Background Information:

The Security Exchange Commission (SEC) established the Office of Minority and Women Inclusion (OMWI) in July of 2011, as required by Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  OMWI is responsible for all matters related to diversity in management, employment and business activities at the SEC. The SEC joined with other federal financial regulators in issuing the “Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies” (Joint Standards) in a final interagency policy statement dated June 10, 2015.  (https://www.sec.gov/page/omwi-section-landing). As a result, an auditing process and self-assessment was developed to assess all regulated entities, including Whitley Mortgage Associates, Inc.

This Diversity and Inclusion Policy ensures diverse and inclusive practices within our company policies and procedures.

 

The Firm’s Policy on Commitment to the Diversity and Inclusion Policy:

Whitley Mortgage Associates, Inc. is committed to ensuring diverse and inclusive practices in recruitment, hiring, retention, intern selection, promotion and separation procedures. WMA’s Diversity and Inclusion Policy provides a roadmap for how to achieve and maintain diverse and inclusive practices.

 

Senior Level Official with Experience in Diversity and Inclusion Policies Appointed to Oversee and Direct Efforts:

WMA has identified Sarah Rynne as the Diversity and Inclusion Officer. Ms. Rynne is responsible for implementing the Diversity and Inclusion Policy that provides mentoring and Internship opportunities for all people, including women and minorities. Ms. Rynne is also identified as the Internship Coordinator.

 

Strategic Plan for Recruiting, Hiring, Retaining and Promoting Employees:

Whitley Mortgage Associates, Inc. includes this Diversity and Inclusion Policy in the greater Strategic Plan for Recruiting, Hiring, Retaining and Promoting Employees.

 

Selecting Executive & Senior Level Officials and Members of the Board of Directors or Other Governing Bodies:

Whitley Mortgage Associates, Inc. advertises within the organization and outside the organization when selecting executive and senior level officials and members of the Board of Directors or other governing bodies. WMA ensures a diverse pool of candidates by advertising such positions through:

1. Media/Social Media groups serving minorities and women
2. Email lists compiled from lists obtained at networking events, expos, online sign-up, contact request forms from our website for those seeking employment, and applicant lists

 

Equal Employment Opportunity and Diversity and Inclusion Trainings:

Whitley Mortgage Associates, Inc. Compliance Department offers mandatory, periodic trainings on:

1. Equal Employment Opportunities and
2. Diversity and Inclusion
3. Vendor Diversity and Inclusion

 

Diversity and Inclusion Progress Reports to Board of Directors:

Diversity and Inclusion progress is reported to the Board of Directors, Senior Management, quarterly.

 

Outreach & Establishing Relationships:

It is a requirement of the “Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies,” and The Diversity and Inclusion Self-Assessment to establish relationships with and provide information on, opportunities to educational institutions. Whitley Mortgage Associates, Inc. engages in outreach opportunities to:

1. Organizations serving predominantly minorities and women
2. Educational Institutions, some that serve predominantly minorities and women
3. Participating in women’s and minority’s conferences, workshops and events that attract minority and women applicants and intern applicants

 

Employee Appraisal System:

WMA’s Human Resources Department implements a fair and equitable employee performance review system. This system incorporates quantitative measures (progress monitoring) to assess the effectiveness of the Diversity and Inclusion Policy when preparing quarterly reports for the Board of Directors.

 

Quantitative Measures for Assessing Effectiveness of the Diversity and Inclusion Practices:

Data on the effectiveness of the recruiting, hiring, selection of interns, retention, promotion and separation of employees and interns is provided to the Board of Directors in a quarterly report.

 

Qualitative Measures for Assessing Effectiveness of Diversity and Inclusion Practices:

WMA utilizes qualitative measures, such as , to assess the effectiveness of recruiting, hiring, selection of interns, retention, promotion and separation of employees and interns. This data is provided to the Board of Directors in a quarterly report.

 

Diversity and Inclusion Objectives for Managers:

WMA’s Manager’s Performance Appraisal includes objectives for managers relating to Diversity and Inclusion.

 

Diversity and Inclusion Vendor Policy:

WMA implements a Diversity and Inclusion Vendor Policy.

 

Developmental Employee Programs:

WMA values our employees and interns and has created a program to develop employee skills and strengths and increase knowledge and experience. Our employees receive ongoing periodic on compliance-related issues, industry regulation(s), changes, and innovations. Employees are provided opportunity to apply for off-campus educational opportunities, such as attending industry conferences, trainings, expos and workshops. Annual goal setting and progress monitoring of these goals is essential in developing the needed skills to build upon for Employees.

 

Developmental Program for Potential Contractors:

WMA values our community and seeks to offer tailored Developmental Programs for Potential Contractors that will equip contractors to be able to provide goods or services for WMA. Potential contractors can submit their information. WMA will evaluate possible candidates for this Developmental Program for Potential Contractors from a pool of contractor-applicants, using the WMA Contractor Candidate Evaluation Form. If selected, the contractor-applicant will meet with WMA Diversity and Inclusion Officer to tailor a Developmental Program for Potential Contractors to their specific service/good/industry.

 

MENTORING AND INTERNSHIPS:

I.               Mentoring Program:

Whitley Mortgage Associates, Inc. offers a mentoring program as a part of the onboarding process of a new hire. All new employees will be offered an Employee Mentor for a period at the beginning of employment.

New employees have an opportunity to provide feedback for qualitative feedback on the Mentoring Program.

 

II.             Internship Program:

Whitley Mortgage has developed the following Internship Program to ensure diverse and inclusive practices.

Our Responsibilities:

It is a requirement of the “Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies,” to:

1. Advertise the Internship to groups and at events promoting the advancement of minorities and women in the workplace.
2. Establish relationships with, and provide information on, opportunities to educational institutions.

Unpaid, Paid Internships & Apprenticeships:

Currently, the internship position at Whitley Mortgage Associates, Inc. is an unpaid internship. The Fair Labor Standards Act (FLSA) requires “for-profit” employers to pay employees for their work. Interns and students, however, may not be “employees” under the FLSA—in which case the FLSA does not require compensation for their work. (https://www.dol.gov/whd/regs/compliance/whdfs71.htm)

Requirements of an Intern:

• High School Graduate
• College preferred
• Proficiency with Microsoft Office
• Strong attention to detail, organization, multitasking, and time-management
• Writes, presents, and communicates in an articulate and persuasive manner, across a variety of platforms, including interoffice, on the phone, in writing and on social media
• Team player who enjoys working with and helping others in a collaborative environment
• Open to ideas and viewpoints from others, with a willingness to learn and take constructive feedback
• A good problem solver who seeks to make improvements and learns from mistakes

Internship Selection Process:

1. Intern applicants submit their resume/application and WMA selects the best Intern applicant(s) based on our standard WMA Intern Candidate Evaluation
2. The Intern enters into an Intern Contract, like an employment Internship Coordinator completes the contract with the Intern selectee according to their specific needs. Under the Fair Labor Standards Act, all parties must agree and of appropriate age.
3. Interns are matched with an “Employee Mentor” and a “Supervising Mentor”. The Intern meets with the Supervising Mentor on a weekly, or more frequent, basis.
   1. Intern completes a self-evaluation upon initial Supervising Mentor meeting, and drafts goals based on self-assessment.
   2. Supervising Mentor completes the evaluation the next week, discussing and possibly adjusting goals.
   3. Intern and Supervising Mentor formally meet weekly to progress monitor goals, problem-solve and collaborate.
   4. Supervising Mentor works closely with Intern teaching identified skills and providing experiential opportunities for Intern, ongoing.
4. Interns gain experience, knowledge and skills in the mortgage industry much like they would in an educational setting. Interns are given the opportunity to learn and experience the mortgage industry: originating, processing, compliance, sales, and management.
5. After completion of the Internship program the Intern can apply for employment with WMA.

Intern Goal Setting and Appraisal System:

Through the Diversity and Inclusion Policy, WMA implements a fair and equitable intern performance review system. This system incorporates quantitative measures (progress monitoring) to assess the effectiveness of the Diversity and Inclusion Policy when preparing quarterly reports for the Board of Directors.

Intern Contract:

Whitley Mortgage Associates, Inc. and the intern will enter into an Intern Contract, similar to an employee contract.

Intern Non-Disclosure Agreement:

Whitley Mortgage Associates, Inc. and the Intern will enter into a non-disclosure agreement.

Intern Roles and Responsibilities:

Day-to-day responsibilities and learning opportunities will include:

1. Research and preparation of reports on borrower demographics, pre- & post-closing data, data-input, compliance, etc.
2. Learning and understand our business model, structure, and offerings
3. Research and drafting marketing for Social Media, and other avenues of advertising
4. Basic customer support/service on the phone and in person with borrowers
5. Data-input pre-submission, processing, and post-close
6. Training on how to deal with confidential data
7. Assisting with Loan Origination, per SAFE Act guidelines
8. Community outreach, including job fairs, expos and events offering to education potential employees and homeowners
9. Daily, weekly, and monthly meetings with mentor(s)
10. Team meeting coordination including scheduling, agendas, materials preparation, note taking, etc.
11. May assist with client billing and/or program budget/expense reconciliation, as needed

 

Internship Mentor:

According to the Onboarding Policy and the Intern Contract, an “employee-mentor” will be provided. A “Supervising Mentor,” or manager, will also be provided to meet on a weekly basis, or more frequently, as needed. Qualitative feedback is sought from intern found in Onboarding Policy page 6.

Established Timeline for Internship:

Timeline of Internship – will be dependent on specific needs of Intern, to be determined by

Internship Coordinator, Supervising Mentor and Intern. Dates of Mentor Meeting(s) – meetings will occur periodically. Intern and Intern Coordinator can determine the frequency of meetings based on goals and progress-monitoring.

Interview Process:

The Intern interviewee will submit a resume to the pool of candidates. The Intern Coordinator will then, in conjunction with CEO, interview candidates in person or virtually. The selection will be made based on The WMA Intern Candidate Evaluation form scores.

 

Summary:

WMA’s is committed to implementing with fidelity the company’s Diversity and Inclusion Policy including its Internship Program. The Firm is committed to ensuring diverse and inclusive practices through the following:

Firm’s Diversity and Inclusion Strategic Plan:

Whitley Mortgage ensures diverse and inclusive practices in recruiting, hiring, selection of interns, retention, promotion, and separation practices by:

1. Providing mandatory, periodic training on Equal Employment Opportunities and Diversity and Inclusion to its staff and interns.
2. Provide Mentoring and Internship Opportunities.
3. Continued implementation of the fair and equitable Employee Appraisal System and Manager Appraisal System and the Developmental Program for Employees and Interns and Contractors.
4. Participate in outreach to groups, organizations, educational institutions, and/or events that appeal to women and/or minorities, and establishing relationships with those groups, organizations and/or institutions.
5. Maintain database of minority-owned and women-owned vendors that will compete for upcoming contracts.
6. Participate in outreach to groups, organizations, educational institutions, workshops and/or events that appeal to women-owned businesses and/or minority-owned businesses, and establish relationships with those groups, organizations and/or institutions.
7. Publishing employment and internship opportunities on our website, and on Social Media (in groups focused on women and minorities).
8. Publish upcoming opportunities to procure goods or services from vendors and contracting opportunities on our website, Social Media (in groups focused on women and minorities), and through email lists.
9. Publish information on mentorship and developmental employee programs and developmental programs for potential contractors on the website.
10. Provide quarterly reports to Senior Management on Progress.

Firm Transparency:

WMA publishes the following information related to Diversity and Inclusion on its website:

1. Commitment Statement: Whitley Mortgage Associates, Inc. is committed to ensuring diverse and inclusive practices in recruitment, hiring, retention, intern selection, promotion and separation procedures. WMA’s Diversity and Inclusion Policy provides a roadmap for how to achieve and maintain diverse and inclusive practices.
2. Diversity and Inclusion Policy
3. Vendor Diversity and Inclusion Policy
4. Employment and internship opportunities
5. Opportunities for vendors to provide goods or services and contracting opportunities
6. Mentorship and developmental employee programs and developmental programs for potential contractors
7. WMA’s Diversity and Inclusion Strategic Plan