Good Faith Effort Procedures
OMWI carries out the good faith effort review in collaboration with ASB and Legal. The review procedures assess a contractor's performance in complying Dodd-Frank Act 342(c)(2). Contractors are selected for review by OMWI using neutral factors, such as, total contract value, type, expiration date, or total expenditure amount. Upon written request from the Contracting Officer the contractor must provide support documentation, satisfactory to FDIC, of their actions intended to identify and, if present, remove barriers to minority and women employment or expansion of employment opportunities for minorities and women within its workforce. The documentation is to be provided within ten business days of the written request.
Actions that demonstrate good faith efforts may include, but are not limited to:
Policies concerning the inclusion of minorities and women in the workforce.
Assessing the utilization of minorities and women in the workforce.
Plan, programs and or initiatives intended to mitigate obstacles or challenges to the employment of minorities and women in the workforce.
Disseminate job opportunities to ensure a diverse pool of qualified candidates have an equitable opportunity to learn about and apply for the position.
Outreach to minority-majority universities and colleges, professional and trade organizations, and diverse communities to expand talent pipeline.
Programs and or initiatives intended to promote an inclusive work environment where the contributions of all employees are valued.
OMWI reviews all the information provided to determine whether the support demonstrates actions taken by the contractor to assess, identify and mitigate barriers to the employment of minorities and women. Federal contractors may leverage existing plans or other information prepared to satisfy equal employment opportunity statutes, legislation or executive orders. OMWI will follow up directly with the contractor to request any clarification.
FDIC is committed to work collaboratively with our contractors on determining the availability of GFE support information. However, if after technical assistance from OMWI the contractor is unable to provide satisfactory GFE support, then contractor will be asked to provide FDIC with a plan for making a good faith effort during the remainder of the contract period. Any questions that pertain to the review procedures should be directed to the OMWI at Good Faith Effort mailbox or Claire Lam, Diversity and Business Inclusion Branch.