Note: This was provided by Mike Alford, Chairman of NADA’s Regulatory Affairs Committee.
Dealers with 100 or more employees are subject to the U.S. Equal Employment Opportunity Commission’s (EEOC) EEO-1 Survey filing mandate. The EEOC enforces federal laws that make it illegal to discriminate against a job applicant or employee because of race, color, religion, sex, national origin, age, disability or genetic information.
The EEO-1 Survey for 2018 data is due by May 31, 2019, and must include demographic data on race, gender and ethnicity by job category (information known as “EEO-1 Survey Component 1 data”).
In addition, the Federal District Court for the District of Columbia recently ruled that additional data for calendar years 2018 and 2017 must be filed by September 30, 2019. Known as “EEO-1 Survey Component 2 data,” these additional filings must include employee W-2 wage and hours worked information set out in 12 specified pay bands. Important: the EEOC intends to open by mid-July a portal for Component 2 data; NADA will notify dealers when that happens.
Last week, the U.S. Department of Justice filed a notice to appeal the District Court’s ruling requiring the Component 2 data. However, since the District Court’s ruling has yet to be stayed, NADA suggests that for now EEO-1 filers should assume that they will have to file Component 2 data by the September 30, 2019 deadline.
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