In late March 2014, Democrats of the U.S. House of Representative’s Committee on Financial Services requested that Inspectors General (IG) of the federal financial regulatory agencies provide a report about workplace discrimination occurring at each applicable agency. In addition, the letter from the committee Democrats requested a review of the role of the Offices of Minority and Women Inclusion (OMWI) at each federal financial regulatory agency.
The request followed an early March 2014 article in the trade magazine American Banker, in which it was reported that the Bureau of Consumer Financial Protection (CFPB) had racial disparities in the execution of its staff performance evaluation program.
The table below presents the responses from the various IGs to the congressional request.
|Federal Financial Agency||Report Number||Internet Link||Comment|
|Consumer Financial Protection Bureau||Audit report 2015-MO-C-002||http://oig.federalreserve.gov/reports/cfpb-diversity-inclusion-mar2015.pdf||American Banker article about racial disparities of CFPB staff evaluations.|
|Department of the Treasury, Office of the Comptroller of the Currency||OIG-15-017||http://www.treasury.gov/about/organizational-structure/ig/Audit%20Reports%20and%20Testimonies/OIG-15-017.pdf|
|Federal Deposit Insurance Corporation||Eval-15-001||http://www.fdicoig.gov/reports15/15-001EV.pdf|
|Federal Housing Finance Agency||EVL-2015-003||http://fhfaoig.gov/Content/Files/EVL-2015-003.pdf|
|Federal Reserve Board||Audit report 2015-MO-B-006||http://oig.federalreserve.gov/reports/board-diversity-inclusion-mar2015.pdf||What is left out of the report is significant: Artis v. Bernanke (now Yellen). Also 12 U.S.C. 244 needs Congressional attention to ensure that Title 5 of the U.S. Code applies to the Board; the Board’s record-keeping on, and reporting of, its internal management is lax.|
|National Credit Union Administration||OIG-14-09||http://www.ncua.gov/about/Leadership/CO/OIG/Documents/OIG201409EqualOpportunityDiversity.pdf||Click for blog post on this report|
|Securities and Exchange Commission||528||http://www.sec.gov/oig/reportspubs/528.pdf||Report is thorough, thoughtful, and well done.|
[Note: As of the initial date of this post (January 26, 2015), the IG for the Federal Reserve Board (FRB) and the Bureau of Consumer Financial Protection (CFPB) has not submitted reports. According to the FRB and CFPB IG work plan, these reports are due in in the first quarter of 2015. (Update: CFPB information added March 9, 2015; blog author added a post about the CFPB audit on March 18, 2015. Federal Reserve Board information added April 6, 2015; blog author added a post about the Board audit on April 13, 2015.)]
The reports vary in investigatory vigor; this variance is disappointing–all reports on this matter must have an equally high amount of investigatory diligence. The Security and Exchange Commission’s IG was the only one that evaluated the responses from the agency and seeks to obtain substantive responses for areas in which the agency sought further time to provide a response.
Other IGs, for example, the IG for the Office of the Comptroller of the Currency, seemed to simply collect information and report what text was received. The IG for the National Credit Union Administration (NCUA) mentioned the activity of the NCUA’s performance evaluation program (pay-for-performance style) but did not probe further to investigate how the performance evaluation worked and review it for compliance with equal opportunity laws and regulations, including the federal merit principles.