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.