TABLE 1

FEDERAL RESERVE BANK OF NEW YORK
FORMAL EEO DISCRIMINATION COMPLAINTS

EEOC dismissed charges - 10/90
EEOC dismissed charges - 6/91

EEOC ruled in favor of Fed., under appeal
Employee withdrew his complaint
EEOC issued no action letter.

Employee sued. Judgment pending.

Note: NYS DOHR - New York State Division of Human Rights

DETAILED RESPONSE TO QUESTION 3

QUESTION 3(a): The Bank has an established outreach

program for minorities and minority-owned entities, having for many years maintained a Small and Disadvantaged Business ("S&DB") Program which fosters business between the Bank and small and minority-owned entities. The Bank's internal policy and guidelines relating to the Program are attached.

The Program is centrally managed by the Bank's Small Company Specialist, Joseph DeMartini. Mr. DeMartini is the officer in charge of the Bank's Administrative Services Department, which includes centralized purchasing functions. Mr. DeMartini reports to John Sobala, Vice President of our Building Services Function, Operations Group. With respect to the S&DB Program, Mr. DeMartini also has a direct line to Suzanne Cutler, Executive Vice President of our Operations Group, and through Miss Cutler to the Bank's President and First Vice President. Further, the Bank's S&DB activity is reported annually to the Board of Governors.

In addition, the Bank is a member of the New York-New Jersey Minority Purchasing Council, which provides the Bank with information on minority companies by category of goods and services. The Council also provides information on its members, including the Bank, to minority companies so the latter may

present themselves for business consideration.

While the Bank's S&DB program is centrally managed

through the Bank's purchasing division, it is important to note that S&DB responsibility is assigned to more than 45 contract representatives across the Bank's different functional areas to ensure coverage of each type of good or service, as indicated in the attached internal policy. These representatives provide relevant S&DB information on each purchase requisition in their functional area, and that information is monitored and assembled in the purchasing division for reporting purposes.

QUESTION 3 (b):

Question 3(b) requests specific information

on the number and value and contracts with minorities or women and firms owned by them, for (a) financial services, (b) investment banking, (c) underwriting, (d) accounting, (e) legal services, (f) asset management, (g) asset disposition, and (h) other. However, the Bank, under its S&DB Program enters into contracts, as a general matter, only for goods and maintenancetype services, all of which would fall under category (h) other. The Bank does not ordinarily purchase any of the services identified (a) through (g), except, occasionally, outside legal services when expertise in a narrow area of the law is required. A total of only $87,000 was spent on outside legal services in

1991.

In 1991, the Bank awarded 7,103 contracts to small businesses, totalling $11,417,414 or 31 percent of all contracts involved in the S&DB Program. While a number of these awards went to minority firms which, for various reasons, chose not to

present themselves to us for consideration of their minority status, in 1991 the Bank did generate 1,243 goods and

maintenance-type contracts with certified minority businesses, Attached is a copy of the Bank's S&DB report

worth $1,619,310.

for 1991 to the Board of Governors.

Inasmuch as we manage our

program consistent with the spirit of the Small Business Act and its implementing regulations, and women are not designated a protected class for the Act's purposes, we do not maintain data on the representation of women in our contracting relationships. Of course, to the extent minority and small businesses with which we have contractual relationships are women owned, they are included in the data.

However, if

In view of the large number of minority contracts involved, we have not broken them out individually. the Chairman were to consider such a breakdown to be necessary, we would be glad to compile it on request.

QUESTION 3(c): The Bank's S&DB Program requires that each company claiming minority status to so attest on a Bank form, and to provide a copy of its certification, if available. Such certification may be issued by any government or agency (federal, state or local) or other recognized body (e.g. the National Minority Council or the New York-New Jersey Minority Council).