regulatory and compliance issues and considerations

• Occasional parties or picnics for employees and their guests.
Exclusion from wages. You can generally exclude the value of de minimis meals you provide to an
employee from the employee's wages.
For your convenience. Whether you furnish meals for your convenience as an employer depends on all the
facts and circumstances. You furnish the meals to your employee for your convenience if you do this for a
substantial business reason other than to provide the employee with additional pay. This is true even if a law or
an employment contract provides that the meals are furnished as pay. However, a written statement that the
meals are furnished for your convenience is not sufficient.
.
Meals after work hours. Meals you furnish to an employee immediately after working hours are furnished for
your convenience if you would have furnished them during working hours for a substantial nonpay business
reason but, because of the work duties, they were not eaten during working hours.
Meals you furnish to promote goodwill, boost morale, or attract prospective employees. Meals you
furnish to promote goodwill, boost morale, or attract prospective employees are not considered furnished for
your convenience. However, you may be able to exclude their value as discussed under De Minimis Meals,
earlier.
G. Apply Common Sense
The purpose of these policies is to avoid violations of 18 U.S.C. Section 215 and to
ensure that ABC Federal Credit Union and its CUSOs’ business is safeguarded from the
influence of bribery or personal favors. Whenever representatives of ABC Federal
Credit Union or any CUSO, have personal dealings with persons who have business
with ABC Federal Credit Union or any CUSO, the requirements of the law must be kept
in mind. Necessarily, the application of the guidelines stated in Paragraph B above will
require good judgment and common sense. If you encounter situations in which you are
not sure of your obligations or if you find the application of these guidelines to be unduly
restrictive, you should consult the Ethics Committee. Under no circumstances should
you accept any personal gift or favor if it appears that by giving it the donor hopes to
influence any business of ABC Federal Credit Union or any CUSO, or to reward you for
actions taken by you or on behalf of ABC Federal Credit Union or any CUSO.
H. Personal Relationships with Members and Vendors
It is inevitable and desirable that persons associated with ABC Federal Credit Union
and its CUSO, will have individual business and personal relationships unrelated to
ABC Federal Credit Union or any CUSO business, with ABC Federal Credit Union or
any CUSO ’ members, vendors and others who do business with ABC Federal Credit
Union or any CUSO . This policy statement is not intended to discourage such
relationships. Any personal business relationships should be on customary terms and
for proper and usual purposes, however, and no one associated with ABC Federal
Credit Union or any CUSO, should solicit any special favors in recognition of his or her
position with ABC Federal Credit Union or any CUSO. See Section IV below.
Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved.
Revised February 2010
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