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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,

worth $1,619,310.

Attached is a copy of the Bank's S&DB report

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.

In view of the large number of minority contracts

involved, we have not broken them out individually. However, if the Chairman were to consider such a breakdown to be necessary,

we would be glad to compile it on request.

QUESTION 3(6): 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).

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Total Cost of Program (1) see explanatory note attached.

Average Number of Personnel
Salary Expense

Other Expense
Incremental Cost of Program

incrementai Increase in Number of Employees
Incremental Increase in Employee Salaries ..

Incremental Increase in Other Costs *(Other than contract cost difference)

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Sub-Contract Awards Made by Prime Contractors under S&DB Program

Number

Dollar Amount

-0

Total Contract Awards with S&DB Requirement
Awards to S&D8 Subcontractors - Regular Contracts
Awards to S&D8 Subcontractors-Construction Contracts

$ $ $

* Second District statistics include the S&DB results of

che Office of Employee Benefits.

Specitic Products or Service Categories Most Accessible to S&DB Participants (specify)

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The Bank's scaff responsible for the acquisicion of goods and services will continue their efforts to enhance compliance with the Small and Disadvantaged Business Procurement Policy by actively pursuing qualified vendors, whenever possible.

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ANNUAL REPORT ON SMALL AND DISADVANTAGED BUSINESS PROCUREMENT

FOR THB YEAR ENDED DECEMBER 31, 1991

NOTE: 1.

Administrative Costs for purposes of panel three are very narrowly defined to encompass only the time spent compiling and keying the relevant data for reporting purposes. The total resources actually involved in the S&DB program are orders of magnitude larger than noted in the panel, although we do not account for them separately from other procurement-related or administrative expenses. At a minimum, a substantial portion of the time of the officer serving as the Bank's Small Company Specialist, as well as legal staff and the more than 45 contract representatives around the Bank with S&DB responsibility would more realistically represent the level of resources involved in the program.

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