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• 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 12
IV. POLICY REGARDING CONFLICTS OF INTEREST A. General Policy Conflicts of interest may arise when individuals associated with ABC Federal Credit Union or one of its CUSOs, acquire personal interests or engage in outside activities in which their normal self-interests or obligations to others conflict with the interests of ABC Federal Credit Union or any CUSO, or its members. In some circumstances, engaging in conflicts of interest violates the law. In other cases, conflicts of interest may lead individuals to accept inappropriate personal benefits -- which may violate the law. In all cases, where even the appearance of a conflict exists, there may be damage to ABC Federal Credit Union and/or its CUSOs’ reputation for integrity. Ultimately, our success depends on our reputation for integrity -- and we will take whatever steps may be necessary in order to preserve our good name. Accordingly, ABC Federal Credit Union and its CUSOs’ policy is that no employee may engage in activities or acquire interests in ABC Federal Credit Union or any CUSO that potentially creates any such conflict of interest(s). Guidelines respecting certain specific practices and conditions are discussed below. It is not possible to describe every possible conflict of interest. The fact that a particular practice or condition is not prohibited below does not mean that it has been approved. Questions will necessarily arise and they should be addressed to the Ethics Committee. All potential conflicts of interest must be disclosed to the Ethics Committee as provided in Paragraph F below. Employees should not attempt to resolve ambiguous or uncertain issues by themselves. B. Misuse of Position with ABC Federal Credit Union or its CUSOs The fact that a person holds a position with ABC Federal Credit Union or any CUSO may not be used as the basis to seek or accept any business opportunity or other favor or benefit that is not available to persons who are not employed by ABC Federal Credit Union or one of its CUSOs. For example, no representative of ABC Federal Credit Union may accept any offer to buy securities or other types of property or assets at terms which are more favorable than the terms available to the general public if the offer is made because the person is associated with ABC Federal Credit Union. See Sections II and III above. C. Employee Transactions with ABC Federal Credit Union or its CUSOs No employee and no member of an employee's immediate family, may sell or buy property of any kind - having a value greater than $100 - to or from ABC Federal Credit Union or any CUSO, directly or indirectly, except with the express approval of the Ethics Committee, after full disclosure of all relevant facts. Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 13
Page 1 and 2: Compliance Update - I REGULATORY AN
Page 3 and 4: Introductory Notes: Basic Obligatio
Page 5 and 6: performed by boards of directors. T
Page 7 and 8: What if an applicant “volunteers
Page 9 and 10: Please answer the following questio
Page 11 and 12: MULTIPLE ISSUES AND RESOURCES - SOM
Page 13 and 14: • Review of the negative shares r
Page 15 and 16: illustrates how certain provisions
Page 17 and 18: SAMPLE CREDIT UNION BUSINESS PLAN M
Page 19 and 20: EMPLOYMENT AGREEMENT Revise to addr
Page 21 and 22: 13. Evaluate the job performance of
Page 23 and 24: 2. By Employer For No Cause. Employ
Page 25 and 26: Vendor Due Diligence II Security As
Page 27 and 28: Vendor Due Diligence VII TERM AND T
Page 29 and 30: Vendor Due Diligence XII Backgroun
Page 31 and 32: Monitoring the Vendor At a minimum,
Page 33 and 34: NOTE: The BSA also contains a “wh
Page 35 and 36: (5) Confidentiality of reports. SAR
Page 37 and 38: PRIVACY - INFORMATION SECURITY Priv
Page 39 and 40: Disposal of Consumer Reports and Ot
Page 41 and 42: Compliance Update - II REGULATORY A
Page 43 and 44: Introductory Notes: Knowing if you
Page 45 and 46: I. POLICY AND GUIDELINES Portions O
Page 47 and 48: any CUSO. [Gifts may not be accepte
Page 49 and 50: Conference and Seminar Costs Fees f
Page 51: We have stated that there must be a
Page 55 and 56: public, even though, such relatives
Page 57 and 58: and other relatives who live in the
Page 59 and 60: protection, and the reimbursement o
Page 61 and 62: Legal / Compliance Consultation Not
Page 63 and 64: MERGER AND CONSOLIDATIONS ISSUES NO
Page 65 and 66: information of which unauthorized d
Page 67 and 68: A Review of ‘Red Flags’ and wha
Page 69 and 70: Business Depositors: Understanding
Page 71 and 72: WHAT POLICIES, PROCEDURES AND RISK
Page 73 and 74: 16. Conflict of Interest/Code of Et
Page 75 and 76: Union Assessment 33. Identity Theft
Page 77 and 78: Procedures 60. Training Policy See
Page 79 and 80: Also - consider the other changes c
Page 81 and 82: policies, procedures and documents
Page 83 and 84: Underwriting Advertising In July 20
Page 85 and 86: 135-2009 Community Notice // OE/CE
Page 87 and 88: Credit Union’s lien right are not

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