Financial institutions, including banks and credit unions are required to maintain an Affirmative Action Plan when the following conditions exist:
- the financial institution has at least 50 employees and
- are issuing and paying agents for U.S. Savings Bonds and Notes in any amount; or
- serve as a depository of Government funds in any amount; or
- hold a prime or subcontract with the federal government of at least $50,000.
Beginning January 1, 2012, the U.S. Treasury will no longer sell U.S. Savings Bonds through financial institutions such as banks and credit unions. Due to this change some financial institutions may no longer be required to develop and maintain an Affirmative Action Plan. Before terminating your AAP, financial institutions should be careful to make sure none of the other criteria above apply.
If you have any questions about the information presented in this alert, or if you are a financial institution that meets the criteria above and have never maintained an affirmative action plan, please feel free to contact Lynn Morris for more information on affirmative action requirements and plan development.