Comerica Transforms Compliance into Competitive Advantage with AAP Services and Diversity Insights

Headquartered in Dallas, Texas, Comerica is a financial services company with three strategic business segments: Business Bank, Retail Bank, and Wealth Management.

The company operates more than 400 banking centers in the U.S. and additional locations in Canada and Mexico. With more than 8,000 employees, Comerica is among the 25 largest U.S. financial holding companies.

Comerica has a long history of investing in the value of diversity in its workforce, business and community outreach, and supplier base.

Since 2004, the bank has relied on Affirmity (previously operating as PeopleFluent) to support its affirmative action program. Today, that support extends beyond AAP preparation and compliance, guiding Comerica’s award-winning diversity initiatives through meaningful metrics and robust reporting.

“You’ve got to invest in analysis or you won’t be able to move the needle.” – Nathaniel Bennett, Senior Vice President, Chief Diversity Officer and Head of Talent Acquisition

Turnkey Planning Services for Audit-Ready AAPs

As a financial services company, compliance is vital to Comerica’s operations.

With Affirmity’s AAPlanner® software, the bank has long been able to automate plan preparation and ensure its AAPs are 100% technically compliant. But it took months of effort to gather and reconcile workforce data, conduct the required analysis, and prepare narratives.

To free up its workforce compliance team to focus on strategic planning, Comerica elected to outsource AAP generation to Affirmity’s expert consultants.

Today, Affirmity produces audit-ready AAPs for all Comerica locations in less than 60 days and manages all aspects of AAP development, including

  • Plan development, reporting, and monitoring
  • Adverse impact analysis
  • Compensation analysis
  • Narrative preparation.

Our consultants serve as an extension of Comerica’s team, always available to answer questions and ensure the compliance team is fully prepared in the event of an OFCCP audit.

We also contribute ongoing training to its compliance and HR teams, delivering multiple webinars each month on good faith efforts, recruiting compliance, and other important regulatory issues.

“Outsourcing our AAP preparation enables me to take a more strategic look at the results.” – Lori Walker, Vice President, Senior Diversity & Inclusion Consultant

Using Data to Drive an Award-Winning Diversity Program

For Comerica, compliance and diversity are paramount and mutually reinforcing commitments, and the company invests in initiatives that go beyond minimum requirements.

For example, Comerica engages Affirmity statisticians to conduct comprehensive pay equity studies—establishing baseline data, reviewing compensation variables, and monitoring their efforts to ensure employees receive
equitable pay. These studies include company-wide and state-focused analyses, to ensure full compliance with all applicable laws governing equal pay.

The bank also looks to Affirmity for assistance with reporting against diversity initiatives. Our experts helped Comerica’s HR team eliminate the need to replicate compliance data in reports prepared for executive leadership.

Today, Comerica relies on a single source for workforce data, prepared by our experts, for both compliance and diversity reporting.

With consistent and accurate data, Comerica gains total visibility of workforce diversity across the organization and at each stage in the talent lifecycle. Its HR and business leaders use the data to drive and track initiatives to foster a diverse and inclusive workplace.

In recognition of their successful program, in 2017 and 2018 Comerica was ranked by DiversityInc® among the top 10 regional companies for diversity.

“While advancing diversity starts with a commitment and a mindset, it also demands robust data.  With Affirmity’s reporting capabilities, we can see where talent utilization doesn’t match intent. And, then we can identify the cause and mitigate it.” – Nathaniel Bennett, Senior Vice President, Chief Diversity Officer and Head of Talent Acquisition

Fostering Executive Accountability for Diversity

At Comerica, accountability for diversity resides with the CEO and executive leadership team. Using data insights prepared by Affirmity experts, the company creates Diversity Involvement Scorecards that capture a leader’s success in

  • Workforce diversity
  • Business outreach
  • Social impact
  • Compliance and risk.

Within each category, the scorecard shows specific metrics—such as hiring, promotions, and retention—to track progress toward diversity goals across all business units.

Powered by Affirmity’s analytics and at-a-glance reporting, Comerica can target training and organizational change where needed and foster accountability at the highest level.

“With Affirmity’s help, we’ve built years of solid data on hiring, promotions, retention, and other metrics, and we’re able to clearly articulate to our executive leadership how we’re progressing toward goals.” – Nathaniel Bennett, Senior Vice President, Chief Diversity Officer and Head of Talent Acquisition

Building and Empowering a Diverse Workforce

In partnership with Affirmity experts, Comerica uses the insights derived from analyzing employee data to weave diversity programs and awareness through all aspects of the organization. The bank trusts our team to support its affirmative action and diversity programs through meaningful metrics, rigorous analysis, and robust reporting.

We celebrate and support Comerica’s commitment to building and empowering a diverse workforce, and to expanding its services and outreach within diverse communities.

What Can Affirmity Do for Your Organization?

Find out how Affirmity can help your HR and compliance teams optimize critical affirmative action and D&I programs.