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Finance Reform Bill Includes Unexpected Employment Law Obligations

Although the media has focused on the financial reforms implemented by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act or Act), less attention has been devoted to the Acts employment-related implications for the financial services industry. Section 342 of the Act mandates diversity initiatives in the financial services industry both the involved federal agencies and at the private companies that those agencies will regulate through the Offices of Minority and Women Inclusion (Offices). The section broadly impacts diversity efforts at private financial services entities, including investment banking firms, mortgage banking firms, asset management firms, brokers, dealers, financial services entities, underwriters, accountants, investment consultants, and legal services providers. Private entities that conduct business with federal financial agencies will be under great scrutiny to ensure compliance with the Offices diversity policies. This StayCurrent bulletin provides an overview of Section 342 of the Dodd-Frank Act and identifies employment issues and considerations in implementing the Section.

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