regulatory and compliance issues and considerations

D. Foreclosures and Repossessions
Employees and their immediate family are prohibited from purchasing property which
ABC Federal Credit Union or any CUSO, is foreclosing or has acquired through
foreclosure or otherwise without first obtaining prior approval of the Ethics Committee.
This prohibition includes not only a direct purchase from ABC Federal Credit Union or
any CUSO, but also an indirect or "straw" purchase arranged through a dealer or any
other person or third party. Employees and their immediate family are prohibited from
purchasing any trust property administered by ABC Federal Credit Union or any CUSO.
E. Guidelines Respecting Transactions Between Employees and Persons Outside
ABC Federal Credit Union any CUSO
Employees of ABC Federal Credit Union or any CUSO, may not engage in conduct or
activities outside their employment that are disloyal, competitive with or damaging to
ABC Federal Credit Union or any CUSO.
Guidelines about certain specific practices and situations are set out below.
1. OUTSIDE EMPLOYMENT. Employees are expected to devote their full time,
attention and abilities to ABC Federal Credit Union or its CUSOs’ interests during
regular hours of employment and for whatever additional time may properly be
required. No other employment or activities may be undertaken, if they will impair
an individual's ability to meet regular job responsibilities. Any outside
employment must be approved in writing in advance by the Ethics Committee.
No employment by a competitor of ABC Federal Credit Union or any CUSO will
be approved.
2. OUTSIDE BUSINESS VENTURES AND INVESTMENTS. All business ventures
and certain types of investments made by employees and members of their
immediate families must be disclosed as provided in Section VI below.
Employees may not, without the prior approval of the Ethics Committee, engage,
directly or indirectly, in business ventures or make investments in companies that
do business with or compete with ABC Federal Credit Union or any CUSO.
Employees who have interests in companies that do business with ABC Federal
Credit Union or any CUSO may not represent ABC Federal Credit Union or any
CUSO in any way business transactions between those companies and ABC
Federal Credit Union or any CUSO. This paragraph does not apply to purchases
of less that 5% of any class of publicly traded securities.
3. PERSONAL LOANS INVOLVING MEMBERS OR VENDORS. No employee
may borrow any money from or lend any money to any members or any others
who do business with or may do business with ABC Federal Credit Union or any
CUSO. Officers and employees may borrow from or lend to members of their
families, however, and they may borrow from companies which make such loans
in the ordinary course of their business on the terms available to the general
Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved.
Revised February 2010
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