Fair Chance Hiring in Financial Services

A Step-by-Step Guide to Hiring Workers with Arrest and Conviction Records in the Financial Services Industry

Executive Summary

All of us are stakeholders in building a just and inclusive economy. That fact has been underlined by the COVID-19 pandemic and recent racial justice uprisings, both of which have brought renewed institutional attention to longstanding racial and economic inequalities in the United States. Employers and their human resources departments have an outsized opportunity to make changes where they will have significant, rippling impacts: the workplace. The need for change is particularly apparent in the financial services industry, which has a predominantly white workforce and concentrates Black and Latinx workers in the most junior, lowest paid jobs.[1]

A just and inclusive economy is only achievable by centering racial equity. The fact that a disproportionate share of people in underpaid, insecure, and unsafe jobs are Black and brown is not inevitable, nor accidental.

–Rebecca Dixon, Executive Director, National Employment Law Project

The exclusion of people with arrest and conviction records contributes to the lack of diversity in financial services and to occupational segregation across industries. Pervasive employment barriers lock individuals with arrest and conviction records—who are disproportionately Black, Latinx, and Indigenous[2] people—into unstable, unsafe, and underpaid jobs long after they are arrested or convicted. Employer policies that increase the hiring and retention of workers with records in good jobs mean a fighting chance for those workers to build economic stability for themselves, their families, and their communities. Such “fair chance hiring” reforms also represent an institutional commitment to racial and economic equity.


The Role of Human Resources in Fair Chance Hiring

As part of an influential sector, financial services companies have a unique duty and opportunity to expand career opportunities for people with records by adopting “fair chance hiring” practices and encouraging other employers to follow that example. Encouraging your company to embrace fair chance hiring is not only the right thing to do, but it will also represent a smart change for your company. Employers that have already made such changes have praised the enthusiasm and work ethic of their new employees as they take steps toward building a more diverse workforce.

Your company and HR team can take concrete steps toward welcoming and retaining a more diverse staff, including workers with records. In various industries—including health care,[3] higher education,[4] philanthropy,[5] and financial services—human resources staff, recruiters, and hiring managers have played a crucial role in the creation of more equitable workplaces. These roles represent where the rubber hits the road and therefore where internal policy change will have the greatest impact. While this guide may be helpful to staff members in a variety of industries and positions, the following advice is particularly targeted toward human resources and hiring staff and executives in the financial services industry.


A Guide to Fair Chance Hiring for Financial Services Employers

At the request of the JPMorgan Chase Foundation, the National Employment Law Project (NELP), along with Safer Foundation (Safer) and Cabrini Green Legal Aid (CGLA), composed this toolkit to help financial services employers expand opportunities for workers with conviction and arrest records. This guide provides step-by-step instructions for financial services employers—particularly, their human resources staff and executives—to operationalize their commitment to fair chance hiring into concrete policies and practices.

The recommendations in this toolkit stem from years of research, work with employers in other industries, and lessons drawn from JPMorgan Chase’s “second chance pilot” in Chicago, which the company undertook in 2019-2021 with Safer, CGLA, and other community partners. Your company may have adopted some of these steps already, in which case we encourage you to read on for opportunities to further improve. Even if your company is not ready to make every change now, you can begin to lay the groundwork for future progress.

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[1] Alex Hickey, 8 Charts that Explore Racial Disparities in the Banking Industry, Morning Brew, May 18, 2021, https://www.morningbrew.com/daily/stories/2021/05/18/8-charts-explore-racial-disparities-banking-industry (synthesizing 2018 EEO-1 data from the EEOC).

[2] Prison Pol’y Initiative, Racial Disparities in Incarceration Rates, 2019 (2021), https://www.prisonpolicy.org/graphs/incarceration_byrace_2019.html.

[3] Nat’l Emp’t Law Proj. & Safer Found., A Healthcare Employer Guide to Hiring People with Arrest and Conviction Records (2016), https://www.nelp.org/wp-content/uploads/NELP-Safer-Toolkit-Healthcare-Employer-Guide-Hiring-People-with-Arrest-Conviction-Records.pdf.

[4] Letter from Marc LeForestier, Gen. Couns., Cal. Cmty. Colls., to Cal. Cmty. Coll. Dist. Hum. Res. Officers (Dec. 31, 2018), https://www.cccco.edu/-/media/CCCCO-Website/About-Us/Divisions/Office-of-the-General-Counsel/Legal-Advisories/2018-12-31-Legal-Advisory-re-Use-of-Criminal-History-in-Hiring-Final.ashx?la=en&hash=6C4754B916DF42371F3FBAAC314D58E8E637A579 (providing guidance on use of criminal history records in hiring, which NELP helped develop).

[5] Execs.’ Alliance for Boys & Men of Color, Formerly Incarcerated, Convicted People & Families Movement & Nat’l Emp’t Law Project, Fair-Chance Hiring in Philanthropy (2016), https://www.nelp.org/publication/fair-chance-hiring-in-philanthropy-a-step-by-step-guide/.

Related to

About the Authors

Beth Avery

Areas of expertise:
  • Criminal Records & Employment

Han Lu

Areas of expertise:
  • Criminal Records & Employment,
  • Workplace Equity

Kemi Role

Areas of expertise:
  • Community Engagement,
  • Criminal Records & Employment,
  • Occupational Segregation,
  • Workplace Equity

Ana Karen Flores

Benjamin Osborne

Senior Director of Monitoring, Evaluation and Research, Safer

Sodiqa Williams

General Counsel and Senior Vice President, Supportive Reentry Division, Safer

Brandon Williams

Supervising Attorney, Cabrini Green Legal Aid

Cynthia Cornelius

Director of Programs, Cabrini Green Legal Aid

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