ELE & Privacy Policies
November 17, 2010
If after reading this notice you have questions, please contact us at 520-795-7950 or 1-800-947-9726, or write to Member Services at Pyramid Federal Credit Union, PO Box 12100, Tucson AZ 85732-2100, or email us firstname.lastname@example.org
The Board of Directors of Pyramid Federal Credit Union (Pyramid FCU) has adopted this luxury expense policy in compliance with the requirements under the American Recovery and Reinvestment Act of 2009 (ARRA) enacted February 17, 2009. The ARRA, which amends certain sections of the Emergency Economic Stabilization Act (EESA), require each recipient of funds under the Community Development Capital Initiative of the Troubled Assets Relief Program to have in place a company wide policy regarding excessive or luxury expenditures during the period that Pyramid FCU participates in the program as identified by the Secretary of the Department of the US Treasury.
It is Pyramid FCU's policy to prohibit such luxury expenditures with respect to the following:
entertainment and eventsoffice and facility renovationsair and other transportation servicesother activities and events that are not reasonable expenditures for conferences, staff training/development, reasonable performance incentives, or other similar activities conducted in the normal course of operations
The CEO and CFO are responsible for the effective implementation of this policy and the CFO shall have the following roles:
Monitor expenditures to ensure compliance of this policy.Document any exceptions to this policy and justify the reasons in a quarterly report to the Board.Recommend any modifications of this policy to the Compensation Committee to ensure it remains compliant with the standards for compensation and corporate governance as defined by the Treasury (31 CFR Part 30) as it may be amended.Ensure the policy is posted on the credit union's website.
This policy specifies prohibited expenditures, approval procedures for expenditure which require prior approval, certification requirements of the CEO and CFO, the reporting of actual or suspected violations and compliance monitoring. This policy applies to all employees of Pyramid FCU.
The types and categories of expenditures covered by this policy include:
Entertainment – defined as an activity whereby any employee using credit union funds for business development purposes relating to a current or prospective member or to further the CU's efforts. Pyramid FCU policy is that all expenses incurred by the credit union should be for corporate purposes and used to develop business of the credit union. Occasional events such as taking members or prospects to sporting events, golf, providing meals, etc., is a necessary part of Pyramid FCU's marketing efforts and are not deemed as luxury expenses or expenses that violate this policy. These expenses should be documented by the credit union through the normal accounts payable process.Conferences/Events – Pyramid FCU encourages its employees and volunteers to attend conferences that are appropriate educational opportunities. These conferences must be related to the financial services industry and have a correlation to the job/position of the person attending. Generally these events are sponsored by vendors, trade associations or other industry related entities. While it may be appropriate for the spouse or other companion to attend these conferences, Pyramid FCU will not pay nor reimburse for any spousal/companion related expenses incurred in attending an event. At times Pyramid FCU may sponsor a table at a local event and it is appropriate for Pyramid FCU to pay for those in attendance whether or not they are an employee, volunteer, or invited guest of Pyramid FCU. Pyramid FCU will not pay for any travel expenses outside of the United States.Employee Recognition/Holiday Parties - Employee recognition/holiday parties are part of the normal employee appreciation process. These events are usually local and are not considered luxury expenses.Board/Management Retreats – Retreats should only be used for educational or business planning purposes. These sessions are held locally and generally incur no overnight lodging expense and focus on strategic planning and/or education.Office and Facility Renovation – Renovations of facilities and offices should be relative to the current business plan of the credit union. An exception will be permitted to address an emergency situation, such as an act of nature, and the expenditure is necessary to make the facility operational for member use. Expenditures for office remodeling, office furnishings or redecoration for any senior executive as defined by EESA, of which the cost exceeds $25,000 is prohibited. This policy does not extend to a "corporate office" remodel which impacts the majority of the facility. Also, it does not extend to new facilities or existing branch remodel.Aviation or Other Transportation Services – transportation provided to staff/volunteers to outlying locations, training opportunities, conferences or other necessary travel should be conducted in the most cost-effective manner. Modes of transportation to be used may consist of personal vehicles, auto rentals, taxis and commercial airlines. The selection of the transportation services will factor in cost, efficiency and timeliness of travel. Expenditures for the use of an automobile by credit union employees must be reasonable. Private air services are not allowed.
C. Expenditures Requiring Prior Approval
The following expenses require pre-approval by the CEO or CFO if the amount exceeds $5,000 and are not otherwise prohibited in this policy:
Entertainment, conferences, board/management retreats, or other events.
Office and facility renovation.
Aviation or other transportation services.
Other similar activities or events for which Pyramid FCU anticipates incurring expenses or reimbursing employee(s) for incurred expenses.
Prior approval is not required for the following expenditures:
To correct or fix an emergency or hazardous condition.
To comply with building codes and ordinances.
To satisfy legal, contractual, or regulatory requirements.
Expenses incurred under the Board-approved annual budget.
D. Administration and Certifications
The Credit Union's CFO is responsible for the day-to-day administration of this policy and the CEO is accountable for the overall adherence to this policy and must approve any exceptions. Strict adherence to this policy is required of all employees. Failure to adhere to this policy will result in appropriate corrective action, up to and including immediate termination of employment.Employees must report any suspected violations of this policy in writing to their immediate manager, the CFO or the Supervisory Committee. The report should include the names and details of the individuals involved and the suspected violation. All reports will be promptly investigated and corrective action will be taken as appropriate. Pyramid FCU prohibits retaliation against anyone who has reported a suspected violation or who participates in the investigation of a suspected violation.Within 90 days of completion of each fiscal year the CEO and CFO shall certify to the Department of the Treasury and any other required regulatory body that Pyramid FCU and its employees have complied with this policy during the fiscal year and that any expenses requiring approval were properly approved. The first report will only cover the time period from when the CDCI funds were first received (9/24/2010) through the end of the year.
If after reading this notice you have questions, please contact us at 520-795-7950 or 1-800-947-9726, or write to Member Services at Pyramid Federal Credit Union, PO Box 12100, Tucson AZ 85732-2100, or email us at email@example.com
INFORMATION WE COLLECT ABOUT YOU
We collect nonpublic personal information about you from the following sources:
Information we receive from you on applications and other forms.
Information about your transactions with us or our affiliates: SOSystems, Equifax, ChexSystems, SourceCorp, eFunds, Certegy, iPay Technologies.
Information we receive from a consumer reporting agency.
Information obtained when verifying the information you provide on an application or other forms; this may be obtained from your current or past employers, or from other institutions where you conduct financial transactions
We may disclose all of the information we collect, as described above, as permitted by law.
PARTIES WHO RECEIVE INFORMATION FROM US
We may disclose nonpublic personal information about you to the following types of third parties:
financial service providers, such as securities broker-dealers.
Non-financial companies, such as consumer reporting agencies, data processors, check/share draft printers, financial statement publishers/printers, plastic card processors, government agencies, and mailhouses.
Pyramid Federal Credit Union and its affiliates may also work closely to offer products and services to meet member needs. As a result, we may also share your nonpublic personal information with each other as permitted by law.
DISCLOSURE OF INFORMATION TO PARTIES THAT PROVIDE SERVICES TO US
In order for us to conduct the business of the credit union, we may disclose all of the information we collect, as described above, to other financial institutions with whom we have joint marketing agreements, to other companies that provide marketing services on our behalf, or to nonaffiliated third parties for the purposes of processing and servicing transactions that you request or authorize, so that we may provide members competitive products and services. We may also disclose nonpublic personal information about you under circumstances as permitted or required by law. These disclosures typically include information to process transactions on your behalf, conduct the operations of the credit union, and follow your instructions as you authorize, or protect the security of our financial records. To protect our members' privacy we only work with companies that agree to maintain strong confidentiality protections and limit the use of information we provide. We do not permit these companies to sell the information we provide to third parties. Members who prefer that we not disclose nonpublic personal information about them to nonaffiliated third parties may opt out of these disclosures. To opt out, members may call us at 520-795-7950 or 1-800-947-9726. Members may also notify us in writing by mailing a request to PO Box 12100, Tucson AZ 85732-2100, or by electronic mail firstname.lastname@example.org.
DISCLOSURE OF INFORMATION ABOUT FORMER MEMBERS
If you terminate your membership with Pyramid Federal Credit Union, we will not share information we collect about you, except as permitted or required by law.
HOW WE PROTECT YOUR INFORMATION
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, or procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
INTERNET ACCESS AND SECURITY
Pyramid Federal Credit Union strives to use the latest technology to protect your account information from exposure to unauthorized persons. Listed below are pieces of this security system: We require an account number and password to access your account. We use 128-bit encryption to process your transactions and rely upon industry standard "secure socket layer" (SSL) encryption to process your transactions. Email should never be used to communicate account or password information. Email is not a secure method of conveying private or personal information. You should not store your account number and password on your computer using Windows software. You should not store secured pages in your cache or leave your computer unattended while logged into our web site. We do use "cookies" to verify who you are while using online banking; these cookies will expire after a brief time with no activity.
WHAT MEMBERS CAN DO TO ENSURE PRIVACY AND ACCOUNT SECURITY
Pyramid is committed to protecting the privacy of its members. Members can help by following these simple guidelines:
Protect your account numbers, plastic card numbers, PINs (personal identification numbers) or passwords. Never keep your PIN with your card, which can provide free access to your accounts if your card is lost or stolen.Use caution when disclosing your account numbers, social security numbers, etc. to other persons. If someone calls you explaining the call is on behalf of the credit union and asks for your account number, you should BEWARE. Official credit union staff will have access to your information and will not need to ask for it.Keep your information with us current. If your address or phone number changes, please let us know. It is important that we have current information on how to reach you. If we detect potentially fraudulent or unauthorized activity or use of an account, we will attempt to contact you immediately.
PROTECTING CHILDREN'S INFORMATION PRIVACY