The Dodd-Frank Wall Street Reform and Consumer Protection Act of 20101 (“Dodd-Frank Act” or “Act”) authorizes certain federal agencies to assess the “diversity policies and practices of the entities they regulate.”2 On June 10, 2015, six federal agencies (“agencies”) issued a joint policy statement establishing standards for assessing those policies and diversity practices.3 While the policy statement provides a useful framework for identifying important components of an effective diversity and inclusion effort aimed at expanding employment and contracting opportunities for women and minorities and evaluating such progress, the analysis involves a voluntary compliance scheme that does not require employers to implement these standards.
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