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Affirmative Action Policy/Program & Savings Bonds

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Question: 
We are an institution with 60 employees and currently have an Affirmative Action Policy/Program in place. We received information from Treasury Direct stating that as of January 1, 2012- paper savings bonds will no longer be sold at financial institutions. As I understand, the two main keys for Affirmative Action are greater than 50 employees and selling US Savings Bonds. Since we will no longer sell the bonds, is our institution required to continue to redeem them? Secondly, without issuing savings bonds, would we be required to maintain our Affirmative Action Policy/Program?
Answer: 

Generally speaking, any business or organization that (1) holds a single Federal contract, subcontract, or Federally assisted construction contract in excess of $10,000.00; (2) has Federal contracts or subcontracts that combined total in excess of $10,000.00 in any 12-month period; or (3) holds Government bills of lading, serves as a depository of Federal funds, or is an issuing and paying agent for U.S. savings bonds and notes in any amount will be subject to requirements under one or more of the laws enforced by OFCCP.

If you remain a paying agent for savings bonds or serve as a depository for any federal funds, you will remain covered.

First published on BankersOnline.com 12/12/11

First published on 12/12/2011

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