Just got asked by one of the staff, and I couldn't answer, so I need your help. Our staf size is approaching 50 employees. Do we need an affirmative action plan? Does it have to be 50 full time employees, or a mix of part time and full time? Anyone have any links I can go to to find what we would need in such a policy, or an example of one? Does this need to be audited annually?

I know I have been asking alot of questions today, but it has been one of those days! Maybe this afternoon, I can get to some file review, after my FINCENS work...

I've not found anything definitive, but we outsourced the writing of our AAP and they recommended we use total employees not FTE's in determining the 50

You should probably check your state laws. Our state laws provide that employer is someone who employs one or more persons.

I should clarify that an employee can bring a discriminatory action against an employer who has one or more employees.

The affirmative action regulations require banks with 50 or more employees to develop and implement a formal written AAP if they are a depository of government funds in any amount or an issuing and paying agent U.S. saving bonds and saving notes. Nearly all financial institutions, which are members of the federal banking systems, will have government funds deposited to them from time to time. Many savings and loan organizations and other financial institutions will also meet these criteria. In the eyes of the OFCCP, simply having one dollar in government deposits during the calendar year will require the organization to maintain a written affirmative action plan.

Additionally, many banks hold transfer authority for the US saving bonds, as do most credit unions. Similarly private corporations, brokerages, and other investment organizations also frequently have such transfer agency authority for U.S. savings bonds and offer the sale and redemption of those bonds to employees and customers as a service or courtesy.

Banks covered under Executive Order 11246 must maintain three different types of written AAPs for: (1) minorities and women; (2) disabled individuals; and (3) Vietnam era, special disabled, and other protected veterans.

Yes, as soon as your employee numbers reach 50, and you are a government contractor of more than $50,000 you must prepare an affirmative action plan. Virtually all banks are government contractors if you handle TT&L and/or savings bonds totaling $50,000 or more in one year.

The employee number of 50 is 50 people, regardless of the number of FTE that you have.

If you'll send me your e-mail address, I be glad to send you guidelines for Affirmative Action Plans, as well as useful websites.

Gayla,my e-mail is ncarli@dsbank.com. Thanx in advance!

I would appreciate the information as well. Thanks.

ltuttle@northbaybancorp.com