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  • Comment Detail

  • Date: 12/27/16
    First Name: William R. "Billy"
    Last Name: Martin
    Organization: Miles and Stockbridge, P.C.
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA78

  • Comment

    The promotion of diversity and inclusion in the marketplace is integral to the success of any business. FHFA’s proposed amendment to include a definition of “Diversity spend with non-diverse-owned businesses” (Section 1207.1), will aid in expanding the reach of diversity and inclusion efforts from both within regulated entities and outside to those Firms/businesses who commit to the policy of diversion and inclusion.

    The initiative of diversity and inclusion should extend beyond minority-, women-, and disabled-owned businesses and should include business organizations where minority, women, and disabled individuals are employed and will be the attorney or person handling the work on behalf of the regulated industry and more importantly, expand the opportunity for minority, women, or disabled persons to become the relationship partner between the Firm and the regulated entity. As a relationship partner, that attorney with the support of the law firm now is responsible for performing the work and staffing as its billing attorney. In mid to large size law firms throughout the country, minority, women, and disabled attorneys strive to engage in relationships with regulated entities to provide sound legal representation. The regulated entities get the benefit, experience and expertise of an established law firm, while also providing opportunities to minority, women, and disabled attorneys who compete in the marketplace to represent these regulated entities. This type of amendment will in effect provide more of an incentive for law firms by providing firms with increased incentive to hire, promote, and utilize minority, women, and disabled individuals consistent with the objective of this proposed amendment.

    Additionally, in order to create a culture that fosters the promotion of diversity and inclusion the “tone at the top” must match the initiatives of the organization. We support the proposed amendment that would revise and clarify §1207.20(b) and (c), and state that a regulated entity’s board of directors or management is ultimately responsible for achieving the requirements of these regulations. As such the leadership of the regulated entities should place the offices or departments tasked with the responsibility of carrying out the regulations in the best possible position to fulfill those duties. In order to run any effective program individuals committed to and qualified in the area of diversity and inclusion must be utilized and firm direction must be given to ensure that the culture and mindset at the regulated entities, as well as those at law firms support the goals of promoting diversity and inclusion.