Topic: Affirmative Action Plans (AAPs)
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We are required to file an EEO-1 due to being a federal contractor, but we have fewer than 100 employees. Are we subject to the Illinois Equal Pay Act of 2003?
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Yes, your bank is subject to the Illinois Equal Pay Act of 2003, which applies to any employer with employees in Illinois. However, we believe that you are exempt from the equal pay registration certificate requirements in Section 11 of the Equal Pay Act, since you have fewer than one hundred employees — even though…
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Since banks are considered federal contractors for purposes of Affirmative Action Plans, are banks subject to the Presidential Executive Order on “Combating Race and Sex Stereotyping” in training programs?
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A federal district court has granted a nationwide preliminary injunction blocking the enforcement of the Presidential Executive Order on “Combating Race and Sex Stereotyping” (Executive Order 13950) with respect to the requirements for government contractors. Consequently, although financial institutions with federal share and deposit insurance arguably should be considered “government contractors” under Executive Order 13950,…
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Since banks are considered federal contractors for purposes of Affirmative Action Plans, are banks subject to the Presidential Executive Order on “Combating Race and Sex Stereotyping” in training programs?
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We believe that financial institutions with federal share and deposit insurance will be subject to the Presidential Executive Order on “Combating Race and Sex Stereotyping” (Executive Order 13950). Executive Order 13950 requires “Government contracting agencies” to include in every “Government contract” provisions related to workplace training that combat race and sex stereotypes. While “Government contract”…
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Are we required to maintain an Affirmative Action Plan (AAP) if we no longer sell savings bonds? We do redeem savings bonds.
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Yes, the AAP requirements apply to your bank. The AAP requirements apply to banks with more than fifty employees that either issue or redeem U.S. bonds or hold U.S. government deposits. While your institution no longer sells savings bonds, its redemption activities do trigger the AAP requirements (assuming that your bank still has more than…
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Who is the state “employment service delivery system” for purposes of fulfilling our job listing requirements under the Vietnam Era Veterans’ Readjustment Act of 1972 (VEVRAA)?
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We believe that the Illinois Department of Employment Security (IDES) labor exchange website (www.IllinoisJoblink.com) is the appropriate state “employment service delivery system.” The Department of Labor states that listing employment openings with the “state workforce agency job bank … will satisfy the requirement to list jobs with the local employment service delivery system.” Because the…
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Do we need to have an Affirmative Action Plan (AAP) in place once we have hit the 50 employee mark, but do not sell any government savings bonds (but do still redeem them)?
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We believe that the affirmative action plan (AAP) requirements would apply to a bank with more than fifty employees that either issues or pays U.S. bonds or has any U.S. government deposits. The AAP requirements apply to “[e]ach nonconstruction contractor . . . if it has 50 or more employees and: . . . (iii) Serves as a depository of Government funds in…
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Are financial institutions that sell savings bonds considered federal contractors subject to affirmative action program requirements?
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Most federally-insured banks with more than fifty employees are considered federal contractors subject to the affirmative action program (AAP) requirements (1) because they contract with the federal government to provide their insurance and (2) because they either have deposits of federal funds or act as agents for federal bonds. See Office of Federal Contract Compliance…