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Your credit union's offices soon (if they aren't already) will be full of cards, chocolates, cookies, fruitcakes, and maybe tickets to the “concert of the year.” Can you accept these? Do you know when you might need to say “no thank you”?
Now is a good time to review your credit union’s Bank Bribery Act policy. The act applies to all credit unions with accounts insured by the National Credit Union Share Insurance Fund.
The National Credit Union Administration (NCUA) issued Interpretive Ruling and Policy Statement (IRPS) No. 87 in 1987 to provide federally insured credit unions with Bank Bribery Act guidelines. IRPS 87-1 gives credit unions some background on the act and recommends procedures to ensure compliance.
Under either 18 U.S.C. § 215(a) or (b), if the item offered or given is greater than $1,000 in value, the offense is a felony punishable by up to 30 years imprisonment and/or a fine of up to $1,000,000 or three times the value of the bribe or gratuity, whichever is greater. If the item of value is $1,000 or less, the offense is a misdemeanor punishable by imprisonment of up to one year and/or a similar fine.
There are situations when it might be appropriate for a credit union employee to receive a business-related gift. Your credit union’s policies should address specific examples.
Make sure you have a clear understanding of the guidelines.
You won’t violate the act if you:
• Accept a gift based on a family relationship;
• Receive a benefit available to the general public; or
• Receive a benefit paid by the credit union as a reasonable business expense.
Next: Examples of appropriate gifts