Subject: File No. S7-08-13
From: Aaron Palmer

January 27, 2014

I understand that six federal financial regulatory agencies the Securities and Exchange Commission, the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency issued a Proposed Interagency Policy Statement to present joint standards and a model assessment approach for assessing the diversity policies and practices of entities regulated by the agencies.
As mandated by Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the OMWI Director must develop standards for assessing the diversity policies and practices of entities regulated by the agency. The proposed joint standards and the model assessment approach presented in the Proposed Interagency Policy Statement are intended to promote the transparency and awareness of, and provide guidance for assessing, the diversity policies and practices of the entities regulated by the agencies.
I applaud the OCC, Board, FDIC, NCUA, CFPB, and SEC (each an Agency and collectively, the Agencies) for proposing joint standards for assessing the diversity policies and practices of the entities they regulate.
I believe these standards are critical. It is important that the Agencies aggressively pursue their legally mandated responsibility to promote the transparency and awareness of, and provide guidance for assessing, the diversity policies and practices of the entities they regulate.
I suggest the Agencies work with experts in the field to get input from organizations that work to develop and grow Black enterprises.
Given increasing global competitiveness, it is in the national interest to foster business innovation and breakthroughs from every sector of the population. This includes fostering the survival, prosperity, and growth of minority-owned businesses.
The diversity standards that the Agencies are responsible for creating will insure that economic rights, relating to the ability for any qualified man/woman to obtain and secure business opportunities, are protected. The proposed diversity standards play a critical role in ensuring that minority and women businesses are treated fairly.