The federal banking agencies, along with the NCUA, CFPB, and SEC, have proposed the manner in which they will enforce the women-and-minority diversity standards mandated by the Dodd-Frank Act. The requirements will, they say, be assessed taking into account the individual characteristics of institutions and the communities they serve and assessments will not be formal supervisory matters. The agencies expect that the new standards will increase transparency, but the proposal does not make clear the extent to which their assessments will be made public. However, any additional transparency suggested could still create significant legal and reputational risk for covered institutions, as well as complicate employee relations. To the extent they promote diversity, though, they may enhance decision-making with regard to under-served communities and increase awareness of new profit opportunities, risk-management concerns, and other matters.
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