As a financial institution, other than having a direct contract with the federal government or a subcontract, you may be considered a federal government contractor or subcontractor and covered under OFCCP’s jurisdiction if any of the following apply to you: 1) if you are a depository of federal government funds in any amount; 2) if you are an issuing and paying agent for U.S. Saving Bonds and savings notes in any amount; 3) if you are a reinsurer for the Federal Employees Group Life Insurance (FEGLI) program, or 4) if you are a financial institution with federal share and deposit insurance (i.e. FDIC and NCUA). OFCCP explicit defines “nonpersonal” services to include insurance agreements. I would advise that you check if any of the above conditions apply to your credit union and if your participation in the Section 184 – Indian Housing Loan Guarantee program triggers any of these. For more information on OFCCP’s jurisdiction over financial institutions, check out their Jurisdiction Frequently Asked Questions.
You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.