Affirmative Action Plans

We have developed a system to cost-effectively prepare and update bank affirmative action plans. We use bank specific language reflecting the most recent changes to OFCCP regulations. We also use an automated statistical analysis to reduce the burden of data collection by the bank. You will receive Plans for Women and Minorities, Covered Veterans and Individuals with Disabilities, ready for signature.

Overtime Exemption ToolkitTM

We have developed a compliance package to assist banks evaluate application of the DOL overtime exemption tests to positions within their organizations. Given significant liability in this area, bankers asked for specific self-audit tools which we have developed in this comprehensive Toolkit.

Compensation Equity Statistical Analysis

Over the past several years, state legislators have begun to significantly expand what is expected under their state “Equal Pay Acts”. The laws require equal pay for individuals performing “substantially similar work”. The OFCCP has also released guidance recently outlining federal enforcement activity. In it’s August 24, 2018 Directive, the agency states how compensation will be analyzed among employees in a “Pay Analysis Grouping”. This approach will also involve a combination of job titles. In light of these new standards, we provide statistical analyses comparing compensation based upon gender and race for bank employees performing substantially similar work.

Diversity Self-Assessment and Reporting Program

The federal banking regulators (CFPB, FDIC, Federal Reserve Board, NCUA, OCC, and SEC) issued a Policy Statement on June 9, 2015 establishing standards for assessing diversity policies and practices within financial institutions. This directive was required by a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act. To address this new burden, we have developed a Program to provide financial institutions the material and telephone guidance necessary to complete annual Self-Assessment Reports.