July 29, 2021

To: The Chief Executive Officers or the Equivalents of New York State Regulated Banking Institutions  and Regulated Non-Depository Financial Institutions *

Re: Diversity, Equity and Inclusion and Corporate Governance

As Superintendent of the New York State Department of Financial Services, I have regularly and consistently emphasized the value of diverse perspectives in the decision making and problem-solving process. There is clear data showing that diverse teams perform better, are more innovative and more effectively manage risk. Since becoming Superintendent, I have made the diversity of my leadership team a top priority, and deepened our commitment to diversity, equity and inclusion (DEI) by establishing the agency’s first employee affinity groups, along with a new Statewide Office of Financial Inclusion and Empowerment headed by Tremaine Wright, to meet the needs of low-and middle-income New Yorkers across the state. In addition, in the fall of 2019, the New York State Council on Women and Girls created the Committee for the Advancement of Women in Leadership in Financial Services, which I co-chair, focused on improving the representation and advancement of women, including women of color in financial services.

As Regulated Banking Institutions and Regulated Non-Depository Financial Institutions move through the 21st century, many challenges and opportunities lie ahead. Already there are several forces at work impacting financial services institutions, including the prevalence of digital technology, increasing customer demands and expectations, and decreasing brand loyalty. Without the ability to innovate and address these challenges, and those that are yet to come, the risks posed to the safety and soundness of the industry have the potential to be highly disruptive. Regulators and industry groups are increasingly taking steps to develop ideas to address these challenges, including: New York Bankers Association‘s (NYBA’s) Virtual Speaker Series, which featured a panel discussion on Diversity, Equity and Inclusion¹, and the Conference of State Bank Supervisors (CSBS) 2021 CSBS Community Bank Case Study Competition,  which brought together fifty-three student teams from thirty-nine colleges and universities and partnered them with local community banks to examine how those institutions have fared through the COVID-19 pandemic and what they are doing with regard to diversity and inclusion.²

DFS has broad statutory authority to ensure the stability of New York’s Regulated Banking Institutions and Regulated Non-Depository Financial Institutions to protect the public interest, the interests of depositors, creditors and consumers, and to promote the growth of the industry and to request special reports. Under Banking Law §37(3) the Superintendent may require any banking organization to make special reports to her at such times as she may prescribe.

The COVID-19 pandemic challenged individuals, institutions, and communities across the world in unprecedented ways, consistently reminding us of the costs, both human and financial, of failing to address systemic risks. Convergent crises -- the pandemic, associated economic downturn, racial unrest, and climate change -- have brought about broad changes in our everyday lives, our economy, and our society. The phrase “new normal” has woven its way into the modern lexicon, as government and business leaders prepare to adapt to life after the pandemic. To operate in this “new normal”, institutions must develop innovative solutions to address complex and evolving risks and identify new avenues of growth. Corporate governance, including capable leadership teams which reflect a diversity of skills, experience, and perspectives, is even more important during periods of great change. With great change comes great opportunity, and DFS stands ready to unite the public and private sectors to work together to reimagine, rebuild and renew.

We commend the actions already taken and the commitments that have been made by many Regulated Banking Institutions and Regulated Non-Depository Financial Institutions 3 to increase the representation of people of color, women and other underrepresented groups on their boards, in their management, and in their workforce generally. We also praise the efforts of trade groups and organizations like CSBS, the American Bankers Association (ABA)3 and the NYBA⁴.

While the public statements from Regulated Banking Institutions and Regulated Non-Depository Financial Institutions in support of DEI initiatives are significant and necessary, it is time to act on those words and make good on good intentions to begin to achieve real change. This industry letter is aimed at supporting existing DEI efforts while outlining DFS’s expectation that New York-regulated financial institutions make the diversity of their leadership a business priority and a fundamental component of their corporate governance.

Diversity as a Business Priority

Diversity is good for an institution’s bottom line, and the data shows it.

Increased Profitability

A 2020 McKinsey report tracking the trajectories of hundreds of companies since 2014 detailed the impacts of diversity on profitability. Companies in the top quartile for gender diversity within their executive teams were 25% more likely to achieve above average profitability than those in the fourth quartile, an increase of 10% from 2014.⁵  The case for ethnic and racial diversity is equally compelling, with companies in the top quartile for ethnic and cultural diversity outperforming those in the fourth by 36%, an increase from 33% in 2017.⁶  Further, the higher the representation of women and people of color, the higher the likelihood of outperformance.⁷ A Wall Street Journal analysis of S&P 500 companies based on diversity and inclusion performance, including the share of women in leadership roles, the presence of diversity and inclusion programs, and board demographics, found that the highest ranking companies achieved a higher operating profit margin relative to their lower performing counterparts.⁸ According to a McKinsey analysis of 366 public companies across varied industries and countries, including the United States, companies in the top quartile for racial and ethnic diversity are 35% more likely to have financial returns above their national industry medians.⁹

Broader Customer Base

Effective DEI programs can improve overall results for an organization, and central to enhancing performance is the ability to better connect with a more diverse customer base.¹⁰ As the population becomes more diverse, banks and financial services firms stand to benefit from having a workforce that better reflects the communities they serve. The Census Bureau projects that between 2016 and 2060, the percentage of non-Hispanic white Americans will decrease by 19 million people, from 61% of the population down to 44.3%. In that same time span the population of Black, Asian and Hispanic Americans is projected to increase from 13.3% to 15%, 5.7% to 9.1% and 17.8% to 27.5%, respectively.¹¹ With regard to gender diversity, it is estimated that financial services firms are missing out on at least $700 billion in revenue opportunities each year by not fully meeting the needs of women customers.¹² This is significant, considering that two-thirds of global household spending is controlled by women, 40% of global wealth is now held by women and 40% of entrepreneurs across the globe are women.¹³ These numbers are expected to increase in the coming years, representing a significant growth opportunity.

More Innovation

Many challenges and opportunities to innovate await the banking and financial services industries, particularly in the wake of COVID-19 which may ultimately lead to permanent shifts in customer expectations. As companies move through the twenty first century the ability to innovate will be a key to growth and success. When companies establish inclusive business cultures and policies, they are more likely to report increases in creativity, innovation and openness and better assessments of consumer interests and demands.¹⁴.  Companies that adapt and innovate enjoy a distinct advantage over their competitors, with research showing that over a three year period, companies with greater management diversity earned 38% more on their revenues, on average, from innovative products and services than their less diverse competitors. A 2018 Boston Consulting Group study of employees at more than 1,700 companies in eight countries identified a “strong and statistically significant correlation between the diversity of management teams and overall innovation.”¹⁵ That same analysis also found that companies that reported above average diversity on their management teams also reported innovation revenue that was 19 % higher than companies with below average leadership diversity.¹⁶ Diverse backgrounds and experiences lead to different viewpoints and opinions on complex issues, thereby leading to a plurality of solutions. This type of innovative and creative environment will better position banks and financial services firms to address the challenges ahead and continue to grow and strengthen their operations.

Better Risk Management

Credit, market, and liquidity risks constitute some of the biggest risks for banking and other financial service providers¹⁷. Overexposure in a category that is prone to large losses, lack of liquidity or overly aggressive capital market sales and trading has significant potential negative consequences for an institution, its clients, and the consumer. To that point, studies have shown that diverse teams process information more carefully, are more likely to remain objective and consistently reexamine facts, encourage greater scrutiny of the actions of others and become more aware of entrenched ways of thinking which may otherwise lead to errors in the decision making process.¹⁸ Additionally, research has shown that gender diverse corporate boards are more likely to make efficient investments and avoid risky overinvestments.¹⁹ Further, female board representation has been found to lead to better investment policies, acquisition decisions, and overall firm performance, by balancing CEO overconfidence.²⁰ Overall, studies show that female board representation improves strategic decision making and improves the overall performance of a firm.²¹

Larger Talent Pool and More Satisfied Employees

Diverse work environments are likely to increase employee job satisfaction and commitment to their employer, and are associated with reduced instances of interpersonal aggression and discrimination.²²  Further, companies with higher levels of gender diversity who also have HR policies and practices which focus on gender diversity are linked to lower levels of employee turnover.²³  

One of the opportunities presented by the upheaval associated with the COVID-19 pandemic has been the forced shift to remote work for considerable segments of the workforce. This has prompted many organizations to rethink how they view remote work, with 93% of companies surveyed by McKinsey saying that more jobs can be performed remotely than these companies had estimated pre-pandemic.²⁴ The increasing prevalence of remote work opportunities presents companies with the opportunity to reach a larger and more diverse talent pool, with 70% of companies in that same survey reporting that they believed the shift to remote work will allow them to increase diversity in their hiring.²⁵

Diversity in the Financial Services Industry

Available research on the diversity of boards and senior management in the financial services industry shows that despite the many admirable efforts undertaken and commitments made by the industry to this point, there is still much work to be done to increase diversity.

The Committee for Better Banks issued a report in March of 2021 which examined issues related to race in the workplace at some of the largest US retail banks.²⁶  Their review found that minority employees are broadly underrepresented in the finance/insurance industry generally, and are overrepresented in lower employment levels compared to their white peers.²⁷ Further, the report found that Black and Latino employees had a less than 25% chance of being promoted or hired for a senior management/executive position compared to their white peers.²⁸

In 2019, the House Financial Services Committee conducted an analysis of bank diversity data and found that among banks reporting demographic information, females made up less than one-third of their executive and senior level workforce ²⁹ despite representing 51% of the US population. ³⁰ The report also found that bank boards were 11% Black, 5% Latino and 3% Asian; in contrast these groups comprise 13%, 18.5% and 6% of the US population, respectively. ³¹

Female participation in the cryptocurrency community is very low.  The percentage of women in the sector, including developers, investors, and interested individuals, usually hovers between 4% and 6%. Data from 2020 shows that Bitcoin community engagement by gender reached 86% male and 14% female, representing a small upturn in female representation.³² Of the 378 venture-backed cryptocurrency and Blockchain companies founded around the world between 2012 and 2018, 92% had a founding team that was entirely male. By comparison, 82% of all technology companies started in that period had all male founders.³³   Additionally, a report from Forbes detailing the richest people in cryptocurrency included 19 people, all of whom were white or East Asian men.³⁴

A recent McKinsey report noted that as of 2018 the proportion of people of color in financial services drops 75% from entry-level positions to the C-suite. Specifically, Black, Hispanic, and Asian employees occupied 10%, 9% and 17% of entry level roles, but only 3%, 2% and 6% of C-suite positions, respectively. ³⁵ A 2018 study of 71 banks across 20 countries found that while women comprised an average of 52% of the banking industry’s workforce, they faced a “double glass ceiling” when moving up the organizational hierarchy; with the first ceiling falling at the middle management level and the second manifesting at the executive level.³⁶ Of the banks surveyed, only 38% of middle managers were female, and 16.5% of executive management was female.³⁷

Investor and Government Actions

Increasingly, investors and governments are taking action to advance diversity in senior management and the board room.

Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 which required all covered agencies, including federal financial services regulators, to create an Office of Minority and Women Inclusion (OMWI) which is responsible for all agency matters related to diversity in management, employment and business activities.³⁸ Each OMWI was then directed to develop standards to assess diversity policies and practices of their regulated entities and report to Congress annually on its own progress on diversity and inclusion, along with the data it received from its regulated entities.³⁹

In 2015, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), Consumer Financial Protection Bureau (CFPB), and Securities and Exchange Commission (SEC) issued their final interagency policy statement which established joint standards for assessing the diversity policies and practices of their regulated entities.⁴⁰ This action, which was required by the Dodd-Frank Act, provided a framework for regulated entities to create and strengthen their diversity policies and practices, including their organizational commitment to diversity, workforce and employment practices, procurement, business practices and transparency around organizational diversity and inclusion within their US operations.⁴¹

Early last year, the House Committee on Financial Services held a hearing on diversity and inclusion at America’s largest banks ⁴², including a review of a report issued by the Committee titled Diversity and Inclusion: Holding America’s Largest Banks Accountable.⁴³ During the hearing, the committee noted the lack of board and senior management diversity and recommended that Congress consider taking legislative action to improve diversity and inclusion in banking institutions, including the disclosure of diversity data to regulators and the public and publicly disclosing their board diversity.⁴⁴ California has enacted legislation requiring publicly held corporations whose principal offices are located in California to have at least one woman on their board by the end of 2019 ⁴⁵, and at least one director who is racially, ethnically or otherwise diverse by the end of 2021.⁴⁶

The Biden Administration has made its commitment to diversity clear. Allison Herren Lee, as Acting SEC Chair, suggested that the agency should strengthen its guidance on board diversity and revisit disclosure requirements for public companies;⁴⁷ and it has been reported that SEC Chair Gary Gensler may be in favor of corporate disclosures regarding boardroom diversity.⁴⁸

Outside of the US, European nations including Belgium, France, Italy and Norway enacted statutory gender quotas with strict non-compliance penalties years ago, aimed at increasing the representation of women in the senior leadership of their largest publicly held companies.^49< In 2020, Canada began requiring corporations governed by the Canada Business Corporations Act with publicly-traded securities to disclose information to their shareholders on the diversity of their boards and senior management teams.⁵⁰ The Central Bank of Ireland articulated ways in which it could use its supervisory authority to address diversity in the boardroom and in senior management, including assessing whether a firm is actively promoting diversity and inclusion throughout its organization and reviewing governance codes and requirements to clearly community expectations regarding diversity policies.⁵¹

Given the business case for diversity, equity and inclusion, investors both at home and abroad have begun to leverage their influence to promote DEI efforts.

In 2017, State Street Global Advisors announced that it will vote against the chair of a board’s nominating and/or governance committee if a company fails to take action to increase the number of women on its board⁵² and reaffirmed that commitment in 2020, again stating they are prepared to use their proxy voting authority to hold organizations accountable for meeting their expectations related to diversity, equity, and inclusion.⁵³

Similarly in 2017, BlackRock voted against board members at five companies who sat on nominating committees but failed to respond to investors’ concerns surrounding diversity.⁵⁴ In 2020, BlackRock again articulated that they will use their voting power to help drive increased boardroom diversity.⁵⁵ Vanguard has announced it will advocate for increased diversity on boards, and will review the progress companies make on increasing diversity on their boards through their voting activities; specifically noting that progress on diversity will inform their voting calculation in the years to come.⁵⁶

Internationally, Legal & General Investment Management (LGIM), the largest fund manager in the United Kingdom, informed S&P 500 companies in the US in late 2020 that it expects their boardrooms to include at least one Black, Asian or other ethnic minority by January 2022 and will vote against the re-election of board/nomination committee chairs who fail to meet this target.⁵⁷ Moreover, Goldman Sachs announced in February of 2020 that the firm will only underwrite the IPOs of private companies in the US and Europe who have at least one diverse board member, with that target increasing to two diverse board members by the end of 2021.⁵⁸

DFS Expectations for New York Regulated Banking Institutions and Regulated Non-Depository Financial Institutions

Considering the reasons detailed in this industry letter, DFS expects Regulated Banking Institutions and Regulated Non-Depository Financial Institutions to make the diversity of their leadership a business priority and integrate it into their corporate governance. Regulated Banking Institutions and Regulated Non-Depository Financial Institutions should also pay close attention to their talent pipeline of future diverse leaders, in addition to the diversity of their affiliates. The greater the diversity an organization has within its talent pipeline, the better positioned it will be to diversify its senior management and boards. All such regulated institutions should view diversity like other strategic priorities, including communicating its importance to all stakeholders, providing a plan for how it will be achieved and explaining that plan, setting measurable goals and tracking progress toward those goals.

DFS has reviewed and evaluated several regulatory approaches to advance DEI in the banking and financial services industry, including imposing quotas and the aggregation and disclosure of diversity data on a firm by firm basis. DFS has also engaged in numerous informal conversations with financial institutions, trade groups and DEI experts to ascertain the industry’s commitment to increasing its diversity, along with the challenges faced by financial institutions in their efforts to realize their commitments. I would like to acknowledge the contributions of the members of New York State’s Committee for the Advancement of Women in Leadership in Financial Services for their insightful and valuable input through this process.

After conducting in depth research and engaging in conversations with stakeholders, we have determined that the best way for DFS to support Regulated Banking Institutions and Regulated Non-Depository Financial Institutions’ DEI efforts is by collecting and publishing data related to the diversity of corporate boards and management. In order to set goals and measure progress, data collection is key. Making this information public will allow firms to assess where they stand relative to their peers, and it is our hope, raise the bar for the entire industry. Transparency and accountability are driving forces for change.

Successful diversity, equity and inclusion programs are a process of continual improvement, not a destination where the correct number of boxes have been checked. This requires commitment from every level of the organization to be successful, starting at the top. Firms should aim to have a board and management team that benefit from a wide diversity of skills, experiences, and perspectives, including those based on gender, race or ethnicity; not simply aim to have one or two diverse board members. To be clear, one or two diverse board members is better than none, but that is insufficient, particularly for a large board, and is not the goal. DFS understands that not every institution is starting from the same place in terms of the diversity of their workforce and leadership. Each company should conduct a self-assessment on where it stands, where it wants to go, and develop a plan on how to get there, taking into consideration its size and other relevant factors, with a focus on improvement over time.

To start, DFS will be sending out a survey to collect data regarding the gender, racial and ethnic makeup of New York Regulated Banking Institutions and Regulated Non-Depository Financial Institution’s boards or equivalent and management as of December 31, 2019 and 2020, including information about board tenure and key board and senior management roles, from all Regulated Banking Institutions with more than $100 million in assets, and all Regulated Non-Depository Financial Institutions with more than $100 million in gross revenue and from all entities authorized to engage in virtual currency business activity, including virtual currency licensees (“BitLicensees”) and virtual currency trust companies.

We plan to collect this data over the late summer and publish the results on an aggregate basis in the first quarter of 2022, categorized by the type of institution and other relevant factors We strongly encourage companies to publicly disclose the composition and diversity of their boards and management as a constituent part of their DEI commitment to their stakeholders. DFS will consider collecting and disclosing similar information in the future, including on a more granular basis, considering any other data collection and disclosure requirements that may be imposed on the banking and financial services industry.

Conclusion

Further diversifying the leadership and workforce of the banking and financial services industry is a business and corporate governance imperative which will strengthen the industry, increase innovation, and provide resiliency. This process is one of continual evolution and improvement, not simply an exercise in box checking, and small changes now will lead to big improvements in the future. We applaud the companies who have already taken meaningful steps to promote diversity within their organization, and we look forward to supporting those who are embarking on this work for the first time now.  In response to feedback from industry participants, DFS will organize a webinar focused on DEI best practices and addressing specific issues that companies have encountered in their diversity efforts.

Please direct questions regarding this industry letter to [email protected].

Sincerely,

Linda A. Lacewell

Superintendent of Financial Services

^[*] This letter is addressed to New York State banking institutions, including New York chartered banks, credit unions and New York licensed branches and agencies of foreign banking organizations (collectively “Regulated Banking Institutions”), as well as New York regulated mortgage banks, mortgage servicers, mortgage brokers, money transmitters, check cashers, licensed lenders, sales finance companies, premium finance agencies, limited purpose trust companies and virtual currency companies (collectively, “Regulated Non-Depository Financial Institutions”).  We note that DFS has issued a similar letter to all New York State domestic and foreign insurance companies dated March 16, 2021.

References:

^[1] New York Bankers Association, (2020), History in Real Time Virtual Speaker Series, Retrieved from: NYBA.com

^[2] Conference of State Bank Supervisors, (March 2021), 53 Teams Enter CSBS Community Bank Case Study Competition, Retrieved from: CSBS.org

^[3] American Bankers Association, (2021), Diversity, Equity & Inclusion, Retrieved from: Aba.com

^[4] New York Bankers Association, (October, 2019), Women in Leadership Conference, Retrieved from: NYBA.com

^[5] Dixon-Fyle, S, Dolan, K, Hunt, V, Prince, S, (May 2020), Diversity wins: How inclusion matters, Retrieved from: McKinsey.com

^[6] Ibid

^[7] Ibid

^[8] Catalyst. (June 24, 2020). Why Diversity and Inclusion Matter: Financial Performance (Appendix), Retrieved from: Catalyst.org

^[9] Hunt, V., Layton, D., and Prince, S. (January 2015), Why diversity matters, Retrieved from: McKinsey.com

^[10] Rogish A., Sandler, S., Shemluck, N., (July 2020), Diversifying the path to CEO in financial services, Retrieved from: Deloitte.com

^[11] Vespa, J., et al.  (Issued March 2018, Revised February 2020).  Demographic Turning Points for the United States: Population Projections for 2020 to 2060.  United States Census Bureau, p. 7.  Retrieved from: census.gov

^[12] Clempner, J., et al.  (2019).  Women in Financial Services 2020.  Oliver Wyman, p. 19.  Retrieved from: oliverwyman.com

^[13] Ibid

^[14] Catalyst.  (June 24, 2020).  Why Diversity and Inclusion Matter: Quick Take.  Retrieved from: Catalyst.org

^[15] Lorenzo, R., et al.  (January 23, 2018).  How Diverse Leadership Teams Boost Innovation.  BCG Henderson Institute.  Retrieved from: Boston Consulting Group Henderson Institute

^[16] Ibid

^[17] Corporate Finance Institute, (2021), Major Risks for Banks, Retrieved from: Corporatefinanceinstute.com

^[18] Rock, D., et al.  (November 4, 2016).  Why Diverse Teams Are Smarter.  Harvard Business Review.  Retrieved from: Harvard Business Review

^[19] Catalyst.  (June 24, 2020).  Why Diversity and Inclusion Matter: Quick Take.  Retrieved from: Catalyst.org

^[20] Ibid

^[21] Chen, J., Leung W., Song, W., Goergen, M., (September 2019), Research: When Women Are On Boards, Male CEOs Are Less Overconfident, Retrieved from: Harvard Business Review

^[22] Catalyst.  (June 24, 2020).  Why Diversity and Inclusion Matter: Quick Take.  Retrieved from: Catalyst.org

^[23] Ibid

^[24] Thomas, R., et al.  (2020).  Women in the Workplace 2020.  McKinsey & Company and LeanIn.Org, p. 51.  Retrieved from: McKinsey.com

^[25] Ibid

^[26] Weiner, N., Munoz, H., (March 2021), Advancing Racial Justice for Frontline Bank Workers,  Retrieved from: bankaccountability.org

^[27] Ibid

^[28] Robinson, A., (April 2021), The push to diversify banking from within the industry, Retrieved from: ABC News

^[29] United States House of Representatives Committee on Financial Services, (2020), Diversity and Inclusion: Holding America’s Large Banks Accountable, Retrieved from: U.S. House of Representatives Committee on Financial Services

^[30] United States Census Bureau.  (2019).  Quick Facts: United States.  Retrieved from: census.gov

^[31] Ibid

^[32] Coindance, (2020), Bitcoin Community Engagement by Gender, Retrieved from: Coindance

^[33] Hao, K., (2018), The first rule of being a woman in crypto is you do not talk about being a woman in crypto, Retrieved from: Quartz

^[34] Dozier, R., (2019), Black Blockchain Meet-up Addresses Lack of Diversity in Crypto, Retrieved from: Breakermag

^[35] Diaz, A. et. Al., (September 2020), Racial Equity in Financial Services, Retrieved from: McKinsey.com

^[36] Manning, J., (July 2019), Achieving Diversity and Inclusion in the Banking Sector: A Work in Progress, Retrieved from: International Banker

^[37] Ibid

^[38] United States Congress (2010), Dodd-Frank Wall Street Reform and Consumer Protection Act, Retrieved from: Congress.gov

^[39] Federal Register, (2015), Final Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies, Retrieved from: The Federal Register

^[40] Ibid

^[41] Ibid

^[42] Wright, M., (October 2020), Why diversity and inclusion matters to regulators, Retrieved from: Independent Banker

^[43] United States House of Representatives Committee on Financial Services, (2020), Diversity and Inclusion: Holding America’s Large Banks Accountable, Retrieved from: U.S. House of Representatives Committee on Financial Services

^[44] Ibid

^[45] State of California.  (2020).  Women on Boards.  Retrieved from: sos.ca.gov

^[46]  Steele, A.  (October 1, 2020).  California Rolls Out Diversity Quotas for Corporate Boards.  The Wall Street Journal.  Retrieved from: The Wall Street Journal

^[47] Reuters.  (February 25, 2021).  U.S. SEC should revisit disclosure requirements on diversity – acting chair.  Retrieved from: reuters.com

^[48] Sorkin, A., et al.  (January 13, 2021).  Potential Priorities for Wall Street’s Next Top Cop.  Retrieved from: The New York Times DealBook

^[49] Arndt, P., et al.  (2019).   Gender quotas in a European comparison: Tough sanctions most effective.  DIW Weekly Report, pp. 339-41.  Retrieved from: diw.de

^[50] Government of Canada.  (2021).  Diversity of boards of directors and senior management.  Retrieved from: ic.gc.ca

^[51]  Manning, J., (July 2019), Achieving Diversity and Inclusion in the Banking Sector: A Work in Progress, Retrieved from: International Banker

^[52] State Street.  (March 7, 2017).  State Street Global Advisors Calls on 3,500 Companies Representing More Than $30 Trillion in Market Capitalization to Increase Number of Women on Corporate Boards [Press Release].  Retrieved from: StateStreet.com

^[53] Lacaille, R., (August 2020), Diversity Strategy, Goals & Disclosure: Our Expectations for Public Companies, Retrieved from: State Street Global Advisors

^[54] Hunnicutt, T.  (July 13, 2017).  BlackRock supports effort to boost number of women board members.  Reuters.  Retrieved from: Reuters

^[55] BlackRock, (March 2020), BlackRock Releases 2020 Stewardship Priorities for Engaging with Public Companies, Retrieved from: BlackRock

^[56] Vanguard Investments, (2019), Vanguard Investment Stewardship Perspectives, Board Diversity, Retrieved from Vanguard

^[57] Makortoff, K., (October 2020), Legal & General warns FTSE 100 firms over lack of ethnic diversity, Retrieved from: The Guardian

^[58] Goldman Sachs.  (February 4, 2020).  Goldman Sachs’ Commitment to Board Diversity.  Retrieved from: goldmansachs.com