Who is subject to OFCCP enforcement?

2019-10-23

Who is subject to OFCCP enforcement?

All contractors and subcontractors who hold a federal contract in excess of $10,000 are subject to regulatory requirements under one or more of the laws enforced by OFCCP depending upon the amount of the contract.

What does the OFCCP regulate?

OFCCP holds those who do business with the federal government (contractors and subcontractors) responsible for complying with the legal requirement to take affirmative action and not discriminate on the basis of race, color, sex, sexual orientation, gender identity, religion, national origin, disability, or status as a …

Does Executive Order 11246 apply to banks?

Banks are most familiar with Executive Order 11246 mandating nondiscrimination and affirmative action for covered federal contractors. A bank is a federal contractor under EO 11246 if: It has a bona fide federal contract; It is a fund depository (i.e., typically involving Treasury Tax & Loan accounts); or.

What is OFCCP CSAL?

The Corporate Scheduling Announcement List (CSAL) is a courtesy notification to an establishment selected to undergo a Compliance Review (Establishment Review), Corporate Management Compliance Evaluation (CMCE), Functional Affirmative Action Program (FAAP) Review, Section 503 Focused Review, VEVRAA Focused Review.

What is the difference between OFCCP and EEOC?

The main difference between OFCCP and EEOC is that OFCCP is an organization that monitors whether or not employers that work with the federal government are following proper practices that are non-discriminatory in nature whereas EEOC investigates employers and businesses that are not associated with the federal …

What can I expect from an OFCCP audit?

An OFCCP audit includes all aspects of the employment process, including, sourcing, hiring, compensation, promotions, transfers, and termination.

What is OFCCP audit?

An OFCCP audit includes all aspects of the employment process, including, sourcing, hiring, compensation, promotions, transfers, and termination. If your company is facing an OFCCP audit for the first time, it can be helpful to know what to expect.

Why are banks considered federal contractors?

Because the guidance is written in broad terms, it could be construed to mean that banks are considered federal contractors because they obtain a “service” from the federal government in the form of FDIC insurance and thus have a “service agreement” for the purposes of the vaccination requirement.

Are bankers federal contractors?

As we know, the Department of Labor has historically taken the position that banks are federal government contractors because we obtain “insurance” through our FDIC relationship.

What is a scheduling letter?

The Scheduling Letter and Itemized Listing is the OMB-approved letter OFCCP sends to start the evaluation process and to request submission of specific contractor records. Upon receipt, a contractor is required to submit its AAPs and supporting data within 30 days.

Is the OFCCP part of EEOC?

The Office of Federal Contract Compliance Programs (OFCCP) and the Equal Employment Opportunity Commission (EEOC) are the two arms of the federal government that have authority over concerns of discrimination relating to employment.

What happens if you fail an OFCCP audit?

Failure or refusal to submit an affirmative action plan or cooperate in the compliance review process can lead to debarment (cancelation of the federal contracts from all locations), a significant amount of local and national bad publicity, and the ability of the OFCCP to instruct the federal contracting agency not to …