Affirmative Action Required??

System

If we sell US Savings Bonds, must we have an affirmative action plan in place? I have been told the law interprets selling/redeeming as transactions/contract with the federal government and therefore require an affirmative action, even if the employer is less than 20 employees.

Gillian

I don't know where you heard what you heard but it's a real stretch as far as I am concerned. Besides, you don't have to have a written plan unless you have 50 employees and $50,000 in contracts. That's a lot of savings bonds.

PR in WA

I agree with Gillian - that does seem like quite a stretch, but in looking at the federal regulations, which can be found at the OFCCP's website at: [url]www.dol.gov/dol/esa/public/ofcp_org.htm[/url] - they do state in Part 60-1.40(a)(1)(iii) and again in Part 60-2.1(b) that "Each nonconstruction (supply and service) contractor must develop and maintain a written affirmative action program for each of its establishments, if it has 50 or more employees and: is a financial institution which is an issuing and paying agent for U.S. savings bonds and savings notes in any amount." I believe this only applies to financial institutions. So if your business is a financial institution, then yes, you would have to develop and maintain a written affirmative action program.

je

Kriss, the rule is 50 employees, financial institution that sells savings bonds. So if you have less than 20, you are just fine.