Financial Institutions covered by the National Credit Union Association (NCUA) with deposit insurance are required to comply with the Affirmative Action Program (AAP) obligations under Executive Order 11246, VEVRAA, and Section 503.
Credit Unions with insured deposits covered by the NCUA, are required to prepare and maintain a written affirmative action plan for women and minorities under Executive Order 11246, for persons with disabilities under Section 503 of the Rehabilitation Act of 1973, and for veterans under Vietnam Era Veterans' Readjustment Assistance Act of 1974.
These three programs, governed by the Office of Federal Contractor Compliance Programs, also mandate federal contractors to document and evaluate their affirmative action programs through reports of workforce statistics and analysis of their employment decisions and actions.
The regulations define a government contract as any agreement between any contracting agency and any person for the purchase, sale, or use of personal property or nonpersonal services. The term "nonpersonal services" includes services that provide insurance and federal depository.
This definition explicitly includes agreements for insurance. Therefore, financial institutions with federal share and deposit insurance are considered to be government contractors, and must comply with affirmative action regulations.
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