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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 16
and other relatives who live in their homes serve as officers, directors, trustees or other fiduciaries. Written disclosures regarding this requirement shall be provided upon the commencement of an employee's employment and annually thereafter. Disclosures are kept on file with the Personnel Officer. VII. ACKNOWLEDGMENT OF AGREEMENT TO COMPLY WITH ABC FEDERAL CREDIT UNION AND ITS CUSO’s POLICY REGARDING CONFLICTS OF INTEREST/CODE OF ETHICS Each director, officer and employee of ABC Federal Credit Union or any CUSO, shall sign a Certificate of Agreement to comply with this policy. Persons who are appointed or employed after this policy is adopted shall sign such a Certificate upon their appointment or employment. At times in the future when this policy is amended, all such persons shall also acknowledge and agree to the changes by written certificate. This certification will be maintained in a file with the Personnel Officer. VIII. MAINTENANCE AND AMENDMENT OF POLICY IX. THIS POLICY IS FOR THE BENEFIT OF ABC FEDERAL CREDIT UNION AND ITS CUSOs X. General Obligations of Senior Management XI. Reporting Violations of this Policy or any other Conduct Detrimental to the Credit Union: Compliance and Ethical Issues Involving Credit Union Boards: Section Topic Page A Introduction 1 B Limited Insurance Benefits 1 C Honorary Titles are Just that “Honorary Titles!” 3 Reserved for Further Matters Reserved for Further Matters Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 17
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 and 52: We have stated that there must be a
Page 53 and 54: IV. POLICY REGARDING CONFLICTS OF I
Page 55: public, even though, such relatives
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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