No one is in a position to provide a definitive opinion at this time. The Executive Order itself is unclear (and some believe purposefully ambivalent) as to the reach of the minimum-wage requirement, leaving the Department of Labor to issue implementing regulations by October 1, 2014. In the past, the Department of Labor (“DOL”) has declared that financial institutions are “federal contractors” due to their receiving federally-insured deposit insurance, selling U.S. savings bonds and notes, and serving as depositories of federal funds. See Office of Federal Contract Compliance Programs (OFCCP) Executive Order 13496 Frequently Asked Questions. Notably, the FDIC in the past has objected to these DOL interpretations, but that has not deterred the DOL from sticking to its interpretation. While the Executive Order poses a similar question in a different context, it remains entirely possible that the DOL will extend its interpretation regarding financial institutions to the Executive Order.