As we currently reported on our January 9 blog, on Dec. 17, 2012, the Equal Employment Opportunity Commission released its strategic enforcement plan (SEP). The SEP resulted from the broader strategic plan unveiled by the EEOC earlier this year, outlining the commission’s activities for 2012-2016. The SEP confirms that combating systemic discrimination will be one of the EEOC’s primary objectives. Read Orrick’s “EEOC’s Plan May Mean Narrower, More Aggressive Oversight” on Law360.
On December 17, 2012, the EEOC released its Strategic Enforcement Plan. As previously reported, the EEOC released the draft SEP for public comment on September 4, 2012, with a plan to vote on and implement it by October 1. The more than two month delay suggests that the Commission reviewed the more than 100 comments to the draft and may have also been internally conflicted over portions of the draft (the Commission’s final vote was 3-1). READ MORE
On September 4, 2012, the EEOC released for comment its draft Strategic Enforcement Plan (SEP). The EEOC invited the public to comment on the SEP by September 18, 2012, with a plan to vote on the draft at the end of September 2012 and to have the SEP become effective October 1. But that time has now passed with no word from the Commission. This suggests that the Commission is closely evaluating the comments submitted and considering which, if any, to incorporate into the final plan. There may also be disagreement within the Commission over portions of the draft plan. As a result, we do not expect the EEOC to issue the final SEP until mid-October at the earliest. READ MORE