Are Credit Unions Federal Contractors?
According to the Department of Labor (DOL), yes, all federally-insured credit unions are considered federal contractors. In a formal FAQ, the Office of Federal Contract Compliance Programs at the DOL concluded "financial institutions with federal share or deposit insurance are considered government contractors within the meaning of the regulations implementing Executive Order 11246."
Background
Historically, credit unions were considered federal contractors because they acted as issuing and paying agents for U.S. savings bonds. In 2012, the United States Department of the Treasury began issuing savings bonds directly. Despite this change, federally-insured credit unions are still considered federal contractors due to their federal share insurance and must ensure they comply with the applicable regulations.
Affirmative Action Plans
As federal contractors, credit unions with more than 50 employees must develop an Affirmative Action Plan. At least annually, the Affirmative Action Plan must be reviewed and updated, as necessary. Credit unions can find the specific requirements in 41 CFR 60-2.
The development of an Affirmative Action Plan is more complex than adopting an Equal Employment Opportunity policy. Specifically, a ffirmative action programs contain a diagnostic component which includes a number of quantitative analyses designed to evaluate the composition of the workforce of the credit union and compare it to the composition of the relevant labor pools.
Additional Information
Howard & Howard Attorneys has a team of Labor and Employment attorneys that are able to help credit unions develop, review and update their Affirmative Action Plans to stay compliant.
If you have any questions on your requirements or would like additional information, please contact Steve Van Beek or Michael Bell.
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About Howard & Howard
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