; 
NCUA: 14; 13%; 
OCC: 40; 20%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 41; 15%. 

Year: 2009; 
FDIC: 40; 16%; 
Federal Reserve: 54; 18%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 11; 11%; 
OCC: 37; 18%; 
SEC[B]:[Empty]; [Empty]; 
Treasury: 40; 14%. 

Year: 2008; 
FDIC: 35; 15%; 
Federal Reserve: 52; 18%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 15; 12%; 
OCC: 45; 18%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 31; 14%. 

Year: 2007; 
FDIC: 32; 16%; 
Federal Reserve: 46; 18%; 
NCUA: 14; 12%; 
OCC: 39; 17%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 25; 14%. 

Race/ethnicity: Black or African American; 

Year: 2011; 
FDIC: 31; 10%; 
Federal Reserve: 35; 10%; 
FHFA[A]: 8; 16%; 
NCUA: 5; 4%; 
OCC: 23; 9%; 
SEC[B]: 3; 2%; 
Treasury: 29; 9%. 

Year: 2010; 
FDIC: 27; 10%; 
Federal Reserve: 33; 11%; 
FHFA[A]: 7; 24%; 
NCUA: 5; 5%; 
OCC: 23; 11%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 21; 8%. 

Year: 2009; 
FDIC: 24; 9%; 
Federal Reserve: 31; 10%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 4; 4%; 
OCC: 23; 11%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 22; 8%. 

Year: 2008; 
FDIC: 24; 10%; 
Federal Reserve: 29; 10%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 7; 6%; 
OCC: 29; 12%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 19; 9%. 

Year: 2007; 
FDIC: 23; 11%; 
Federal Reserve: 27; 11%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 7; 6%; 
OCC: 29; 13%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 17; 10%. 

Race/ethnicity: Hispanic; 

Year: 2011; 
FDIC: 9; 3%; 
Federal Reserve: 7; 2%; 
FHFA[A]: 4; 8%; 
NCUA: 6; 4%; 
OCC: 12; 5%; 
SEC[B]: 6; 5%; 
Treasury: 12; 4%. 

Year: 2010; 
FDIC: 9; 3%; 
Federal Reserve: 7; 2%; 
FHFA[A]: 1; 3%; 
NCUA: 5; 5%; 
OCC: 10; 5%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 11; 4%. 

Year: 2009; 
FDIC: 7; 3%; 
Federal Reserve: 5; 2%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 5; 5%; 
OCC: 6; 3%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 12; 4%. 

Year: 2008; 
FDIC: 5; 2%; 
Federal Reserve: 4; 1%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 5; 4%; 
OCC: 9; 4%; 
SEC[B]:[Empty]; [Empty]; 
Treasury: 8; 4%. 

Year: 2007; 
FDIC: 4; 2%; 
Federal Reserve: 3; 1%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 4; 3%; 
OCC: 6; 3%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 5; 3%. 

Race/ethnicity: Asian; 

Year: 2011; 
FDIC: 9; 3%; 
Federal Reserve: 20; 6%; 
FHFA[A]: 0; 0; 
NCUA: 3; 2%; 
OCC: 9; 4%; 
SEC[B]: 3; 2%; 
Treasury: 10; 3%. 

Year: 2010; 
FDIC: 9; 3%; 
Federal Reserve: 17; 6%; 
FHFA[A]:[Empty]; [Empty]; 
NCUA: 2; 2%; 
OCC: 6; 3%; 
SEC[B]:[Empty]; [Empty]; 
Treasury: 8; 3%. 

Year: 2009; 
FDIC: 7; 3%; 
Federal Reserve: 13; 4%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 1; 1%; 
OCC: 7; 3%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 6; 2%. 

Year: 2008; 
FDIC: 5; 2%; 
Federal Reserve: 14; 5%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 2; 2%; 
OCC: 5; 2%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 4; 2%. 

Year: 2007; 
FDIC: 1; 0%; 
Federal Reserve: 11; 4%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 2; 2%; 
OCC: 2; 1%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 3; 2%. 

Race/ethnicity: Other; 

Year: 2011; 
FDIC: 2; 1%; 
Federal Reserve: 4; 1%; 
FHFA[A]: 0; 0%; 
NCUA: 2; 1%; 
OCC: 0; 0%; 
SEC[B]: 2; 2%; 
Treasury: 2; 1%. 

Year: 2010; 
FDIC: 2; 1%; 
Federal Reserve: 4; 1%; 
FHFA[A]: 0; 0%; 
NCUA: 2; 2%; 
OCC: 1; 0%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 1; 0%. 

Year: 2009; 
FDIC: 2; 1%; 
Federal Reserve: 5; 2%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 1; 1%; 
OCC: 1; 0%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 0; 0%. 

Year: 2008; 
FDIC: 1; 0%; 
Federal Reserve: 5; 2%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 1; 1%; 
OCC: 2; 1%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 0; 0%. 

Year: 2007; 
FDIC: 4; 2%; 
Federal Reserve: 5; 2%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 1; 1%; 
OCC: 2; 1%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 0; 0%. 

Source: GAO analysis of agency reports. 

Notes: Percentages are rounded to the nearest percent. 

For our analysis, we reviewed the numbers of employees the agencies 
reported according to race/ethnicity and gender in table A3 of their 
MD-715 reports from 2007 through 2011. These data are based on 
information self-reported by employees to each agency and there were 
some differences in reporting across the agencies. In some years, some 
agencies reported all employees--permanent and temporary--in their A3 
tables while others reported permanent employees only. We considered 
employees reported by agencies in the category "Executive/Senior 
Level" as senior management-level employees. Though the MD-715 report 
guidelines instruct agencies to identify employees Grades 15 and above 
who have supervisory responsibility in this category, agencies have 
discretion to include employees who have significant policymaking 
responsibilities but do not supervise employees. As a result, the 
composition of the "Executive/Senior Level" category may vary among 
the different agencies and does not necessarily involve the same set 
of managers at each agency. 

[A] FHFA was established in 2008 and started reporting workforce data 
for 2010. 

[B] SEC revised how it reported officials and managers between 2007 
and 2011. While our analysis includes 2011 management-level data for 
SEC, we excluded previous years from our trend analysis. 

[End of table] 

Table 8: Percentage of Minorities among Senior Management-Level 
Employees at the 12 Reserve Banks, 2007-2011: 

Senior management-level Reserve Bank employees (number and percent): 

Race/ethnicity: All; 
Year: 2011; 
Atlanta: 13; 100%; 
Boston: 13; 100%; 
Chicago: 9; 100%; 
Cleveland: 13; 100%; 
Dallas: 9; 100%; 
Kansas City: 12; 100%; 
Minneapolis: 9; 100%; 
New York: 59; 100%; 
Philadelphia: 11; 100%; 
Richmond: 22; 100%; 
San Francisco: 13; 100%; 
St. Louis: 11; 00%. 

Year: 2010; 
Atlanta: 86; 100%; 
Boston: 11; 100%; 
Chicago: 9; 100%; 
Cleveland: 12; 100%; 
Dallas: 10; 100%; 
Kansas City: 14; 100%; 
Minneapolis: 8; 100%; 
New York: 74; 100%; 
Philadelphia: 10; 100%; 
Richmond: 23; 100%; 
San Francisco: 23; 100%; 
St. Louis: 9; 100%. 

Year: 2009; 100%; 
Boston: 12; 100%; 
Chicago: 11; 100%; 
Cleveland: 12; 100%; 
Dallas: 10; 100%; 
Kansas City: 12; 100%; 
Minneapolis: 8; 100%; 
New York: 71; 100%; 
Philadelphia: 13; 100%; 
Richmond: 20; 100%; 
San Francisco: 26; 100%; 
St. Louis: 37; 100%. 

Year: 2008; 
Atlanta: 80; 100%; 
Boston: 12; 00; 
Chicago: 11; 100%; 
Cleveland: 13; 100%; 
Dallas: 10; 100%; 
Kansas City: 11; 100%; 
Minneapolis: 9; 100%; 
New York: 65; 100%; 
Philadelphia: 12; 100%; 
Richmond: 19; 100%; 
San Francisco: 26; 100%; 
St. Louis: 34; 100%. 

Year: 2007; 
Atlanta: 75; 100%; 
Boston: 12; 100%; 
Chicago: 11; 100%; 
Cleveland: 12; 100%; 
Dallas: 10; 100%; 
Kansas City: 12; 100%; 
Minneapolis: 7; 100%; 
New York: 55; 100%; 
Philadelphia: 11; 100%; 
Richmond: White: 19; 100%; 
San Francisco: 26; 100%; 
St. Louis: 30; 100%. 

Race/ethnicity: White; 

Year: 2011; 
Atlanta: 10; 77%; 
Boston: 11; 85%; 
Chicago: 8; 89%; 
Cleveland: 13; 100%; 
Dallas: 8; 89%; 
Kansas City: 11; 92%; 
Minneapolis: 5; 56%; 
New York: 52; 88%; 
Philadelphia: 10; 91%; 
Richmond: 19; 86%; 
San Francisco: 10; 77%; 
St. Louis: 10; 91%. 

Year: 2010; 
Atlanta: 72; 84%; 
Boston: 11; 100%; 
Chicago: 8; 89%; 
Cleveland: 12; 100%; 
Dallas: 9; 90%; 
Kansas City: 13; 93%; 
Minneapolis: 5; 63%; 
New York: 66; 89%; 
Philadelphia: 9; 90%; 
Richmond: 20; 87%; 
San Francisco: 20; 87;% 
St. Louis: 9; 100%. 

Year: 2009; 
Atlanta: 68; 83%; 
Boston: 12; 100%; 
Chicago: 10; 9%1; 
Cleveland: 12; 100%; 
Dallas: 9; 90%; 
Kansas City: 12; 100%; 
Minneapolis: 7; 88%; 
New York: 62; 87%; 
Philadelphia: 11; 85%; 
Richmond: 19; 95%; 
San Francisco: 23; 88%; 
St. Louis: 33; 89%. 

Year: 2008; 
Atlanta: 66; 83%; 
Boston: 12; 100%; 
Chicago: 10; 91%; 
Cleveland: 13; 100%; 
Dallas: 9; 90%; 
Kansas City: 11; 100%; 
Minneapolis: 8; 89%; 
New York: 55; 85%; 
Philadelphia: 10; 83%; 
Richmond: 17; 89%; 
San Francisco: 23; 88%; 
St. Louis: 31; 91%. 

Year: 2007; 
Atlanta: 62; 83%; 
Boston: 12; 100%; 
Chicago: 10; 91%; 
Cleveland: 12; 100%; 
Dallas: 9; 90%; 
Kansas City: 12; 100%; 
Minneapolis: 6; 86%; 
New York: 46; 84%; 
Philadelphia: 10; 91%; 
Richmond: 18; 95%; 
San Francisco: 24; 92%; 
St. Louis: 29; 97%. 

Total minority; 

Year: 2011; 
Atlanta: 3; 23%; 
Boston: 2; 15%; 
Chicago: 1; 11%; 
Cleveland: 0; 0%; 
Dallas: 1; 11%; 
Kansas City: 1; 8%; 
Minneapolis: 4; 44%; 
New York: 7; 12%; 
Philadelphia: 1; 9%; 
Richmond: 3; 14%; 
San Francisco: 3; 23%; 
St. Louis: 1; 9%. 

Year: 2010; 
Atlanta: 14; 16%; 
Boston: 0; 0%; 
Chicago: 1; 11%; 
Cleveland: 0; 0%; 
Dallas: 1; 10%; 
Kansas City: 1; 7%; 
Minneapolis: 3; 38%; 
New York: 8; 11%; 
Philadelphia: 1; 10%; 
Richmond: 3; 13%; 
San Francisco: 3; 13%; 
St. Louis: 0; 0%. 

Year: 2009; 
Atlanta: 14; 17%; 
Boston: 0; 0%; 
Chicago: 1; 9%; 
Cleveland: 0; 0%; 
Dallas: 1; 10%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 13%; 
New York: 9; 13%; 
Philadelphia: 2; 15%; 
Richmond: 1; 5%; 
San Francisco: 3; 12%; 
St. Louis: 4; 11%. 

Year: 2008; 
Atlanta: 14; 18%; 
Boston: 0; 0%; 
Chicago: 1; 9%; 
Cleveland: 0; 0%; 
Dallas: 1; 10%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 11%; 
New York: 10; 15%; 
Philadelphia: 2; 17%; 
Richmond: 2; 11%; 
San Francisco: 3; 12%; 
St. Louis: 3; 9%. 

Year: 2007; 
Atlanta: 13; 17%; 
Boston: 0; 0%; 
Chicago: 1; 9%; 
Cleveland: 0; 0%; 
Dallas: 1; 10%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 14%; 
New York: 9; 16%; 
Philadelphia: 1; 9%; 
Richmond: 1; 5%; 
San Francisco: 2; 8%; 
St. Louis: 1; 3%. 

Black or African American; 

Year: 2011; 
Atlanta: 2; 15%; 
Boston: 2; 15%; 
Chicago: 1; 11%; 
Cleveland: 0; 0%; 
Dallas: 1; 11%; 
Kansas City: 0; 0%; 
Minneapolis: 2; 22%; 
New York: 4; 7%; 
Philadelphia: 0; 0%; 
Richmond: 1; 5%; 
San Francisco: 1; 8%; 
St. Louis: 1; 9%. 

Year: 2010; 
Atlanta: 11; 13%; 
Boston: 0; 0%; 
Chicago: 1; 11%; 
Cleveland: 0; 0%; 
Dallas: 1; 10%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 13%; 
New York: 3; 4%; 
Philadelphia: 1; 10%; 
Richmond: 1; 4%; 
San Francisco: 2; 9%; 
St. Louis: 0; 0%. 

Year: 2009; 
Atlanta: 11; 13%; 
Boston: 0; 0%; 
Chicago: 1; 9%; 
Cleveland: 0; 0%; 
Dallas: 1; 10%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 13%; 
New York: 4; 6%; 
Philadelphia: 1; 8%; 
Richmond: 0; 0%; 
San Francisco: 2; 8%; 
St. Louis: 2; 5%. 

Year: 2008; 
Atlanta: 10; 13%; 
Boston: 0; 0%; 
Chicago: 1; 9%; 
Cleveland: 0; 0%; 
Dallas: 1; 10%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 11%; 
New York: 4; 6%; 
Philadelphia: 1; 8%; 
Richmond: 1; 5%; 
San Francisco: 2; 8%; 
St. Louis: 2; 6%. 

Year: 2007; 
Atlanta: 9; 12%; 
Boston: 0; 0%; 
Chicago: 1; 9%; 
Cleveland: 0; 0%; 
Dallas: 1; 10%; 
Kansas 0; 0%; 
Minneapolis: 1; 14%; 
New York: 4; 7%; 
Philadelphia: 1; 9%; 
Richmond: 1; 5%; 
San Francisco: 2; 8%; 
St. Louis: 1; 3%. 

Hispanic; 
Year: 2011; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 1; 8%; 
Minneapolis: 0; 0%; 
New York: 1; 2%; 
Philadelphia: 0; 0%; 
Richmond: 2; 9%; 
San Francisco: 1; 8%; 
St. Louis: 0; 0%. 

Year: 2010; 
Atlanta: 3; 3%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 1; 7%; 
Minneapolis: 0; 0%; 
New York: 2; 3%; 
Philadelphia: 0; 0%; 
Richmond: 2; 9%; 
San Francisco: 0; 0%; 
St. Louis: 0; 0%. 

Year: 2009; 
Atlanta: 3; 4%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 0; 0%; 
New York: 2; 3%; 
Philadelphia: 0; 0%; 
Richmond: 1; 5%; 
an Francisco: 0; 0%; 
St. Louis: 1; 3%. 

Year: 2008; 
Atlanta: 4; 5%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 0; 0%; 
New York: 3; 5%; 
Philadelphia: 0; 0%; 
Richmond: 1; 5%; 
San Francisco: 0; 0%; 
St. Louis: 1; 3%. 

Year: 2007; 
Atlanta: 4; 5%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0;% 
Minneapolis: 0; 0%; 
New York: 3; 5%; 
Philadelphia: 0; 0%; 
Richmond: 0; 0%; 
San Francisco: 0; 0%; 
St. Louis: 0; 0%. 

Asian; 

Year: 2011; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 11%; 
New York: 2; 3%; 
Philadelphia: 1; 9%; 
Richmond: 0; 0%; 
San Francisco: 1; 8%; 
St. Louis: 0; 0%. 

Year: 2010; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 13%; 
New York: 3; 4%; 
Philadelphia: 0; 0%; 
Richmond: 0; 0%; 
San Francisco: 1; 4%; 
St. Louis: 0; 0%. 

Year: 2009; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 0; 0%; 
New York: 3; 4%; 
Philadelphia: 1; 8%; 
Richmond: 0; 0%; 
San Francisco: 1; 4%; 
St. Louis: 1; 3%. 

Year: 2008; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 0; 0%; 
New York: 3; 5%; 
Philadelphia: 1; 8%; 
Richmond: 0; 0%; 
San Francisco: 1; 4%; 
St. Louis: 0; 0%. 

Year: 2007; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 0; 0%; 
New York: 2; 4%; 
Philadelphia: 0; 0%; 
Richmond: 0; 0%; 
San Francisco: 0; 0%; 
St. Louis: 0 ;0%. 

Other; 

Year: 2011; 
Atlanta: 1; 8%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 11%; 
New York: 0; 0%; 
Philadelphia: 0; 0%; 
Richmond: 0; 0%; 
San Francisco: 0; 0%; 
St. Louis: 0; 0%. 

Year: 2010; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 1; 13%; 
New York: 0; 0%; 
Philadelphia: 0; 0%; 
Richmond: 0; 0%; 
San Francisco: 0; 0%; 
St. Louis: 0; 0%. 

Year: 2009; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 0; 0%; 
New York: 0; 0%; 
Philadelphia: 0; 0%; 
Richmond: 0; 0%; 
San Francisco: 0; 0%; 
St. Louis: 0; 0%. 

Year: 2008; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 0; 0%; 
New York: 0; 0%; 
Philadelphia: 0; 0%; 
Richmond: 0; 0%; 
San Francisco: 0; 0%; 
St. Louis: 0; 0%. 

Year: 2007; 
Atlanta: 0; 0%; 
Boston: 0; 0%; 
Chicago: 0; 0%; 
Cleveland: 0; 0%; 
Dallas: 0; 0%; 
Kansas City: 0; 0%; 
Minneapolis: 0; 0%; 
New York: 0; 0%; 
Philadelphia: 0; 0%; 
Richmond: 0; 0%; 
San Francisco: 0; 0%; 
St. Louis: 0; 0%. 

Source: GAO analysis of EEO-1 reports provided by Reserve Banks. 

Notes: Percentages are rounded to the nearest percent. 

For our analysis of the representation of minorities and women at the 
senior management level for Reserve Banks, we reviewed the numbers of 
employees the banks reported as "Executive/Senior Level Officials and 
Managers" from 2007 through 2011. While EEOC provides instructions on 
reporting job categories based on the skill levels, knowledge, and 
responsibilities involved in occupations identified within each job 
category, employers have discretion to decide which positions they 
report as Executive/Senior Level Officials and Managers versus those 
at lower levels of management. Therefore, comparisons of a given 
management level between the Reserve Banks do not necessarily involve 
the same set of managers at each bank. For example, the Reserve Bank 
of Atlanta revised how it reported officials and managers for 2011. 
From 2007 through 2010, the bank reported all officers as 
Executive/Senior Level Officials and Managers, and for 2011, the bank 
reported as Executive/Senior Level Officials and Managers those 
employees that have strategic roles and/or report to the Reserve 
Bank's President. According to Reserve Bank officials, recent efforts 
have been made to align reporting of officials and managers across the 
Federal Reserve System. 

Table 9: Percentage of Women among Senior Management-Level Employees 
at Seven Federal Financial Agencies, 2007-2011: 

Senior management-level federal financial agency employees (number and 
percent): 

Gender: All; 

Year: 2011; 
FDIC: 301; 100%; 
Federal Reserve: 343; 100%; 
FHFA[A]: 51; 100%; 
NCUA: 134; 100%; 
OCC: 251; 100%; 
SEC[B]: 125; 100%; 
Treasury: 312; 100%. 

Year: 2010; 
FDIC: 284; 100%; 
Federal Reserve: 307; 100%; 
FHFA[A]: 29; 100%; 
NCUA: 109; 100%; 
OCC: 204; 100%; 
SEC[B]: [Empty]; 
Treasury: 279; 100%. 

Year: 2009; 
FDIC: 257; 100%; 
Federal Reserve: 301; 100%; 
FHFA[A]: [Empty]; 
NCUA: 101; 100%; 
OCC: 201; 100%; 
SEC[B]: [Empty]; 
Treasury: 176; 100%. 

Year: 2008; 
FDIC: 234; 100%; 
Federal Reserve: 289; 100%; 
FHFA[A]: [Empty]; 
NCUA: 123; 100%; 
OCC: 252; 100%; 
SEC[B]: [Empty]; 
Treasury: 219; 100%. 

Year: 2007; 
FDIC: 203; 100%; 
Federal Reserve: 253; 100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: Men: 118; 100%; 
OCC: Men: 229; 100%; 
SEC[B]: [Empty]; 
Treasury: Men: 175; 100%. 

Gender: Men; 

Year: 2011; 
FDIC: 209; 69%; 
Federal Reserve: 201; 59%; 
FHFA[A]: 27; 53%; 
NCUA: 87; 65%; 
OCC: 171; 68%; 
SEC[B]: 85; 68%; 
Treasury: 192; 62%. 

Year: 2010; 
FDIC: 197; 69; 
Federal Reserve: 185; 60%; 
FHFA[A]: 14; 48%; 
NCUA: 77; 71%; 
OCC: 137; 67%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 178; 64%. 

Year: 2009; 
FDIC: 187; 72%; 
Federal Reserve: 184; 61%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 72; 71%; 
OCC: 130; 65%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 176; 64%. 

Year: 2008; 
FDIC: 165; 71%; 
Federal Reserve: 180; 62%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 84; 68%; 
OCC: 161; 64%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 143; 65%. 

Year: 2007; 
FDIC: 147; 72%; 
Federal Reserve: 155; 61%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 82; 69%; 
OCC: 145; 63%; 
SEC[B]:[Empty]; [Empty]; 
Treasury: 115; 66%. 

Gender: Women; 

Year: 2011; 
FDIC: 92; 31; 
Federal Reserve: 142; 41%; 
FHFA[A]: 24; 47%; 
NCUA: 47; 35%; 
OCC: 80; 32%; 
SEC[B]: 40; 32%; 
Treasury: 120; 38%. 

Year: 2010; 
FDIC: 87; 31; 
Federal Reserve: 122; 40%; 
FHFA[A]: 15; 52%; 
NCUA: 32; 29%; 
OCC: 67; 33%; 
SEC[B]:[Empty]; [Empty]; 
Treasury: 101; 36%. 

Year: 2009; 
FDIC: 71; 28; 
Federal Reserve: 117; 39%; 
FHFA[A]:[Empty]; [Empty]; 
NCUA: 29; 29%; 
OCC: 71; 35%; 
SEC[B]:[Empty]; [Empty]; 
Treasury: 100; 36%. 

Year: 2008; 29; 
Federal Reserve: 109; 38%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 39; 32%; 
OCC: 91; 36%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 76; 35%. 

Year: 2007; 
FDIC: 56; 28; 
Federal Reserve: 98; 39%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 36; 31%; 
OCC: 84; 37%; 
SEC[B]: [Empty]; [Empty]; 
Treasury: 60; 34%. 

Source: GAO analysis of agency reports. 

Notes: Percentages are rounded to the nearest percent. 

For our analysis, we reviewed the numbers of employees the agencies 
reported according to race/ethnicity and gender in table A3 of their 
MD-715 reports from 2007 through 2011. These data are based on 
information self-reported by employees to each agency and there were 
some differences in reporting across the agencies. In some years, some 
agencies reported all employees--permanent and temporary--in their A3 
tables while others reported permanent employees only. We considered 
employees reported by agencies in the category "Executive/Senior 
Level" as senior management-level employees. Though the MD-715 report 
guidelines instruct agencies to identify employees Grades 15 and above 
who have supervisory responsibility in this category, agencies have 
discretion to include employees who have significant policymaking 
responsibilities but do not supervise employees. As a result, the 
composition of the "Executive/Senior Level" category may vary among 
the different agencies and does not necessarily involve the same set 
of managers at each agency. 

[A] FHFA was established in 2008 and started reporting workforce data 
for 2010. 

[B] SEC revised how it reported officials and managers between 2007 
and 2011. While our analysis includes 2011 management-level data for 
SEC, we excluded previous years from our trend analysis. 

[End of table] 

Table 1o: Percentage of Women among Senior Management-Level Employees 
at the 12 Reserve Banks, 2007-2011: 

Senior management-level federal financial agency employees (number and 
percent): 

Race/ethnicity: All; 

Year: 2011; 
Atlanta: 13; 100%; 
Boston: 13; 100%; 
Chicago: 9; 100%; 
Cleveland: 13; 100%; 
Dallas: 9; 100%; 
Kansas City: 12; 100%; 
Minneapolis: 9; 100%; 
New York: 59; 100%; 
Philadelphia: 11; 100%; 
Richmond: 22; 100%; 
San Francisco: 13; 100%; 
St. Louis: 11; 100%. 

Year: 2010; 
Atlanta: 86; 100%; 
Boston: 11; 100%; 
Chicago: 9; 100%; 
Cleveland: 12; 100%; 
Dallas: 10; 100%; 
Kansas City: 14; 100%; 
Minneapolis: 8; 100%; 
New York: 74; 100%; 
Philadelphia: 10; 100%; 
Richmond: 23; 100%; 
San Francisco: 23; 100%; 
St. Louis: 9; 100%. 

Year: 2009; 

Atlanta: 82; 100%; 
Boston: 12; 100%; 
Chicago: 11; 100%; 
Cleveland: 12; 100%; 
Dallas: 10; 100%; 
Kansas City: 12; 100%; 
Minneapolis: 8; 100%; 
New York: 71; 100%; 
Philadelphia: 13; 100%; 
Richmond: 20; 100%; 
San Francisco: 26; 100%; 
St. Louis: 37; 100%. 

Year: 2008; 
Atlanta: 80; 100%; 
Boston: 12; 100%; 
Chicago: 11; 100%; 
Cleveland: 13; 100%; 
Dallas: 10; 100%; 
Kansas City: 11; 100%; 
Minneapolis: 9; 100%; 
New York: 65; 100%; 
Philadelphia: 12; 100%; 
Richmond: 19; 100%; 
San Francisco: 26; 100%; 
St. Louis: 34; 100%. 

Year: 2007; 
Atlanta: 75; 100%; 
Boston: 2; 100%; 
Chicago: 11; 100%; 
Cleveland: 12; 100%; 
Dallas: 10; 100%; 
Kansas City: 12; 100%; 
Minneapolis: 7; 100%; 
New York: 55; 100%; 
Philadelphia: 11; 100%; 
Richmond: 19; 100%; 
San Francisco: 26; 100%; 
St. Louis: 30; 100%. 

Race/ethnicity: Men; 

Year: 2011; 
Atlanta: 7; 54%; 
Boston: 11; 85%; 
Chicago: 5; 56%; 
Cleveland: 9; 69%; 
Dallas: 6; 67%; 
Kansas City: 5; 42%; 
Minneapolis: 6; 67%; 
New York: 34; 58%; 
Philadelphia: 6; 55%; 
Richmond: 15; 68%; 
San Francisco: 9; 69%; 
St. Louis: 7; 64%. 

Year: 2010; 
Atlanta: 53; 62%; 
Boston: 9; 82%; 
Chicago: 5; 56%; 
Cleveland: 9; 75%; 
Dallas: 7; 70%; 
Kansas City: 9; 64%; 
Minneapolis: 6; 75%; 
New York: 48; 65%; 
Philadelphia: 5; 50%; 
Richmond: 16; 70%; 
San Francisco: 16; 70%; 
St. Louis: 6; 67%. 

Year: 2009; 
Atlanta: 49; 60%; 
Boston: 9; 75%; 
Chicago: 6; 55%; 
Cleveland: 8; 67%; 
Dallas: 7; 70%; 
Kansas City: 8; 67%; 
Minneapolis: 6; 75%; 
New York: 46; 65%; 
Philadelphia: 9; 69%; 
Richmond: 13; 65%; 
San Francisco: 17; 65%; 
St. Louis: 26; 70%. 

Year: 2008; 
Atlanta: 49; 61%; 
Boston: 9; 75%; 
Chicago: 6; 55%; 
Cleveland: 9; 69%; 
Dallas: 7; 70%; 
Kansas City: 8; 73%; 
Minneapolis: 7; 78%; 
New York: 43; 66%; 
Philadelphia: 8; 67%; 
Richmond: 14; 74%; 
San Francisco: 17; 65%; 
St. Louis: 22; 65%. 

Year: 2007; 
Atlanta: 48; 64%; 
Boston: 9; 75%; 
Chicago: 6; 55%; 
Cleveland: 8; 67%; 
Dallas: 7; 70%; 
Kansas City: 8; 67%; 
Minneapolis: 6; 86%; 
New York: 39; 71%; 
Philadelphia: 7; 64%; 
Richmond: 15; 79%; 
San Francisco: 17; 65%; 
St. Louis: 20; 67%. 

Race/ethnicity: Women; 

Year: 2011; 
Atlanta: 6; 46%; 
Boston: 2; 15%; 
Chicago: 4; 44%; 
Cleveland: 4; 31%; 
Dallas: 3; 33%; 
Kansas City: 7; 58%; 
Minneapolis: 3; 33%; 
New York: 25; 42%; 
Philadelphia: 5; 45%; 
Richmond: 7; 32%; 
San Francisco: 4; 31%; 
St. Louis: 4; St. Louis: 36%. 

Year: 2010; 
Atlanta: 33; 38%; 
Boston: 2; 18%; 
Chicago: 4; 44%; 
Cleveland: 3; 25%; 
Dallas: 3; 30%; 
Kansas City: 5; 36%; 
Minneapolis: 2; 25%; 
New York: 26; 35%; 
Philadelphia: 5; 50%; 
Richmond: 7; 30%; 
San Francisco: 7; 30%; 
St. Louis: 3; 33%. 

Year: 2009; 
Atlanta: 33; 40%; 
Boston: 3; 25%; 
Chicago: 5; 45%; 
Cleveland: 4; 33%; 
Dallas: 3; 30%; 
Kansas City: 4; 33%; 
Minneapolis: 2; 25%; 
New York: 25; 35%; 
Philadelphia: 4; 31%; 
Richmond: 7; 35%; 
San Francisco: 9; 35%; 
St. Louis: 11; 30%. 

Year: 2008; 
Atlanta: 31; 39%; 
Boston: 3; 25%; 
Chicago: 5; 45%; 
Cleveland: 4; 31%; 
Dallas: 3; 30%; 
Kansas City: 3; 27%; 
Minneapolis: 2; 22%; 
New York: 22; 34%; 
Philadelphia: 4; 33%; 
Richmond: 5; 26%; 
San Francisco: 9; 35%; 
St. Louis: 12; 35%. 

Year: Year: 2007; 
Atlanta: 27; 36%; 
Boston: 3; 25%; 
Chicago: 5; 45%; 
Cleveland: 4; 33%; 
Dallas: 3; 30%; 
Kansas City: 4; 33%; 
Minneapolis: 1; 14%; 
New York:16; 29%; 
Philadelphia: 4; 36%; 
Richmond: 4; 21%; 
San Francisco: 9; 35%; 
St. Louis: 10; 33%. 

Source: GAO analysis of EEO-1 reports provided by Reserve Banks. 
Notes: Percentages are rounded to the nearest percent. 

For our analysis of the representation of minorities and women at the 
senior management level for Reserve Banks, we reviewed the numbers of 
employees the banks reported as "Executive/Senior Level Officials and 
Managers" from 2007 through 2011. While EEOC provides instructions on 
reporting job categories based on the skill levels, knowledge, and 
responsibilities involved in occupations identified within each job 
category, employers have discretion to decide which positions they 
report as Executive/Senior Level Officials and Managers versus those 
at lower levels of management. Therefore, comparisons of a given 
management level between the Reserve Banks do not necessarily involve 
the same set of managers at each bank. For example, the Reserve Bank 
of Atlanta revised how it reported officials and managers for 2011. 
From 2007 through 2010, the bank reported all officers as 
Executive/Senior Level Officials and Managers, and for 2011, the bank 
reported as Executive/Senior Level Officials and Managers those 
employees that have strategic roles and/or report to the Reserve 
Bank's President. According to Reserve Bank officials, recent efforts 
have been made to align reporting of officials and managers across the 
Federal Reserve System. 

[End of table] 

Table 11: Percentage of Minorities among All Employees at Seven 
Federal Financial Agencies, 2007-2011: 

Federal financial agency employees (number and percent): 

Race/ethnicity: All; 

Year: 2011; 
FDIC: 8,398; 100%; 
Federal Reserve: 2,274; 100%; 
FHFA[A]: 494; 100%; 
NCUA: 1,159; 100%; 
OCC: 3,560; 100%; 
SEC: 3,812; 100%; 
Treasury: 1,586; 100%. 

Year: 2010; 
FDIC: 8,316; 100%; 
Federal Reserve: 2,137; 100%; 
FHFA[A]: 406; 100%; 
NCUA: 1,095; 100%; 
OCC: 3,054; 100%; 
SEC: 3,897; 100%; 
Treasury: 1,599; 100%. 

Year: 2009; 
FDIC: 6,530; 100%; 
Federal Reserve: 2,143; 100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 1,024; 100%; 
OCC: 3,117; 100%; 
SEC: 3,720; 100%; 
Treasury: 1,529; 100%. 

Year: 2008; 
FDIC: 5,028; 100%; 
Federal Reserve: 2,028; 100%; 
FHFA[A]:[Empty]; [Empty]; 
NCUA: 934; 100%; 
OCC: 3,039; 100%; 
SEC: 3,653; 100%; 
Treasury: 1,295; 100%. 

Year: 2007; 
FDIC: 4,428; 100%; 
Federal Reserve: 1,945; 100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 929; 100%; 
OCC: 3,000; 100%; 
SEC: 3,154; 100%; 
Treasury: 1,223; 100%. 

Race/ethnicity: White; 

Year: 2011; 
FDIC: 6,152; 73%; 
Federal Reserve: 1,276; 56%; 
FHFA[A]: 335; 38%; 
NCUA: 871; 75%; 
OCC: 2,503; 70%; 
SEC: 2,616; 69%; 
Treasury: 1,087; 69%. 

Year: 2010; 
FDIC: 6,107; 73%; 
Federal Reserve: 1,196; 56%; 
FHFA[A]: 270; 67%; 
NCUA: 833; 76%; 
OCC: 2,145; 70%; 
SEC: 2,664; 68%; 
Treasury: 1,080; 68%. 

Year: 2009; 
FDIC: 4,800; 74%; 
Federal Reserve: 1,187; 55%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 769; 75%; 
OCC: 2,185; 70%; 
SEC: 2,516; 68%; 
Treasury: 1,041; 68%. 

Year: 2008; 
FDIC: 3,655; 3%; 
Federal Reserve: 1,115; 55%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 722; 78%; 
OCC: 2,161; 72%; 
SEC: 2,204; 70%; 
Treasury: 772; 63%. 

Year: 2007; 
FDIC: 3,261; 74%; 
Federal Reserve: 1,066; 55%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 722; 78%; 
OCC: 2,161; 72%; 
SEC: 2,204; 7%; 
Treasury: 772; 63%. 

Race/ethnicity: Total minority; 

Year: 2011; 
FDIC: 2,246; 27%; 
Federal Reserve: 998; 44%; 
FHFA[A]: 159; 32%; 
NCUA: 288; 25%; 
OCC: 1,057; 30%; 
SEC: 1,196; 31%; 
Treasury: 499; 31%. 

Year: 2010; 
FDIC: 2,209; 27%; 
Federal Reserve: 941; 44%; 
FHFA[A]: 136; 33%; 
NCUA: 262; 24%; 
OCC: 909; 30%; 
SEC: 1,233; 32%; 
Treasury: 519; 32%. 

Year: 2009; 
FDIC: 1,730; 26%; 
Federal Reserve: 956; 45%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 255; 25%; 
OCC: 932; 30%; 
SEC: 1,204; 32%; 
Treasury: 488; 32%. 

Year: 2008; 
FDIC: 1,373; 27%; 
Federal Reserve: 913; 45%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 216; 23%; 
OCC: 887; 29%; 
SEC: 1,168; 32%; 
Treasury: 464; 36%. 

Year: 2007; 
FDIC: 1,167; 26%; 
Federal Reserve: 879; 45%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 207; 22%; 
OCC: 839; 28%; 
SEC: 950; 30%; 
Treasury: 451; 37%. 

Race/ethnicity: Black or African American; 

Year: 2011; 
FDIC: 1,385; 16%; 
Federal Reserve: 591; 26%; 
FHFA[A]: 95; 19%; 
NCUA: 157; 14%; 
OCC: 577; 16;% 
SEC: 632; 17%; 
Treasury: 356; 22%. 

Year: 2010; 
FDIC: 1,353; 16%; 
Federal Reserve: 582; 27%; 
FHFA[A]: 90; 22%; 
NCUA: 141; 13%; 
OCC: 508; 17%; 
SEC: 682; 18%; 
Treasury: 372; 23%. 

Year: 2009; 
FDIC: 1,109; 17; 
Federal Reserve: 612; 29%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 153; 15%; 
OCC: 534; 17%; 
SEC: 679; 18%; 
Treasury: 362; 24%. 

Year: 2008; 
FDIC: 944; 19%; 
Federal Reserve: 604; 30%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 133; 14%; 
OCC: 517; 17%; 
SEC: 668; 18%; 
Treasury: 352; 27%. 

Year: 2007; 
FDIC: 799; 18%; 
Federal Reserve: 589; 30%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 126; 14%; 
OCC: 501; 17%; 
SEC: 523; 1%7; 
Treasury: 344%; 
Treasury: 28%. 

Race/ethnicity: Hispanic; 

Year: 2011; 
FDIC: 359; 4%; 
Federal Reserve: 94; 4%; 
FHFA[A]: 17; 3%; 
NCUA: 48; 4%; 
OCC: 201; 6%; 
SEC: 182; 5%; 
Treasury: 46; 3%. 

Year: 2010; 
FDIC: 364; 4; 
Federal Reserve: 81; 4%; 
FHFA[A]: 12; 3%; 
NCUA: 47; 4%; 
OCC: 181; 6%; 
SEC: 133; 3%; 
Treasury: 49; 3%. 

Year: 2009; 
FDIC: 261; 4%; 
Federal Reserve: 75; 3%; 
FHFA[A]:[Empty]; [Empty]; 
NCUA: 43; 4%; 
OCC: 181; 6%; 
SEC: 144; 4%; 
Treasury: 54; 4%. 

Year: 2008; 
FDIC: 198; 4%; 
Federal Reserve: 70; 3%; 
FHFA[A]:[Empty]; [Empty]; 
NCUA: 35; 4%; 
OCC: 168; 6%; 
SEC: 137; 4%; 
Treasury: 47; 4%. 

Year: 2007; 
FDIC: 181; 4%; 
Federal Reserve: 68; 3%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 34; 4%; 
OCC: 157; 5%; 
SEC: 129; 4%; 
Treasury: 50; 4%. 

Race/ethnicity: Asian; 

Year: 2011; 
FDIC: 374; 4%; 
Federal Reserve: 271; 12%; 
FHFA[A]: 46; 9%; 
NCUA: 56; 5%; 
OCC: 212; 6%; 
SEC: 354; 9%; 
Treasury: 80; 5%. 

Year: 2010; 
FDIC: 372; 4%; 
Federal Reserve: 238; 11%; 
FHFA[A]: 33; 8%; 
NCUA: 52; 5%; 
OCC: 169; 6%; 
SEC: 352; 9%; 
Treasury: 79; 5%. 

Year: 2009; 
FDIC: 283; 4%; 
Federal Reserve: 231; 11%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 37; 4%; 
OCC: 163; 5%; 
SEC: 319; 9%; 
Treasury: 60; 4%. 

Year: 2008; 
FDIC: 199; 4%; 
Federal Reserve: 204; 10%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 36; 4%; 
OCC: 158; 5%; 
SEC: 312; 9%; 
Treasury: 53; 4%. 

Year: 2007; 
FDIC: 25; 1%; 
Federal Reserve: 187; 10%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 33; 4%; 
OCC: 145; 5%; 
SEC: 266; 8%; 
Treasury: 49; 4%. 

Race/ethnicity: Other; 

Year: 2011; 
FDIC: 128; 2%; 
Federal Reserve: 42; 2%; 
FHFA[A]: 1; 0%; 
NCUA: 27; 2%; 
OCC: 67; 2%; 
SEC: 28; 1%; 
Treasury: 17; 1%. 

Year: 2010; 
FDIC: 120; 1%; 
Federal Reserve: 40; 2%; 
FHFA[A]: 1; 0; 
NCUA: 22; 2%; 
OCC: 51; 2%; 
SEC: 66; 2%; 
Treasury: 19; 1%. 

Year: 2009; 
FDIC: 77; 1%; 
Federal Reserve: 38; 2%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 22; 2%; 
OCC: 54; 2%; 
SEC: 62; 2%; 
Treasury: 12; 1%. 

Year: 2008; 
FDIC: 32; 1%; 
Federal Reserve: 35; 2%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 12; 1%; 
OCC: 44; 1%; 
SEC: 51; 1%; 
Treasury: 12; 1%. 

Year: 2007; 
FDIC: 162; 4%; 
Federal Reserve: 35; 2%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 14; 2%; 
OCC: 36; 1%; 
SEC: 32; 1%; 
Treasury: 8%; 
Treasury: 1%. 

Source: GAO analysis of agency reports. 

Notes: Percentages are rounded to the nearest percent. 

For our analysis, we reviewed the numbers of employees the agencies 
reported according to race/ethnicity and gender in table A3 of their 
MD-715 reports from 2007 through 2011. These data are based on 
information self-reported by employees to each agency and there were 
some differences in reporting across the agencies. In some years, some 
agencies reported all employees--permanent and temporary--in their A3 
tables while others reported permanent employees only. 

[A] FHFA was established in 2008 and started reporting workforce data 
for 2010. 

[End of table] 

Table 12: Percentage of Minorities among All Employees at the 12 
Reserve Banks, 2007-2011: 

Reserve Bank employees (number and percent): 

Race/ethnicity: All; 

Year: 2011; 
Atlanta: 1,594; 100%; 
Boston: 875; 100%; 
Chicago: 1,431; 100%; 
Cleveland: 1,094; 100%; 
Dallas: 1,098; 100%; 
Kansas City: 1,225; 100%; 
Minneapolis: 1,011; 100%; 
New York: 2,955; 100%; 
Philadelphia: 839; 100%; 
Richmond: 2,444; 100%; 
San Francisco: 1,495; 100%; 
St. Louis: 955; 100%. 

Year: 2010; 
Atlanta: 1,623; 100%; 
Boston: 858; 100%; 
Chicago: 1,353; 100%; 
Cleveland: 1,276; 100%; 
Dallas: 1,110; 100%; 
Kansas City: 1,292; 100%; 
Minneapolis: 1,004; 100%; 
New York: 2,999; 100%; 
Philadelphia: 840; 100%; 
Richmond: 2,356; 100%; 
San Francisco: 1,514; 100%; 
St. Louis: 944; 100%. 

Year: 2009; 
Atlanta: 1,728; 100%; 
Boston: 868; 100%; 
Chicago: 1,379; 100%; 
Cleveland: 1,340; 100%; 
Dallas: 1,168; 100%; 
Kansas City: 1,220; 100%; 
Minneapolis: 1,051; 100%; 
New York: 2,940; 100%; 
Philadelphia: 914; 100%; 
Richmond: 2,421; 100%; 
San Francisco: 1,632; 100%; 
St. Louis: 932; 100%. 

Year: 2008; 
Atlanta: 1,886; 100%; 
Boston: 884; 100%; 
Chicago: 1,415; 100%; 
Cleveland: 1,511; 100%; 
Dallas: 1,225; 100%; 
Kansas City: 1,277; 100%; 
Minneapolis: 1,172; 100%; 
New York: 2,791; 100%; 
Philadelphia: 1,016; 100%; 
Richmond: 2,534; 100%; 
San Francisco: 1,700; 100%; 
St. Louis: 987; 100%. 

Year: 2007; 
Atlanta: 2,017; 100%; 
Boston: 978; 100%; 
Chicago: 1,532; 100%; 
Cleveland: 1,568; 100%; 
Dallas: 1,269; 100%; 
Kansas City: 1,357; 100%; 
Minneapolis: 1,278; 100%; 
New York: 2,860; 100%; 
Philadelphia: 1,092; 100%; 
Richmond: 2,733; 100%; 
San Francisco: 1,779; 100%; 
St. Louis: 1,089; 100%. 

Race/ethnicity: White; 

Year: 2011; 
Atlanta: 839; 53%; 
Boston: 607; 69%; 
Chicago: 889; 62%; 
Cleveland: 878; 80%; 
Dallas: 551; 50%; 
Kansas City: 1,026; 84%; 
Minneapolis: 830; 82%; 
New York: 1,617; 55%; 
Philadelphia: 539; 64%; 
Richmond: 1,721; 70%; 
San Francisco: 701; 47%; 
St. Louis: 691; 72%. 

Year: 2010; 
Atlanta: 839; 52%; 
Boston: 607; 71%; 
Chicago: 845; 62%; 
Cleveland: 1,017; 80%; 
Dallas: 555; 50%; 
Kansas City: 1,082; 84%; 
Minneapolis: 830; 83%; 
New York: 1,626; 54%; 
Philadelphia: 534; 64%; 
Richmond: 1,672; 71%; 
San Francisco: 703; 46%; 
St. Louis: 679; 72%. 

Year: 2009; 
Atlanta: 864; 50%; 
Boston: 611; 70%; 
Chicago: 850; 62%; 
Cleveland: 1,063; 79%; 
Dallas: 561; 48%; 
Kansas City: 1,018; 83%; 
Minneapolis: 879; 84%; 
New York: 1,596; 54%; 
Philadelphia: 562; 61%; 
Richmond: 1,719; 71%; 
San Francisco: 758; 46%; 
St. Louis: 674; 72%. 

Year: 2008; 
Atlanta: 899; 48%; 
Boston: 614; 69%; 
Chicago: 866; 61%; 
Cleveland: 1,168; 77%; 
Dallas: 572; 47%; 
Kansas City: 1,050; 82%; 
Minneapolis: 980; 84%; 
New York: 1,522; 55%; 
Philadelphia: 581; 57%; 
Richmond: 1,753; 69%; 
San Francisco: 768; 45%; 
St. Louis: 694; 70%. 

Year: 2007; 
Atlanta: 949; 47%; 
Boston: 676; 6%9; 
Chicago: 933; 61%; 
Cleveland: 1,213; 77%; 
Dallas: 590; 46%; 
Kansas City: 1,096; 81%; 
Minneapolis: 1,071; 84%; 
New York: 1,630; 57%; 
Philadelphia: 613; 56%; 
Richmond: 1,823; 67%; 
San Francisco: 774; 44%; 
St. Louis: 740; 68%. 

Total minority; 

Year: 2011; 
Atlanta: 755; 47%; 
Boston: 268; 31%; 
Chicago: 542; 38%; 
Cleveland: 216; 20%; 
Dallas: 547; 50%; 
Kansas City: 199; 16%; 
Minneapolis: 181; 18%; 
New York: 1,338; 45%; 
Philadelphia: 300; 36%; 
Richmond: 723; 30%; 
San Francisco: 794; 53%; 
St. Louis: 264; 28%. 

Year: 2010; 
Atlanta: 784; 48%; 
Boston: 251; 29%; 
Chicago: 508; 38%; 
Cleveland: 259; 20%; 
Dallas: 555; 50%; 
Kansas City: 210; 16%; 
Minneapolis: 174; 17%; 
New York: 1,373; 46%; 
Philadelphia: 306; 36%; 
Richmond: 684; 29%; 
San Francisco: 811; 54%; 
St. Louis: 265; 28%. 

Year: 2009; 
Atlanta: 864; 50%; 
Boston: 257; 30%; 
Chicago: 529; 38%; 
Cleveland: 277; 21%; 
Dallas: 607; 5%2; 
Kansas City: 202; 17%; 
Minneapolis: 172; 16%; 
New York: 1,344; 46%; 
Philadelphia: 352; 39%; 
Richmond: 702; 29%; 
San Francisco: 874; 54%; 
St. Louis: 258; 28%. 

Year: 2008; 
Atlanta: 987; 52%; 
Boston: 270; 31%; 
Chicago: 549; 39%; 
Cleveland: 343; 23%; 
Dallas: 653; 53%; 
Kansas City: 227; 18%; 
Minneapolis: 192; 16%; 
New York: 1,269; 45%; 
Philadelphia: 435; 43%; 
Richmond: 781; 31%; 
San Francisco: 932; 55%; 
St. Louis: 293; 30%. 

Year: 2007; 
Atlanta: 1068; 53%; 
Boston: 302; 31%; 
Chicago: 599; 39%; 
Cleveland: 355; 23%; 
Dallas: 679; 54%; 
Kansas City: 261; 19%; 
Minneapolis: 207; 16%; 
New York: 1,230; 43%; 
Philadelphia: 479; 44%; 
Richmond: 910; 33%; 
San Francisco: 1,005; 56%; 
St. Louis: 349; 32%. 

Black or African American; 

Year: 2011; 
Atlanta: 525; 33%; 
Boston: 108; 12%; 
Chicago: 279; 19%; 
Cleveland: 167; 15%; 
Dallas: 238; 22%; 
Kansas City: 93; 8%; 
Minneapolis: 79; 8%; 
New York: 494; 17%; 
Philadelphia: 184; 22%; 
Richmond: 509; 21%; 
San Francisco: 101; 7%; 
St. Louis: 209; 22%. 

Year: 2010; 
Atlanta: 557; 34%; 
Boston: 106; 12%; 
Chicago: 275; 20%; 
Cleveland: 208; 16%; 
Dallas: 229; 21%; 
Kansas City: 107; 8%; 
Minneapolis: 81; 8%; 
New York: 523; 17%; 
Philadelphia: 198; 24%; 
Richmond: 503; 21%; 
San Francisco: 116; 8%; 
St. Louis: 215; 23%. 

Year: 2009; 
Atlanta: 634; 37%; 
Boston: 107; 1%2; 
Chicago: 310; 22%; 
Cleveland: 228; 17%; 
Dallas: 269; 23%; 
Kansas City: 109; 9%; 
Minneapolis: 82; 8%; 
New York: 530; 18%; 
Philadelphia: 248; 27%; 
Richmond: 533; 22%; 
San Francisco: 140; 9%; 
St. Louis: 216; 23%. 

Year: 2008; 
Atlanta: 758; 40%; 
Boston: 117; 13%; 
Chicago: 334; 24%; 
Cleveland: 290; 19%; 
Dallas: 326; 27%; 
Kansas City: 120; 9%; 
Minneapolis: 102; 9%; 
New York: 539; 19%; 
Philadelphia: 330; 32%; 
Richmond: 603; 24%; 
San Francisco: 160; 9%; 
St. Louis: 254; 26%. 

Year: 2007; 
Atlanta: 830; 41%; 
Boston: 132; 13%; 
Chicago: 391; 26%; 
Cleveland: 308; 20%; 
Dallas: 354; 28%; 
Kansas City: 146; 11%; 
Minneapolis: 118; 9%; 
New York: 560; 20%; 
Philadelphia: 372; 34%; 
Richmond: 713; 26%; 
San Francisco: 178; 10%; 
St. Louis: 315; 29%. 

Hispanic; 

Year: 2011; 
Atlanta: 147; 9%; 
Boston: 45; 5%; 
Chicago: 132; 9%; 
Cleveland: 12; 1%; 
Dallas: 235; 21%; 
Kansas City: 57; 5%; 
Minneapolis: 24; 2%; 
New York: 301; 10%; 
Philadelphia: 31; 4%; 
Richmond: 65; 3%; 
San Francisco: 179; 12%; 
St. Louis: 19; 2%. 

Year: 2010; 
Atlanta: 148; 9%; 
Boston: 41; 5%; 
Chicago: 114; 8%; 
Cleveland: 13; 1%; 
Dallas: 247; 2%2; 
Kansas City: 59; 5%; 
Minneapolis: 21; 2%; 
New York: 301; 10%; 
Philadelphia: 28; 3%; 
Richmond: 58; 2%; 
San Francisco: 177; 12%; 
St. Louis: 19; 2%. 

Year: 2009; 
Atlanta: 152; 9%; 
Boston: 44; 5%; 
Chicago: 112; 8%; 
Cleveland: 13; 1%; 
Dallas: 260; 22%; 
Kansas City: 51; 4%; 
Minneapolis: 20; 2%; 
New York: 290; 10%; 
Philadelphia: 28; 3%; 
Richmond: 56; 2%; 
San Francisco: 205; 13%; 
St. Louis: 15; 2%. 

Year: 2008; 
Atlanta: 148; 8%; 
Boston: 47; 5%; 
Chicago: 102; 7%; 
Cleveland: 16; 1%; 
Dallas: 265; 22%; 
Kansas City: 62; 5%; 
Minneapolis: 20; 2%; 
New York: 278; 10%; 
Philadelphia: 28; 3%; 
Richmond: 59; 2%; 
San Francisco: 224; 13%; 
St. Louis: 15; 2%. 

Year: 2007; 
Atlanta: 153; 8%; 
Boston: 52; 5%; 
Chicago: 96; 6%; 
Cleveland: 14; 1%; 
Dallas: 266; 21%; 
Kansas City: 67; 5%; 
Minneapolis: 20; 2%; 
New York: 280; 10%; 
Philadelphia: 29; 3%; 
Richmond: 63; 2%; 
San Francisco: 251; 14%; 
St. Louis: 9; 1%. 

Asian; 

Year: 2011; 
Atlanta: 69; 4%; 
Boston: 112; 13%; 
Chicago: 119; 8%; 
Cleveland: 29; 3%; 
Dallas: 67; 6%; 
Kansas City: 41; 3%; 
Minneapolis: 71; 7%; 
New York: 523; 18%; 
Philadelphia: 80; 10%; 
Richmond: 129; 5%; 
San Francisco: 490; 33%; 
St. Louis: 33; 3%. 

Year: 2010; 
Atlanta: 68; 4%; 
Boston: 104; 12%; 
Chicago: 109; 8%; 
Cleveland: 31; 2%; 
Dallas: 73; 7%; 
Kansas City: 40; 3%; 
Minneapolis: 66; 7%; 
New York: 532; 18%; 
Philadelphia: 75; 9%; 
Richmond: 103; 4%; 
San Francisco: 493; 33%; 
St. Louis: 29; 3%. 

Year: 2009; 
Atlanta: 68; 4%; 
Boston: 105; 12%; 
Chicago: 95; 7%; 
Cleveland: 29; 2%; 
Dallas: 70; 6%; 
Kansas City: 38; 3%; 
Minneapolis: 64; 6%; 
New York: 508; 17%; 
Philadelphia: 73; 8%; 
Richmond: 96; 4%; 
San Francisco: 502; 31%; 
St. Louis: 25; 3%. 

Year: 2008; 
Atlanta: 72; 4%; 
Boston: 106; 12%; 
Chicago: 101; 7%; 
Cleveland: 28; 2%; 
Dallas: 54; 4%; 
Kansas City: 41; 3%; 
Minneapolis: 65; 6%; 
New York: 439; 16%; 
Philadelphia: 75; 7%; 
Richmond: 103; 4%; 
San Francisco: 516; 30%; 
St. Louis: 22; 2%. 

Year: 2007; 
Atlanta: 78; 4%; 
Boston: 117; 12%; 
Chicago: 104; 7%; 
Cleveland: 26; 2%; 
Dallas: 53; 4%; 
Kansas City: 43; 3%; 
Minneapolis: 64; 5%; 
New York: 389; 14%; 
Philadelphia: 75; 7%; 
Richmond: 113; 4%; 
San Francisco: 547; 31%; 
St. Louis: 23; 2%. 

Other; 

Year: 2011; 
Atlanta: 14; 1%; 
Boston: 3; 0%; 
Chicago: 12; 1%; 
Cleveland: 8; 1%; 
Dallas: 7; 1%; 
Kansas City: 8; 1%; 
Minneapolis: 7; 1%; 
New York: 20; 1%; 
Philadelphia: 5; 1%; 
Richmond: 20; 1%; 
San Francisco: 24; 2%; 
St. Louis: 3; 0%. 

Year: 2010; 
Atlanta: 11; 1%; 
Boston: 0; 0%; 
Chicago: 10; 1%; 
Cleveland: 7; 1%; 
Dallas: 6; 1%; 
Kansas City: 4; 0%; 
Minneapolis: 6; 1%; 
New York: 17; 1%; 
Philadelphia: 5; 1%; 
Richmond: 20; 1%; 
San Francisco: 25; 2%; 
St. Louis: 2; 0%. 

Year: 2009; 
Atlanta: 10; 1%; 
Boston: 1; 0%; 
Chicago: 12; 1%; 
Cleveland: 7; 1%; 
Dallas: 8; 1%; 
Kansas City: 4; 0%; 
Minneapolis: 6; 1%; 
New York: 16; 1%; 
Philadelphia: 3; 0%; 
Richmond: 17; 1%; 
San Francisco: 27; 2%; 
St. Louis: 2; 0%. 

Year: 2008; 
Atlanta: 9; 0%; 
Boston: 0; 0%; 
Chicago: 12; 1%; 
Cleveland: 9; 1%; 
Dallas: 8; 1%; 
Kansas City: 4; 0%; 
Minneapolis: 5; 0%; 
New York: 13; 0%; 
Philadelphia: 2; 0%; 
Richmond: 16; 1%; 
San Francisco: 32; 2%; 
St. Louis: 2; 0%. 

Year: 2007; 
Atlanta: 7; 0%; 
Boston: 1; 0%; 
Chicago: 8; 1%; 
Cleveland: 7; 0%; 
Dallas: 6; 0%; 
Kansas City: 5; 0%; 
Minneapolis: 5; 0%; 
New York: 1; 0%; 
Philadelphia: 3; 0%; 
Richmond: 21; 1;% 
San Francisco: 29; 2%; 
St. Louis: 2; 0%. 

Source: GAO analysis of EEO-1 reports provided by Reserve Banks. 

Note: Percentages are rounded to the nearest percent. 

[End of table] 

Table 13: Percentage of Women among All Employees at Seven Federal 
Financial Agencies, 2007-2011: 

Federal financial agency employees (number and percent): 

Gender: All; 

Year: 2011; 
FDIC: 8,398; 100%; 
Federal Reserve: 2,274; 100%; 
FHFA[A]: 494; 100%; 
NCUA: 1,159; 100%; 
OCC: 3,560; 100%; 
SEC: 3,812; 100%; 
Treasury: 1,586; 100%. 

Year: 2010; 
FDIC: 8,316; 100%; 
Federal Reserve: 2,137; 100%; 
FHFA[A]: 406; 100%; 
NCUA: 1,095; 100%; 
OCC: 3,054; 100%; 
SEC: 3,897; 100%; 
Treasury: 1,599; 100%. 

Year: 2009; 
FDIC: 6,530; 100%; 
Federal Reserve: 2,143; 100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 1,024; 100%; 
OCC: 3,117; 100%; 
SEC: 3,720; 100%; 
Treasury: 1,529; 100%. 

Year: 2008;
FDIC: 5,028; 100%; 
Federal Reserve: 2,028; 100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 934; 100%; 
OCC: 3,039; 100%; 
SEC: 3,653; 100%; 
Treasury: 1,295; 100%. 

Year: 2007; 
FDIC: 4,428; 100%; 
Federal Reserve: 1,945;100%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 929; 100%; 
OCC: 3,000; 100%; 
SEC: 3,154; 100%; 
Treasury: 1,223; 100%. 

Gender: Men; 

Year: 2011; 
FDIC: 4,846; 58%; 
Federal Reserve: 1,238; 54%; 
FHFA[A]: 277; 56%; 
NCUA: 640; 55%; 
OCC: 1,917; 54%; 
SEC: 1,984; 52%; 
Treasury: 822; 52%. 

Year: 2010; 
FDIC: 4,852; 58%; 
Federal Reserve: 1,138; 53%; 
FHFA[A]: 219; 54%; 
NCUA: 589; 54%; 
OCC: 1,587; 52%; 
SEC: 2,024; 52%; 
Treasury: 827; 52%. 

Year: 2009; 
FDIC: 3,735; 57; 
Federal Reserve: 1,140; 53%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 555; 54%; 
OCC: 1,617; 52%; 
SEC: 1,924; 52%; 
Treasury: 798; 52%. 

Year: 2008; 
FDIC: 2,809; 56%; 
Federal Reserve: 1,080; 53%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 515; 55%; 
OCC: 1,584; 52%; 
SEC: 1,882; 52%; 
Treasury: 657; 51%. 

Year: 2007; 
FDIC: 2,462; 56%; 
Federal Reserve: 1,022; 53%; 
FHFA[A]:[Empty]; [Empty]; 
NCUA: 509; 55%; 
OCC: 1,583; 53%; 
SEC: 1,655; 52%; 
Treasury: 613; 50%. 

Gender: Women; 

Year: 2011; 
FDIC: 3,552; 42%; 
Federal Reserve: 1,036; 46%; 
FHFA[A]: 217; 44%; 
NCUA: 519; 45%; 
OCC: 1,643; 46%; 
SEC: 1,828; 48%; 
Treasury: 764; 48%. 

Year: 2010; 
FDIC: 3,464; 42%; 
Federal Reserve: 999; 47%; 
FHFA[A]: 187; 46%; 
NCUA: 506; 46%; 
OCC: 1,467; 48%; 
SEC: 1,873; 48%; 
Treasury: 772; 48%. 

Year: 2009; 
FDIC: 2,795; 43%; 
Federal Reserve: 1,003; 47%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 469; 46%; 
OCC: 1,500; 48%; 
SEC: 1,796; 48%; 
Treasury: 731; 48%. 

Year: 2008; 
FDIC: 2,219; 44%; 
Federal Reserve: 948; 47%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 419; 45%; 
OCC: 1,455; 48%; 
SEC: 1,771; 48%; 
Treasury: 638; 49%. 

Year: 2007; 
FDIC: 1,966; 44%; 
Federal Reserve: 923; 47%; 
FHFA[A]: [Empty]; [Empty]; 
NCUA: 420; 45%; 
OCC: 1,417; 47%; 
SEC: 1,499; 48%; 
Treasury: 610; 50%. 

Source: GAO analysis of agency reports. 

Note: Percentages are rounded to the nearest percent. 

For our analysis, we reviewed the numbers of employees the agencies 
reported according to race/ethnicity and gender in table A3 of their 
MD-715 reports from 2007 through 2011. These data are based on 
information self-reported by employees to each agency and there were 
some differences in reporting across the agencies. In some years, some 
agencies reported all employees--permanent and temporary--in their A3 
tables while others reported permanent employees only. 

[A] FHFA was established in 2008 and started reporting workforce data 
for 2010. 

[End of table] 

Table 14: Percentage of Women among All Employees at the 12 Reserve 
Banks, 2007-2011: 

Reserve Bank employees (number and percent): 

Race/Ethnicity: All; 

Year: 2011; 
Atlanta: 1,594; 100%; 
Boston: 875; 100%; 
Chicago: 1,431; 100%; 
Cleveland: 1,094; 100%; 
Dallas: 1,098; 100%; 
Kansas City: 1,225; 100%; 
Minneapolis: 1,011; 100%; 
New York: 2,955; 100%; 
Philadelphia: 869; 100%; 
Richmond: 2,444; 100%; 
San Francisco: 1,495; 100%; 
St. Louis: 955; 100%. 

Year: 2010; 
Atlanta: 1,623; 100%; 
Boston: 858; 100%; 
Chicago: 1,353; 100%; 
Cleveland: 1,276; 100%; 
Dallas: 1,110; 100%; 
Kansas City: 1,292; 100%; 
Minneapolis: 1,004; 100%; 
New York: 2,999; 100%; 
Philadelphia: 840; 100%; 
Richmond: 2,356; 100%; 
San Francisco: 1,514; 100%; 
St. Louis: 944; 100%. 

Year: 2009; 
Atlanta: 1,728; 100%; 
Boston: 868; 100%; 
Chicago: 1,379; 100%; 
Cleveland: 1,340; 100%; 
Dallas: 1,168; 100%; 
Kansas City: 1,220; 100%; 
Minneapolis: 1,051; 100%; 
New York: 2,940; 100%; 
Philadelphia: 914; 100%; 
Richmond: 2,421; 100%; 
San Francisco: 1,632; 100%; 
St. Louis: 932; 100%. 

Year: 2008; 
Atlanta: 1,886; 100%; 
Boston: 884; 100%; 
Chicago: 1,415; 100%; 
Cleveland: 1,511; 100%; 
Dallas: 1,225; 100%; 
Kansas City: 1,277; 100%; 
Minneapolis: 1,172; 100%; 
New York: 2,791; 100%; 
Philadelphia: 1016; 100%; 
Richmond: 2,534; 100%; 
San Francisco: 1,700; 100%; 
St. Louis: 987; 100%. 

Year: 2007; 
Atlanta: 2,017; 100%; 
Boston: 978; 100%; 
Chicago: 1,532; 100%; 
Cleveland: 1,568; 100%; 
Dallas: 1,269; 100%; 
Kansas City: 1,357; 100%; 
Minneapolis: 1,278; 100%; 
New York: 2,860; 100%; 
Philadelphia: 1092; 100%; 
Richmond: 2,733; 100%; 
San Francisco: 1,779; 100%; 
St. Louis: 1,089; 100%. 

Race/Ethnicity: Men; 

Year: 2011%; 
Atlanta: 853; 54%; 
Boston: 475; 54%; 
Chicago: 775; 54%; 
Cleveland: 594; 54%; 
Dallas: 631; 57%; 
Kansas City: 650; 53%; 
Minneapolis: 473; 47%; 
New York: 1,587; 54%; 
Philadelphia: 503; 60%; 
Richmond: 1,460; 60%; 
San Francisco: 889; 59%; 
St. Louis: 517; 54%. 

Year: 2010%; 
Atlanta: 856; 53%; 
Boston: 469; 55%; 
Chicago: 728; 54%; 
Cleveland: 648; 51%; 
Dallas: 640; 58%; 
Kansas City: 677; 52%; 
Minneapolis: 468; 47%; 
New York: 1,621; 54%; 
Philadelphia: 498; 59%; 
Richmond: 1,396; 59%; 
San Francisco: 905; 60%; 
St. Louis: 510; 54%. 

Year: 2009%; 
Atlanta: 913; 53%; 
Boston: 471; 54%; 
Chicago: 729; 53%; 
Cleveland: 678; 51%; 
Dallas: 669; 57%; 
Kansas City: 617;51%; 
Minneapolis: 474; 45%; 
New York: 1,600; 54%; 
Philadelphia: 432; 58%; 
Richmond: 1,410; 58%; 
San Francisco: 950; 58%; 
St. Louis: 499; 54%. 

Year: 2008%; 
Atlanta: 964; 51%; 
Boston: 477; 54%; 
Chicago: 707; 50%; 
Cleveland: 727; 48%; 
Dallas: 685; 56%; 
Kansas City: 626; 49%; 
Minneapolis: 497; 42%; 
New York: 1,506; 54%; 
Philadelphia: 567; 56%; 
Richmond: 1,420; 56%; 
San Francisco: 959; 56%; 
St. Louis: 526; 53%. 

Year: 2007%; 
Atlanta: 1,008; 50%; 
Boston: 491; 50%; 
Chicago: 745; 49%; 
Cleveland: 741; 47%; 
Dallas: 689; 54%; 
Kansas City: 647; 48%; 
Minneapolis: 521; 41%; 
New York: 1,512; 53%; 
Philadelphia: 603; 55%; 
Richmond: 1,505; 55%; 
San Francisco: 992; 56%; 
St. Louis: 556; 51%. 

Race/Ethnicity: Women%; 

Year: 2011%; 
Atlanta: 741; 46%; 
Boston: 400; 46%; 
Chicago: 656; 46%; 
Cleveland: 500; 46%; 
Dallas: 467; 43%; 
Kansas City: 575; 47%; 
Minneapolis: 538; 53%; 
New York: 1,368; 46%; 
Philadelphia: 336; 40%; 
Richmond: 984; 40%; 
San Francisco: 606; 41%; 
4St. Louis: 38; 46%. 

Year: 2010%; 
Atlanta: 767; 47%; 
Boston: 389; 45%; 
Chicago: 625; 46%; 
Cleveland: 628; 49%; 
Dallas: 470; 42%; 
Kansas City: 615; 48%; 
Minneapolis: 536; 53%; 
New York: 1,378; 46%; 
Philadelphia: 342; 41%; 
Richmond: 960; 41%; 
San Francisco: 609; 40%; 
St. Louis: 434; 46%. 

Year: 2009%; 
Atlanta: 815; 47%; 
Boston: 397; 46%; 
Chicago: 650; 47%; 
Cleveland: 662; 49%; 
Dallas: 499; 43%; 
Kansas City: 603; 49%; 
Minneapolis: 577; 55%; 
New York: 1,340; 46%; 
Philadelphia: 382; 42%; 
Richmond: 1,011; 42%; 
San Francisco: 682; 42%; 
St. Louis: 433; 46%. 

Year: 2008%; 
Atlanta: 922; 49%; 
Boston: 407; 46%; 
Chicago: 708; 50%; 
Cleveland: 784; 52%; 
Dallas: 540; 44%; 
Kansas City: 651; 51%; 
Minneapolis: 675; 58%; 
New York: 1,285; 46%; 
Philadelphia: 449; 44%; 
Richmond: 1,114; 44%; 
San Francisco: 741; 44%; 
St. Louis: 461; 47%. 

Year: 2007; 
Atlanta: 1,009; 50%; 
Boston: 487; 50%; 
Chicago: 787; 51%; 
Cleveland: 827; 53%; 
Dallas: 580; 46%; 
Kansas City: 710; 52%; 
Minneapolis: 757; 59%; 
New York: 1,348; 47%; 
Philadelphia: 489; 45%; 
Richmond: 1,228; 45%; 
San Francisco: 787; 44%; 
St. Louis: 533; 49%. 

Source: GAO analysis of EEO-1 reports provided by Reserve Banks. 

Note: Percentages are rounded to the nearest percent. 

[End of table] 

[End of section] 

Appendix V: Comments from the Consumer Financial Protection Bureau: 

Consumer Financial Protection Bureau: 
1700 G Street NW: 
Washington, DC 20552: 

March 25, 2013: 

Mr. Daniel Garcia-Diaz: 
Director: 
Financial Markets and Community Investment: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. Garcia-Diaz: 

Thank you for the opportunity to comment on the Government 
Accountability Office's (GAO) draft report, Diversity Management, 
Trends and Practices in the Financial Services Industry and Agencies 
After the Recent Financial Crisis, GAO-13-238. 

This report examines workforce diversity in the financial services 
industry and in the financial regulatory agencies from 2007 through 
2011 and also efforts by the financial regulatory agencies to 
implement workforce and contractor diversity practices under the Dodd-
Frank Act. The Consumer Financial Protection Bureau (CFPB or Bureau) 
opened its doors for business in July 2011, and its Office of Minority 
and Women Inclusion (OMWI) was established in January 2012. As the 
report notes, the Director of OMWI assumed his duties on April 30, 
2012. 

The report contains one recommendation: 

To enhance the availability of information on the progress and impact 
of agency and reserve bank diversity practices, we are recommending to 
CFPB...that each OMWI report on efforts to measure the progress of its 
employment diversity and inclusion practices, including measurement 
outcomes as appropriate, to indicate areas for improvement as part of 
its annual report to Congress. 

CFPB concurs with the recommendation. 

As we discussed during our meetings, the OMWI at CFPB is the newest 
OMWI to open following the creation of the Bureau in the Dodd-Frank 
Act. Because the Bureau was formed after the period 2007-11, the 
report does not contain workforce information from that period. The 
CFPB did provide demographic information about its workforce as of May 
2012. 

Since I began my tenure as the OMWI Director on April 30, 2012, the 
office has been building capacity to address the three primary 
responsibilities of the office: promoting diversity and inclusion in 
the Bureau's workforce, in the Bureau's procurement, and working with 
our fellow financial regulators and their OMWI offices to create 
standards for diversity and inclusion at regulated entities. The 
office has made good progress during these opening months in 
addressing these disparate challenges, and has set a solid foundation 
for the work that lies ahead. 

We agree that reporting on appropriate measures to improve diversity 
and inclusion in employment would be a valuable addition to the annual 
report to Congress. Much of our work in this first year is obtaining 
and understanding the baselines for measurements. We expect in future 
reports to build out this reporting, as appropriate, and to address 
areas for improvement. 

Thank you for the opportunity to comment on the report. 

Sincerely, 

Signed by: 

Stuart J. Ishimaru: 
Director: 
Office of Minority and Women Inclusion: 

[End of section] 

Appendix VI: Comments from the Federal Reserve Banks: 

Federal Reserve Banks of:       
Boston, New York, Philadelphia, Cleveland, Richmond, Atlanta, Chicago, 
St. Louis, Minneapolis, Kansas City, Dallas, San Francisco: 

March 25, 2013: 

Mr. Daniel Garcia-Diaz: 
Director: 
Financial Markets and Community Investment: 
Government Accountability Office: 
441 G Street, NW: 
Washington, D.C. 20548: 

Dear Mr. Garcia-Diaz: 

Thank you for the opportunity to respond to the GAO's draft report on 
"Diversity Management: Trends and Practices in the Financial Services 
Industry and Agencies after the Recent Financial Crisis" (GAO-13-238). 
This letter represents a consolidated response from all twelve 
Directors of the Office of Minority and Women Inclusion (OMWI) at the 
Reserve Banks. 

The Reserve Banks are committed to promoting workforce diversity and 
increasing contracting opportunities for minority-owned and women-
owned businesses. As the GAO report recognizes, significant efforts 
have been undertaken to satisfy the requirements of Section 342 of the 
Dodd-Frank Wall Street Reform and Consumer Protection Act. The report 
contains one recommendation to the agencies and Reserve Banks: that 
each OMWI report on its efforts to measure the progress of diversity 
and inclusion practices in its annual report to Congress. The Reserve 
Banks currently include some measurements in the annual reports. We 
will evaluate these current efforts and consider additional ways to 
measure and report on the progress of our diversity practices. 

We appreciate the attention of the GAO to this important topic and 
wish to thank the GAO staff for the courtesy and professionalism 
demonstrated during the review. 

Signed by: 

Marques Benton: 
Federal Reserve Bank of Boston: 

Diane Ashley: 
Federal Reserve Bank of New York: 
                
Mary Ann Hood: 
Federal Reserve Bank of Philadelphia: 

David W. Hollis: 
Federal Reserve Bank of Cleveland: 

Tammy H. Cummings: 
Federal Reserve Bank of Richmond: 

Joan H. Buchanan: 
Federal Reserve Bank of Atlanta: 

Valerie Van Meter: 
Federal Reserve Bank of Chicago: 

James Price: 
Federal Reserve Bank of St. Louis: 

Duane Carter: 
Federal Reserve Bank of Minneapolis: 

Donna J. Ward: 
Federal Reserve Bank of Kansas City: 

Tyrone Gholson: 
Federal Reserve Bank of Dallas: 

Susan A. Sutherland: 
Federal Reserve Bank of San Francisco: 

[End of section] 

Appendix VII: Comments from the Federal Reserve Board: 

Board of Governors of The Federal Reserve System: 
Washington, DC 20551: 

March 26, 2013: 

Mr. Daniel Garcia-Diaz: 
Director, Financial Markets: 
and Community Investment: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Garcia-Diaz: 

Thank you for the opportunity to comment on your draft report entitled 
"Diversity Management: Trends and Practices in the Financial Services 
Industry and Agencies After the Recent Financial Crisis". The Federal 
Reserve Board takes seriously its efforts to encourage and promote 
diversity in its workforce and contracting decisions. As the draft 
report shows, the Federal Reserve Board's representation of both 
minorities and women at the senior management-level increased from 
2007 through 2011. In addition, the report determined that the 
representation of both minorities and women among mid-level officials 
and managers at the Federal Reserve Board in 2011 was highest among 
the agencies the GAO reviewed. 

The report includes one recommendation to the agencies and reserve 
banks, which is: 

To enhance the availability of information on the progress and impact 
of agency and Reserve Bank diversity practices, we are recommending to 
CFPB, FDIC, the Federal Reserve Board, FHFA, NCUA, OCC, SEC, Treasury, 
and the Reserve Banks that each OMWI report on efforts to measure the 
progress of its employment diversity and inclusion practices,
including measurement outcomes as appropriate, to indicate areas for 
improvement as part of its annual report to Congress. 

As we have discussed with the GAO, this recommendation is consistent 
with our ongoing practices. We will look for additional ways to 
measure and report on the progress of our diversity practices. 

We appreciate the thorough and comprehensive analysis the GAO has 
provided. 

Signed by: 

Sheila Clark: 
Director: 
Office of Minority and Women and Inclusion: 

[End of section] 

Appendix VIII: Comments from the Federal Deposit Insurance Corporation: 

FDIC: 
Federal Deposit insurance Corporation: 
Office of Minority and Women Inclusion: 
3501 Fairfax Drive: 
Arlington, VA 22226-3500: 

March 29, 2013: 

Mr. Daniel Garcia-Diaz: 
Director, Financial Markets and Community Investment: 
United States Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Garcia-Diaz: 

The Federal Deposit Insurance Corporation (FDIC) reviewed the GAO 
report Diversity Management: Trends and Practices in the Financial 
Services Industry and Agencies After the Recent Financial Crisis 
(Report) (GAO-13-238). The Report stated each agency should include in 
its annual OMWI report to Congress efforts to measure the progress of 
its diversity practices. The FDIC agrees with the Report's 
recommendation and will include efforts to measure the progress of our 
diversity practices in annual OMWI report to Congress. We believe this 
recommendation is important to not only meeting the requirements of 
Section 342 of the Dodd-Frank Act, but to the success of the FDIC in 
carrying out its mission responsibilities. 

The FDIC is committed to providing all employees with a work 
environment that embodies excellence, and acknowledges and honors the 
diversity of its employees. In 2012, the FDIC Acting Chairman 
established a number of Performance Goals designed to enhance the 
FDIC's commitment to diversity, inclusion, and equal employment 
opportunity, including asking the Corporation's senior leaders to 
update the FDIC's Diversity Strategic Plan and directing each division 
and major office to develop its own strategic plans to identify steps 
to increase diversity through the FDIC's recruiting and hiring. 

The FDIC's updated 2013 Diversity and Inclusion Strategic Plan 
addresses the goals of Executive Order 13583, dated August 18, 2011, 
which calls for federal agencies to develop and implement a more 
comprehensive, integrated, and strategic focus on diversity and 
inclusion. The plan lays out a course for achieving workforce 
diversity by recruiting from a diverse, qualified group of potential 
applicants; cultivating workplace inclusion through collaboration, 
flexibility, and fairness; and ensuring sustainability of diversity 
and inclusion achievements by equipping leaders with the ability to 
manage diversity, measure results, and refine approaches based on 
available data. The updated plan issued on March 1, 2013, follows the 
guidance issued by the U.S. Office of Personnel Management (OPM) in 
November 2011, and identifies a number of strategies and action plans 
to address workforce diversity, workplace inclusion, and 
sustainability. 

Specifically, under sustainability, the FDIC will develop structures 
and strategies to equip leaders with the ability to manage diversity, 
be accountable, measure results, refine approaches on the basis of 
such data, and institutionalize a culture of inclusion. This objective 
will improve diversity and inclusion analytics and reporting by using 
a strategy to make diversity and inclusion reporting more actionable 
through improvements in data collection, presentation, and reporting 
frequency. 

Further, in 2012, the FDIC contracted for a third party review of 
diversity and inclusion programs and activities to help us identify 
additional initiatives to strengthen our diversity practices.
Thank you for the opportunity to review the Report. 

Sincerely, 

Signed by: 

D. Michael Collins: 
Director: 

[End of section] 

Appendix IX: Comments from the Federal Housing Finance Agency: 

Federal Housing Finance Agency: 
Constitution Center: 
400 7th Street, S.W. 
Washington, D.C. 20024: 
Telephone: (202) 649-3800: 
Facsimile: (202) 649-1071: 
[hyperlink, http://www.fhfa.gov] 

March 25, 2013: 

Mr. Daniel Garcia-Diaz: 
Director: 
Financial Markets and Community Investment: 
Government Accountability Office (GAO): 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Garcia-Diaz: 

Thank you for the opportunity to review and comment on the Government 
Accountability Office (GAO) Report, Diversity Management; Trends and 
Practices in the Financial Services Industry and Agencies After the 
Recent Financial Crisis. 

During the review GAO examined diversity in the financial services 
industry, the federal financial agencies, and the Federal Reserve 
Banks (Reserve Banks) and efforts of the agencies and Reserve Banks to 
implement diversity practices under the Dodd-Frank Act. The GAO has 
recommended that the agencies and Reserve Banks, including the Federal 
Housing Finance Agency (FHFA), should include in its annual Office of 
Minority and Women Inclusion (OMWI) report to Congress efforts to 
measure the progress of its diversity practices, including measurement 
outcomes as appropriate, to indicate areas for improvement as part of 
their annual reports to Congress. 

FHFA agrees with the recommendation to include in our annual OMWI 
report to Congress our efforts to measure the progress of our 
diversity efforts, and will include this information in FHFA's 2013 
OMWI Annual Report to Congress. 

If you have any questions, please do not hesitate to contact me. 

Sincerely, 

Signed by: 

Nancy P. Burnett: 
Acting Associate Director: 
Office of Minority and Women Inclusion: 
Federal Housing Finance Agency: 

[End of section] 

Appendix X: Comments from the National Credit Union Administration: 

National Credit Union Administration: 
1775 Duke Street: 
Alexandria, VA 22314-3428: 
703-518-6300: 

March 26, 2013: 

Ms. Kay D. Kuhlman: 
Assistant Director: 
Financial Markets and Community Investment: 
U. S. Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Ms. Kuhlman: 

Thank you for the opportunity to review and comment on the draft GAO 
report for the Committee on Financial Services of the U.S. House of 
Representatives. The report, titled "Diversity Management: Trends and 
Practice in the Financial Services Industry and Agencies After the 
Recent Financial Crisis" is comprehensive and appropriately outlines 
the changes in the agencies' workforce and in the industry from 2007 
to 2011. 

Overall, your report indicates the financial services agencies made 
some progress in diversity although additional progress needs to be 
made. In 2012, NCUA continues to make strides and address challenges 
in achieving its goal of "cultivating a diverse, well trained, and 
motivated workforce." The establishment of the Office of Minority and 
Women Inclusion, in 2011, helped NCUA focus its diversity efforts. Our 
2012 Annual Report to Congress highlights many of the accomplishments 
achieved in diversity of the workforce and contracting as well as the 
challenges. 

We agree with your recommendation and will work towards reporting on 
our efforts to measure the progress of the workforce diversity and 
inclusion practices, including measurement outcomes as appropriate, as 
part of the annual reports to Congress. 

Sincerely, 

Signed by: 

Mark A. Treichel: 
Executive Director: 

[End of section] 

Appendix XI: Comments from the Comptroller of the Currency: 

Comptroller of the Currency: 
Administrator of National Banks: 
Washington, DC 20219: 

March 22, 2013: 

Mr. Daniel Garcia-Diaz: 
Director, Financial Markets and Community Investment: 
United States Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Garcia-Diaz: 

Thank you for the opportunity to review the draft report titled 
"Diversity Management: Trends and Practices in the Financial Services 
Industry and Agencies After the Recent Financial Crisis." Your report 
responds to congressional requests that GAO review (1) workforce 
diversity in the financial services industry, the federal financial 
agencies and the Federal Reserve Banks (Reserve Banks) from 2007-2011 
and (2) efforts of the agencies and Reserve Banks to implement 
workforce diversity practices under the Dodd-Frank Act, including 
contracting. 

The draft report fords that industry diversity levels remained about 
the same from 2007 through 2011; agency and Reserve Bank workforce 
diversity varied, and officials reported difficulty identifying 
diverse candidates; and Dodd-Frank requirements are being implemented, 
but enhanced reporting of efforts to measure progress is needed. 

GAO recommends that each Office of Minority and Women Inclusion report 
on efforts to measure the progress of its employment diversity and 
inclusion practices, including measurement outcomes as appropriate, to 
indicate areas for improvement as part of its annual report to 
Congress. 

We acknowledge and accept GAO's recommendation and are pleased to 
report that the OCC has a well-established employment diversity and 
inclusion program that measures and evaluates the agency's
progress in these areas. Further, we have included additional 
workforce data and metrics in our fiscal year 2012 Section 342 annual 
report. 

We appreciate the opportunity to comment on the draft Report. If you 
need additional information, please contact Joyce B. Cofield, 
Executive Director, Office of Minority and Women Inclusion, at (202) 
649-6892. 

Sincerely, 

Signed by: 

Thomas J. Curry: 
Comptroller of the Currency: 

[End of section] 

Appendix XII: Comments from the Securities and Exchange Commission: 

United States Securities and Exchange Commission: 
Office of Minority and Women Inclusion: 
Washington, D.C. 20549: 

March 13, 2013: 

Mr. Daniel Garcia-Diaz: 
Director, Financial Markets and Community Investment: 
Government Accountability Office: 
441 G Street NW: 
Washington, D.C. 20548: 

Dear Mr. Garcia-Diaz: 

This letter responds to your request, dated April 2013 to review and 
comment on the draft GAO report entitled Diversity Management: Trends 
and Practices in the Financial Services Industry and Agencies After 
the Recent Financial Crisis (GAO-13-238). 

The U.S. Securities and Exchange Commission's (SEC) Office of Minority 
and Women inclusion (0MW1) appreciates the United States Government 
Accountability Office's (GAO) thorough review of trends and practices 
since the beginning of the financial crisis - updating GAO's previous 
work by discussing 1) workforce diversity at the management level in 
the financial services industry, federal financial agencies such as 
the SEC and Reserve Banks from 2007-2011 and 2) the implementation of 
requirements in Section 342 of the Dodd-Frank Act regarding workplace 
diversity including contracting. 

OMWI accepts and endorses GAO's recommendation that it include in its 
annual OMWI report to Congress efforts to measure the progress of its 
diversity practices. Our office plans to incorporate such measurements 
in its future annual reports upon their implementation. 

In addition, we submit the following minor comments to the draft GAO 
report: 

* The information in Table 3 (p. 34) of the draft GAO report should be 
corrected to reflect that the stalling level allocation for OMWI in 
Fiscal Year 2012 was 9 Full Time Equivalent Positions and as of 
January 2013, 8 such positions were filled. In the draft GAO report 
provided to OMW1 for review and comment, Table 3 shows that OMWI was 
allocated 11 Full Time Equivalent Positions and 10 such were filled. 

* With regard to the draft GAO report section entitled Fair Inclusion 
Provision in Contracts (p. 44), please note that in addition to the 
Consumer Financial Protection Board, the SEC has also been using the 
equal employment opportunity statement contained in the Federal 
Acquisition Regulation in executed contracts while the SEC develops an 
inclusion statement pursuant to Section 342(c)(2). 

* Under the same section entitled Fair Inclusion Provision in 
Contracts and in relation to Section 342 (c)(1) and (2), OMWI suggests 
restating the second sentence to provide as follows: "Section 342 of 
the Dodd-Frank Act requires agencies and Reserve Banks to develop 
procedures for review and evaluation of contract proposals and for 
hiring service providers that include a written statement that it 
contractor shall ensure, to the maximum extent possible, the fair 
inclusion of women and minorities in the workforce of the contractor 
and, as applicable, subcontractors." 

Thank you for the consideration that you and your staff have shown our 
staff and for the opportunity to comment an this draft report. If you 
have any questions or would like to further discuss this letter, 
please feel free to contact me at (202) 551-6503. 

Sincerely, 

Signed by: 

Pamela A. Gibbs: 
Director: 

[End of section] 

Appendix XIII: Comments from the Treasury Department: 

DEPARTMENT OF THE TREASURY: 
WASHINGTON, D.C. 20220: 

March 29, 2013: 

Sent via email to trinderj@gao.aov: 

Daniel Garcia-Diaz: 
Director, Financial Markets and Community Investment: 
Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Mr. Garcia-Diaz: 

Thank you for providing the Department of the Treasury an opportunity 
to review your draft report entitled Diversity Management: Trends and 
Practices in the Financial Services Industry and Agencies After the 
Recent Financial Crisis. Covering 2007 to 2011, the report provides 
important workforce trends leading up to the FY 2011 baseline year for 
the Treasury's Departmental Offices, Office of Minority and Women 
Inclusion (OMWI). While the workforce of Treasury's Departmental 
Offices is comprised of a different range of critical occupations than 
those of the financial services industry, the federal reserve banks 
and the other federal financial agencies, the data in the draft report 
are relevant to our analysis of that segment of common occupations in 
our workforce. 

We welcome the GAO recommendation to incorporate one of the nine 
leading diversity practices as part of the analysis in future OMWI 
annual reports to Congress. This recommendation is consistent with the 
efforts of Treasury's Departmental Offices to move beyond using only 
demographic representation to gauge the status and progress of 
diversity and inclusion within the Departmental Offices. 

While there is still much more work to be done, we value the important 
strides that have been made in workforce and business diversity within 
Treasury's Departmental Offices. 

Sincerely, 

Signed by: 

Lorraine Cole, Ph.D. 
Director, Office of Minority and Women Inclusion: 

[End of section] 

Appendix XIV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Daniel Garcia-Diaz, (202) 512-8678 or garciadiazd@GAO.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Kay Kuhlman, Assistant 
Director; Heather Chartier; Brendan Kretzschmar; Alma Laris; Ruben 
Montes de Oca; Cheryl Peterson; Jennifer Schwartz; Jena Sinkfield; 
Andrew Stavisky; and Julie Trinder made major contributions to this 
report. 

[End of section] 

Footnotes: 

[1] GAO has conducted prior work on the challenges faced in the 
financial sector for promoting and retaining a diverse workforce. See 
GAO, Financial Services Industry: Overall Trends in Management-Level 
Diversity and Diversity Initiatives, 1993-2004, [hyperlink, 
http://www.gao.gov/products/GAO-06-617] (Washington, D.C.: June 1, 
2006) and Financial Services Industry: Overall Trends in Management-
Level Diversity and Diversity Initiatives, 1993-2008, [hyperlink, 
http://www.gao.gov/products/GAO-10-736T] (Washington, D.C.: May 12, 
2010). 

[2] Pub. L. No. 111-203 § 342,124 Stat.1376,1441-1443 (2010).The 
federal agencies required to meet the workforce diversity provisions 
in section 342 of the Dodd-Frank Act include the Departmental Offices 
of the Department of the Treasury (Treasury), the Federal Deposit 
Insurance Corporation (FDIC), the Federal Housing Finance Agency 
(FHFA), the Board of Governors of the Federal Reserve System (Federal 
Reserve Board), the National Credit Union Administration (NCUA), the 
Office of the Comptroller of the Currency (OCC), the Securities and 
Exchange Commission (SEC), and the Bureau of Consumer Financial 
Protection, commonly known as the Consumer Financial Protection Bureau 
(CFPB). Throughout the report we refer to these as either federal 
financial agencies or agencies. 

[3] CFPB had until January 21, 2012, to establish its OMWI and begin 
addressing the other requirements of the act. 

[4] The race/ethnicity categories in EEOC data include White, Black, 
Hispanic, Asian, and other races. All non-White categories in EEOC 
data are considered racial/ethnic minorities in this report. 

[5] See [hyperlink, http://www.gao.gov/products/GAO-06-617] and 
[hyperlink, http://www.gao.gov/products/GAO-10-736T]. 

[6] GAO, Diversity Management: Expert-Identified Leading Practices and 
Agency Examples, [hyperlink, http://www.gao.gov/products/GAO-05-90] 
(Washington, D.C.: Jan. 14, 2005). 

[7] Pub. L. No. 111-203. § 342, 124 Stat. 1376, 1541-1544 (2010). CFPB 
had until January 21, 2012, to comply with the requirements. 

[8] Federal Reserve Act, 63 Cong. Ch. 6, 38 Stat. 251-275 (Dec. 23, 
1913). 

[9] For purposes of the act, minority means any Black American, Native 
American, Hispanic American, or Asian American. Minority-owned 
business means a business (i) more than 50 percent of the ownership or 
control of which is held by one or more minority individuals; and (ii) 
more than 50 percent of net profit and loss of which accrues to one or 
more minority individuals. Women-owned business means a business (i) 
more than 50 percent of the ownership or control of which is held by 
one or more women; (ii) more than 50 percent of the new profit or loss 
of which accrues to one or more women; and (iii) a significant 
percentage of senior management positions are held by women. 

[10] Section 342 applies to all contracts of an agency for services of 
any kind, including the services of financial institutions, investment-
banking firms, mortgage banking entities, underwriters, accountants, 
investment consultants, and providers of legal services. It also 
includes all contracts for all business and activities of an agency, 
at all levels, including contracts for the issuance or guarantee of 
any debt, equity, or security; the sale of assets; the management of 
assets of the agency; the making of equity investments by the agency; 
and the implementation of programs to address economic recovery. 

[11] EEOC compiles EEO-1 data from the reports it collects annually 
from private employers with 100% or more employees or federal 
contractors with 50 or more employees. Similar to our 2006 report, we 
obtained data from EEOC for private employers with 100% or more 
employees. Consequently, the analysis included in this report may not 
match the analysis found in EEOC's website, which would also include 
federal contractors with 50 or more employees. The financial services 
industry EEO-1 data analysis provided in this section of the report 
includes workforce information from the 12 Federal Reserve Banks, as 
they are considered part of the financial services industry. We 
provide a separate analysis of the 12 Federal Reserve Banks' workforce 
later in the report because they were also covered by the Dodd-Frank 
Act provisions. 

[12] [hyperlink, http://www.gao.gov/products/GAO-06-617]. 

[13] [hyperlink, http://www.gao.gov/products/GAO-06-617]. 

[14] We determined the CPS-estimated minority percentages of 
management positions within the financial services industry cannot be 
precisely measured. However, CPS-estimated minority percentages were 
included in this report to provide some more context. Since many of 
the percentage estimates have wide confidence intervals, we encourage 
the reader to interpret the CPS-estimated minority percentages in this 
report with caution. Please see appendix I for the estimated minority 
percentages and standard errors. 

[15] As previously discussed the nine leading diversity practices are 
(1) commitment to diversity as demonstrated and communicated by an 
organization's top leadership; (2) the inclusion of diversity 
management in an organization's strategic plan; (3) diversity linked 
to performance, making the case that a more diverse and inclusive work 
environment could help improve productivity and individual and 
organizational performance; (4) measurement of the impact of various 
aspects of a diversity program; (5) management accountability for the 
progress of diversity initiatives; (6) succession planning; (7) 
recruitment; (8) employee involvement in an organization's diversity 
management; and (9) training for management and staff about diversity 
management. See [hyperlink, http://www.gao.gov/products/GAO-05-90]. 

[16] This relates to leading practice diversity linked to performance, 
which refers to the understanding that a more diverse and inclusive 
work environment can yield greater productivity and help improve 
individuals' and organization performance, while employee involvement 
refers to the contribution of employees in driving diversity 
throughout an organization. See [hyperlink, 
http://www.gao.gov/products/GAO-05-90]. 

[17] [hyperlink, http://www.gao.gov/products/GAO-06-617] and 
[hyperlink, http://www.gao.gov/products/GAO-10-736T]. 

[18] [hyperlink, http://www.gao.gov/products/GAO-06-617]. 

[19] [hyperlink, http://www.gao.gov/products/GAO-06-617] and 
[hyperlink, http://www.gao.gov/products/GAO-10-736T]. 

[20] [hyperlink, http://www.gao.gov/products/GAO-06-617] and 
[hyperlink, http://www.gao.gov/products/GAO-10-736T]. 

[21] We refer to overall representation of students from 
undergraduate, graduate, and doctoral programs as the university 
system. These data exclude specialized graduate programs, such as 
Master of Economics. In addition, these overall percentages only 
represent enrolled students for which race/ethnicity or gender were 
indicated. 

[22] AACSB, the world's largest accreditation association for business 
schools, conducts an annual survey called "Business School 
Questionnaire" of all its member schools. Participation in this survey 
is voluntary. 

[23] Accountability refers to the means to ensure that leaders are 
responsible for diversity by aligning their performance assessment and 
compensation to the progress of diversity initiatives. See [hyperlink, 
http://www.gao.gov/products/GAO-05-90]. 

[24] Our analysis of employment data in this section of the report 
differs from how EEOC typically reports data. While EEOC reports on 
individual equal employment opportunity groups, we report on 
minorities as a group. Additional data and figures supporting this 
section of the report are in appendixes III and IV. 

[25] On July 21, 2010, the Consumer Financial Protection Act 
established CFPB as an independent bureau within the Federal Reserve 
System to be headed by a director. Effective July 21, 2011, CFPB 
assumed responsibility for certain consumer financial protection 
functions formerly the responsibilities of the Board of Governors of 
the Federal Reserve System, the Comptroller of the Currency, the 
Director of the Office of Thrift Supervision, FDIC, the Federal Trade 
Commission, NCUA, and the Secretary of the Department of Housing and 
Urban Development. 

[26] CFPB provided to us workforce diversity data for all employees, 
senior officials, and supervisors as of May 19, 2012. 

[27] Federal financial agencies provided us reports they issued 
according to EEOC Management Directive 715, known as MD-715 reports. 
This directive does not apply to the Federal Reserve Banks, as they 
are not federal agencies. Our analysis of the representation of 
minorities and women at the senior management level for agencies 
reviewed the numbers of employees the agencies reported as 
"Executive/Senior Level" from 2007 through 2011. Though the MD-715 
reports allow for this category to cover Grades 15 and above, agencies 
have discretion to decide which positions are included in this senior 
level versus those the agencies include at lower levels of management. 
Therefore, comparisons of a given management level between the 
agencies do not necessarily involve the same set of managers at each 
agency. Figures in our analysis are rounded to the nearest percent. 

[28] Percentage changes in the representation of minorities among 
senior management-level employees from 2007 through 2011 for NCUA and 
OCC were zero when rounded to the nearest percent. The representation 
of minorities among senior management-level employees was 12 percent 
at NCUA in 2007 and 2011, and at OCC, 17 percent in 2007 and 18 
percent in 2011. 

[29] CFPB identified these employees as Executive/Senior Officials. 

[30] Reserve Banks provided us reports they issued to EEOC according 
to form EEO-1. Our analysis of senior management-level representation 
for the Reserve Banks included employees the banks reported as 
"Executive/Senior Officials and Managers." Figures in our analysis are 
rounded to the nearest percent. 

[31] Among other things, the act outlines steps the specific agencies 
and Reserve Banks should take to seek workforce diversity at all 
levels of their organizations. These steps include recruiting from 
colleges serving primarily minority populations, sponsoring and 
recruiting at job fairs in urban communities, and advertising 
positions in newspapers and magazines oriented toward minorities and 
women. 

[32] SEC determined it could not use appropriated funds for the 
purpose of establishing an OMWI without first obtaining congressional 
approval. Its reprogramming request was approved by the House and 
Senate Appropriations Committees in July 2011. 

[33] As mentioned previously, on July 21, 2010, the Consumer Financial 
Protection Act of 2010 established CFPB as an independent bureau 
within the Federal Reserve System to be headed by a director. 
Effective July 21, 2011, CFPB assumed responsibility for certain 
consumer financial protection functions formerly the responsibilities 
of the Board of Governors of the Federal Reserve System, the 
Comptroller of the Currency, the Director of the Office of Thrift 
Supervision, FDIC, the Federal Trade Commission, NCUA, and the 
Secretary of the Department of Housing and Urban Development. CFPB had 
until January 21, 2012, to establish its OMWI and begin addressing the 
other requirements of the act. 

[34] Pub. L. No. 111-203. § 342(b)(2) (2010). 

[35] Exec. Order 13583 (2011). 

[36] Although this report reviews eight federal agencies, this 
requirement does not apply to Treasury Departmental Offices, as the 
agency does not have regulated entities. Additionally, the requirement 
does not directly apply to the Reserve Banks. However, the Federal 
Reserve Board has delegated some of its supervisory responsibilities 
to the Reserve Banks--such as responsibility for examining bank and 
thrift holding companies and state member banks under rules, 
regulations, and policies established by the Federal Reserve Board. 
The scope of these delegated authorities does not include section 342 
oversight of regulated entities at this time. 

[37] Pub. L. No. 110-289 § 1116, 122 Stat. 2654, 2681-2683 (2008). 
Under HERA, FHFA's regulated entities must establish an OMWI and 
develop and implement standards and procedures to ensure, to the 
maximum extent possible, the inclusion and utilization of minorities 
and women, and minority-and women-owned businesses in all business and 
activities of the regulated entity at all levels, including in 
procurement, insurance, and all types of contracts. Additionally, each 
of its regulated entities must report annually to FHFA on actions 
taken pursuant to these requirements. Further, the act requires FHFA 
to take affirmative steps to seek diversity in its workforce at all 
levels, consistent with the demographic diversity of the United States. 

[38] Minority and Women Inclusion. 12 C.F.R. § 1207.1 -24 (Dec. 28, 
2010). 

[39] Pub. L. No. 111-203. § 342(b)(4) (2010). Even though section 342 
provides for the development of standards for the assessment of 
diversity policies and practices of regulated entities, it further 
provides that nothing in the requirement may be construed to require 
any specific action based on the findings of the assessment. 

[40] 5 U.S.C. § 552. The Freedom of Information Act requires that 
federal agencies provide the public with access to government records 
and information on the basis of the principles of openness and 
accountability in government. 

[41] Pub. L. No. 111-203, § 342(e)(5) (2010). 

[42] [hyperlink, http://www.gao.gov/products/GAO-05-90]. 

[43] For purposes of the act, minority-owned business means a business 
for which more than 50 percent of the ownership is held by one or more 
minority individuals and more than 50 percent of net profit and loss 
of the business accrues to one or more minority individuals. Women-
owned business means a business for which more than 50 percent of the 
ownership is held by one or more women, more than 50 percent of the 
net profit or loss of the business accrues to one or more women, and a 
significant percentage of senior management positions are held by 
women. 

[44] The FAR is the primary regulation for use by all federal 
executive agencies in their acquisition of supplies and services with 
appropriated funds. Two federal financial agencies subject to the 
contracting provisions in section 342 of Dodd-Frank are also governed 
by the FAR because they receive appropriated funds: SEC and Treasury. 
The other agencies included in this report are not legally required to 
follow the FAR because they do not receive appropriated funds. 
However, according to CFPB, FDIC, FHFA, and OCC these agencies choose 
to adhere to part or all of this regulation. According to NCUA, it 
used the FAR as guidance when establishing its contracting procedures. 
The Federal Reserve Board described their procurement policy as 
consistent with the FAR. 

[45] As previously discussed, the Reserve Banks are not federal 
agencies. 

[46] According to one Reserve Bank, there are certain types of 
contracts from which the fair inclusion provision would be 
automatically excluded. For example, the Reserve Bank of Chicago would 
not include the provision in a new contract with a vendor that has an 
existing contract with the National Procurement Office of the Federal 
Reserve System because in that previous contract the vendor had 
already agreed to make efforts to include women and minorities in its 
workforce. 

[47] The Office of Federal Contract Compliance Programs enforces, for 
the benefit of job seekers and wage earners, the contractual promise 
of affirmative action and equal employment opportunity required of 
those who do business with the federal government. 

[48] The act does not set a standard that the federal agencies or 
Reserve Banks must meet in making contracting awards to MWOBs. 

[49] The Small Business Administration (SBA) negotiates goals with 
federal agencies for contract dollars awarded to small businesses to 
meet statutory government-wide goals. 15 U.S.C. § 664(g) sets forth a 
statutory goal for 23 percent of all aggregated federal contracting 
dollars to be awarded to small businesses. These include current goals 
for 5 percent of all prime contract and subcontract dollars to be 
awarded to small disadvantaged businesses and 5 percent of all prime 
contract and subcontract dollars to be awarded to women-owned small 
businesses. SBA also negotiates goals for the award of contract 
dollars to service-disabled veteran-owned and HUBZone small businesses. 

[49] See GAO, Government Contracts: Federal Efforts to Assist Small 
Minority Owned Businesses, [hyperlink, 
http://www.gao.gov/products/GAO-12-873] (Washington, D.C.: Sept. 28, 
2012). We analyzed data from the Federal Procurement Data System--Next 
Generation. Minority designations are self-reported, and some 
businesses are both minority-and women-owned and may be counted under 
both categories. 

[50] The NPO, housed in the Reserve Bank of Richmond, conducts 
research and negotiates, manages, and administers contracts on behalf 
of the 12 Reserve Banks, but the purchases are made by the individual 
Reserve Bank that chooses to use the contract. 

[51] The NPO, housed in the Reserve Bank of Richmond, conducts 
research and negotiates, manages, and administers contracts on behalf 
of the 12 Reserve Banks, but the purchases are made by the individual 
Reserve Bank that chooses to use the contract. 

[52] A mentor-protégé program is an arrangement in which mentors--
businesses, typically experienced prime contractors--provide 
technical, managerial, and other business development assistance to 
eligible small businesses, or protégés. Overall, mentor-protégé 
programs seek to enhance the ability of small businesses to compete 
more successfully for federal government contracts by furnishing them 
with assistance to improve their performance. See GAO, Mentor-Protégé 
Programs Have Policies that Aim to Benefit Participants but Do Not 
Require Postagreement Tracking, [hyperlink, 
http://www.gao.gov/products/GAO-11-548R] (Washington, D.C.: June 15, 
2011) and Small Business Contracting: Opportunities to Improve the 
Effectiveness of Agency and SBA Advocates and Mentor-Protégé Programs, 
[hyperlink, http://www.gao.gov/products/GAO-11-844T] (Washington, 
D.C.: Sept. 15, 2011). 

[53] Federal contractors with 50 or more employees are also required 
to submit to EEOC annual reports showing the composition of their 
workforce; however, we did not include these firms in our analysis. 
Accordingly, our EEO-1 analysis presented in this report may not match 
the EEO-1 data presented on EEOC's website. As required under the 
Civil Rights Act of 1964, EEOC collects periodic reports from public 
and private employers and unions and labor organizations that indicate 
the composition of their work forces by sex and by racial/ethnic 
category. Key among these reports is the EEO-1. 

[54] EEOC defines the job category of "officials and managers" as 
occupations requiring administrative and managerial personnel, who set 
broad policies, exercise overall responsibility for execution of these 
policies, and direct individual departments or special phases of a 
firm's operation. 

[55] In 2007, EEOC subdivided the "officials and managers' category 
into two subcategories. The first one, "Executive/Senior Level 
Officials and Managers," includes individuals who reside in the 
highest levels of organizations and plan, direct, and formulate 
policies, set strategy, and provide the overall direction of 
enterprises/organizations for the development and delivery of products 
or services, within the parameters approved by boards of directors or 
other governing bodies. The second category, "First/Mid-Level 
Officials and Managers," includes individuals who receive directions 
from Executive/Senior Level management and oversee and direct the 
delivery of products, services, or functions at group, regional, or 
divisional levels of organizations. 

[56] We used monthly averages over 3 months--July, August, and 
September--from the Basic Monthly CPS for each year and then 
calculated the estimated percentages, as EEOC's EEO-1 reports are 
collected over this period of time every year. 

[57] In our 2006 report we selected industry representatives based on 
a variety of criteria including whether they had received public 
recognition of their diversity programs or on the type of sector (such 
as securities or commercial banking) they were involved in. 
[hyperlink, http://www.gao.gov/products/GAO-06-617]. 

[58] EEOC collects a variety of data on workforce diversity from 
federal agencies, including information pursuant to a management 
directive it issued in 2003 that included policy guidelines and 
standards for establishing and maintaining affirmative employment 
programs. This directive does not apply to the Federal Reserve Banks, 
as they are not federal agencies. EEOC MD-715 (2003). 

[59] On July 21, 2010, the Consumer Financial Protection Act 
established CFPB as an independent bureau within the Federal Reserve 
System to be headed by a director. Effective July 21, 2011, CFPB 
assumed responsibility for certain consumer financial protection 
functions formerly the responsibilities of the Board of Governors of 
the Federal Reserve System, the Comptroller of the Currency, the 
Director of the Office of Thrift Supervision, FDIC, the Federal Trade 
Commission, NCUA, and the Secretary of the Department of Housing and 
Urban Development. 

[60] We obtained annual EEO-1 reports from all 12 Reserve Banks, which 
are located in Atlanta, Boston, Chicago, Cleveland, Dallas, Kansas 
City, Minneapolis, New York, Philadelphia, Richmond, San Francisco, 
and St. Louis. 

[61] These data are organized in table A3 of each MD-715 report and as 
part of the consolidated employer information reports for Reserve Bank 
EEO-1 data. For both data sets, race and ethnicity categories included 
Hispanic or Latino, White, Black or African American, Asian American, 
Native Hawaiian or Other Pacific Islander, American Indian or Alaskan 
Native, and Two or More Races. Our analysis included as an Other 
category: Native Hawaiian or Other Pacific Islander, American Indian 
or Alaskan Native, and Two or More Races. 

[62] We defined senior management-level as employees reported in the 
most senior job category by federal financial agencies and Reserve 
Banks. For agency MD-715 data, we considered senior management-level 
as officials and managers reported as "Executive/Senior Level," in 
each agency's A3 data tables. For Reserve Bank EEO-1 data, we 
considered senior management-level as "Executive/Senior Officials and 
Managers," reported by each Reserve Bank. Our analysis of agencywide 
data included all job categories reported by each agency: 
Executive/Senior Level, Mid-level, First-level, and Other Officials 
and Managers, Professionals, Technicians, Sales Workers, 
Administrative Support Workers, Craft Workers, Operatives, Laborers 
and Helpers, and Service Workers. Our analysis of bankwide data 
included all job categories reported by each Reserve Bank: 
Executive/Senior Officials and Managers, First/Mid Officials and 
Managers, Professionals, Technicians, Sales Workers, Administrative 
Support Workers, Craft Workers, Operatives, Laborers and Helpers, and 
Service Workers. 

[63] These industry sectors under the financial services industry are 
split according to the NAICS. 

[64] The agencies included FDIC, the Federal Reserve Board, NCUA, OCC, 
SEC, and Treasury. FHFA was established in 2008 and started reporting 
workforce data for 2010, and is excluded from our trend analysis. 
Additionally, CFPB was established in July 2011 and trend data were 
not available. 

[End of section] 

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