Spotlight for Recruiting Professionals, August 17, 2011
Effective January 1, 2012, the U.S. Treasury Department will no longer sell U.S. Savings Bonds through financial institutions. Instead, the Treasury Department will only sell U.S. Saving Bonds through its website. In light of this announcement, financial institutions may need to re-evaluate whether they will continue to have federal affirmative action obligations, according to Jackson Lewis LLP.
Under Executive Order 11246 and its implementing regulations, financial institutions may become subject to federal affirmative action requirements in several ways, Jackson Lewis reports. Financial institutions must maintain written affirmative action plans if they have at least 50 employees and:
- Are issuing and paying agents for U.S. Savings Bonds and Notes in any amount
- Serve as a depository of government funds in any amount
- Hold a prime or subcontract with the federal government of at least $50,000
Jackson Lewis adds that the Office of Federal Contract Compliance Programs (OFCCP) has taken the position that financial institutions that participate in Federal Deposit Insurance Corporation or National Credit Union Association programs are subject to the agency’s jurisdiction. Accordingly, financial institutions may continue to be subject to the federal requirements despite the Treasury Department’s announcement.