regulatory and compliance issues and considerations

elations is confidential. Credit Union related persons including Volunteers, Committee
Members and Employees may not disclose such information to other persons except to
the extent that disclosure is necessary to carry out assigned responsibilities. Questions
about disclosing information should be addressed to the President.
B. Requests for Information by News Media, Financial Analysts, Financial
Institutions and Others
From time to time employees may receive requests for information about ABC Federal
Credit Union and/or any of its CUSOs or its members or suppliers from the news media,
investment analysts, financial institutions, or others. All such inquiries should be referred
to the President. No employee may respond to such inquiries unless expressly directed
to do so by the President.
C. Information May Not Be Used for Personal Purposes
No employee may use confidential information which might reflect upon the investment
value or future market value of any business enterprise for purposes of personal
advantage or to provide an advantage to others. In particular, information received in
the course of employment with ABC Federal Credit Union or any CUSO, which is not
available to the general public may never be used as the basis for making any decision
to buy or sell stocks or other securities. Likewise, such information may not be used in
giving investment advice to others.
VI. DISCLOSURE OF PERSONAL FINANCIAL INTERESTS AND FIDUCIARY
OBLIGATIONS
Note: This provision is not specifically required, and may be subject to
assessment based on employment agreements as well as state laws as
applicable.
Employees may be required to disclose certain of their outside financial interests and
fiduciary obligations to the Ethics Committee as provided in this Section. In addition, the
following persons may be requested to provide complete financial statements on a
periodic basis: Chief Executive Officer, President, Senior Vice President & Executive
Vice President. Employees must disclose all interests owned in business enterprises,
including corporations, partnerships and proprietorships, if such interests have a fair
market of $10,000 or more, or if more than a 10% interest in an enterprise is owned.
Interests owned by the spouse and minor children of an employee and interests owned
by other relatives who live in the home of an employee must be disclosed. "Interests
owned" include interests over which an employee exercises voting control. No
investments in publicly traded securities are required to be reported, unless an
employee owns more than 5% of any such class of securities. Employees must disclose
all firms, associations, trusts, estates or other beneficiaries for which they, their spouses
Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved.
Revised February 2010
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