OFCCP’s New MOU with the EEOC Could Dramatically Change OFCCP’s Enforcement Program

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The Office of Federal Contract Compliance Programs (“OFCCP”), the Equal Employment Opportunity Commission (“EEOC”), and the U.S. Department of Justice’s Civil Rights Division (“DOJ CRD”) executed and finalized on November 3, 2020 a dramatically different (Memorandum of Understanding (“MOU”) than we have previously seen. The big change from the 2011 predecessor MOU is that OFCCP will now become an “agent” of the EEOC stepping-into-its-shoes to investigate Title VII Charges and for the first time ever will be authorized to apply both Title VII liabilities and remedies to Charges arising pursuant to Title VII. The agencies will

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