FR2100_20230828_omb

Supporting Statement for the
Joint Standards for Assessing the Diversity Policies and Practices of
Entities Regulated by the Agencies
(FR 2100; OMB No. 7100-0368)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Joint Standards for Assessing the Diversity Policies and Practices of Entities
Regulated by the Agencies (FR 2100; OMB No. 7100-0368). Section 342 of the Dodd-Frank
Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)1 requires the Board, Office
of the Comptroller of the Currency, Federal Deposit Insurance Corporation, National Credit
Union Administration, Consumer Financial Protection Bureau, and Securities and Exchange
Commission (collectively, the agencies) each to establish an Office of Minority and Women
Inclusion (OMWI) to be responsible for all matters of the respective agency relating to diversity
in management, employment, and business activities. Section 342 requires each OMWI Director
to develop standards for “assessing the diversity policies and practices of entities regulated by
the agency.” The Interagency Policy Statement Establishing Joint Standards for Assessing the
Diversity Policies and Practices of Entities Regulated by the Agencies, published jointly by the
agencies in June 2015, contains these standards (Joint Standards).2
The Joint Standards encourage a regulated entity to be transparent about its diversity and
inclusion activities by voluntarily disclosing certain information available to the public annually
on its websites or through other appropriate communication methods, in a manner reflective of
the entity’s size and other characteristics (Transparency Standard). The Joint Standards also
encourage a regulated entity, in a manner reflective of its size and other characteristics, to
voluntarily conduct a self-assessment of its diversity policies and practices and to report
information pertaining to its self-assessment to the OMWI Director of its primary federal
financial regulator, as well as to publish information pertaining to its efforts with respect to the
Joint Standards (Self-Assessment Standard). The Board has developed a voluntary reporting
template entitled “Diversity Self-Assessment Template” for use by institutions regulated by the
Board to facilitate the provision of self-assessment information. The Transparency Standard,
Self-Assessment Standard, and reporting template comprise the FR 2100.
The Board revised the FR 2100 by adding a field identifying institutions to the reporting
template and reformatting the reporting template’s table identifying workforce numbers.
The current estimated total annual burden for the FR 2100 is 1,248 hours, and would
remain the same with the revisions. The reporting template and instructions are available on the
Board’s public website at https://www.federalreserve.gov/aboutthefed/omwi-regulated-entitiesself-assessments.htm.

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2

12 U.S.C. § 5452.
80 FR 33016 (June 10, 2015).

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Background and Justification
Section 342(b)(2)(C) of the Dodd-Frank Act requires the OMWI Director of each of the
respective agencies to develop standards for assessing the diversity policies and practices of
entities regulated by their agency. To promote consistency, the agencies worked together to
jointly develop the Joint Standards for assessing diversity policies and practices.
The Board (on its own or in conjunction with the other agencies) may use the information
provided by regulated entities to monitor progress and trends in the financial services industry
with regard to diversity and inclusion in employment and contracting activities, as well as to
identify and highlight those policies and practices that have been successful.
Description of Information Collection
The Joint Standards include a Transparency Standard, which encourages a regulated
entity to be transparent about its diversity and inclusion activities by voluntarily making certain
information available to the public annually on its websites or through other appropriate
communications methods, in a manner reflective of the entity’s size and other characteristics.
The specific information referenced in this standard is (1) the entity’s diversity and inclusion
strategic plan, (2) its policy on its commitment to diversity and inclusion, (3) its progress toward
achieving diversity and inclusion in its workforce and procurement activities (which may include
the entity’s current workforce and supplier diversity demographic profiles), and (4) opportunities
available at the entity that promote diversity (e.g., current employment and procurement
opportunities; forecasts of potential employment and procurement opportunities; and the
availability of mentorship and developmental programs for employees and contractors). The
individual entity would determine the type and extent of information that demonstrates its
progress toward achieving diversity and inclusion. The disclosure of information associated with
the Transparency Standard is voluntary and no specific information is required to be disclosed to
the public by the agencies.
In addition, the Joint Standards include a Self-Assessment Standard, which encourages a
regulated entity, in a manner reflective of its size and other characteristics, to voluntarily
(1) conduct an annual self-assessment of its diversity policies and practices, (2) monitor and
evaluate its performance under its diversity policies and practices on an ongoing basis,
(3) provide information pertaining to its self-assessment to the OMWI Director of its primary
federal financial regulator, and (4) publish information pertaining to its efforts with respect to the
Joint Standards.
In 2016, in collaboration with the agencies, the Board supplied a reporting template that
Board-regulated entities could opt to use to assist with reporting information to address the
“Entities’ Self-Assessment” standard. The reporting template (1) asks for general information
about a respondent, (2) includes a checklist of the Joint Standards, (3) seeks additional diversity
data, and (4) provides an opportunity for a respondent to provide other information regarding or
comment on the self-assessment of its diversity policies and practices. The Board added this

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reporting template to the voluntary information collections associated with the Joint Standards
previously approved by OMB,3 and the use of it is voluntary.
Respondent Panel
The FR 2100 panel comprises all financial institutions for which the Federal Reserve is
the primary federal financial regulator.
Frequency and Time Schedule
The FR 2100 is submitted annually. The Board encourages its regulated institutions to
provide their diversity policies and practices, as well as information related to their selfassessments, to the Board and disclose such information to the public on an annual basis. Selfassessments should be submitted within 90 days of the close of the calendar year.
Revisions to the FR 2100
The Board updated the Diversity Self-Assessment Template by adding a Research,
Statistics, Supervision and Regulation, and Discount and Credit Database (RSSD) number field
to identify regulated entities and improve the efficiency of data collections. The Board also
reformatted the Workforce Profile and Employment Practices section of the template to make
clarifications. Changes include the separation of managers in the workforce count from
Executive/Senior Level Officials.
Public Availability of Data
The Board may publish information disclosed to it, such as best practices, in any form
that does not identify a particular entity or individual or disclose confidential business
information. Entities are encouraged to disclose their diversity policies and practices, as well as
information related to their self-assessments, to the public. The Boards OMWI also publishes the
summary data in its annual report to Congress.
Legal Status
The FR 2100 is authorized pursuant to section 342 of the Dodd-Frank Act (12 U.S.C. §
5452).4 The FR 2100 is voluntary.
The Transparency Standard and portions of the Self-Assessment Standard encourage
regulated entities to provide diversity information to the public. Information provided in this
fashion is not confidential. A regulated entity may request confidential treatment for selfassessment material provided to the Board in accordance with the Board’s Rules Regarding
Availability of Information.5 Requests for confidential treatment of information are reviewed on
3

See 81 FR 66275, 66276 (September 27, 2016); 81 FR 89463, 89464 (December 12, 2016).
Requiring the Board’s OMWI Director to develop standards for assessing regulated entities’ diversity policies and
practices.
5
12 CFR 261.17.
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a case-by-case basis. Information provided under the FR 2100 may be nonpublic commercial or
financial information that is both customarily and actually treated as private by the respondent,
which is protected from disclosure pursuant to exemption 4 of the Freedom of Information Act
(FOIA) (5 U.S.C. § 552(b)(4)). Information provided under the FR 2100 may also contain
personnel and medical files the disclosure of which would constitute a clearly unwarranted
invasion of personal privacy, which are protected under exemption 6 of the FOIA (5 U.S.C. §
552(b)(6)).
Consultation Outside the Agency
The Board consulted with the agencies regarding the revisions to the reporting template.
Public Comments
On March 30, 2023, the Board published an initial notice in the Federal Register (88 FR
19146) requesting public comment for 60 days on the extension, with revision, of the FR 2100.
The comment period for this notice expired on May 30, 2023. The Board did not receive any
comments. The Board adopted the extension, with revision, of the FR 2100 as originally
proposed. On July 19, 2023, the Board published a final notice in the Federal Register (88 FR
46165).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2100 is 1,248
hours, and would remain unchanged with the revisions. The number of respondents is based on
the average number of FR 2100 reports received in the past two years. The FR 2100 includes a
disclosure provision for respondent institutions. These reporting and disclosure provisions
represent less than 1 percent of the Board’s total paperwork burden.
Estimated
number of
respondents6
156
156

FR 2100
Reporting
Disclosure
Total

Estimated
annual
frequency
1
1

Estimated
Estimated
average hours annual burden
per response
hours
7
1,092
1
156
1,248

The estimated total annual cost to the public for the FR 2100 is $82,680.7
6

Of these respondents, 151 respondents are considered small entities as defined by the Small Business
Administration (i.e., entities with less than $850 million in total assets). Size standards effective March 17, 2023.
See https://www.sba.gov/document/support-table-size-standards. There are no special accommodations given to
mitigate the burden on small institutions.
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Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $22, 45% Financial Managers at
$80, 15% Lawyers at $79, and 10% Chief Executives at $118). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment and Wages,
May 2022, published April 25, 2023, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

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Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
information collection is negligible.

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