Privacy Policy

The Lower East Side People’s Federal Credit Union (LESPFCU) shares nonpublic personal information about members only with the following non-affiliated third parties:

  • Auditor (Fontanella and Babbits, CPA)
  • Check Printing (Liberty Check Printer)
  • Collection Agencies (Stephen Einstein and Associates)
  • Credit Bureaus (Equifax, Experian, Transunion)
  • Data Processing (EPL Inc.)
  • Examiner (NCUA)
  • IRS
  • State Data Matching Program

LESPFCU collects non-public personal information about our members from the following sources:

  • Information we receive from loan applications or other forms
  • Information about a member’s transactions with LESPFCU or others; and
  • Information we receive from a consumer reporting agency.

The information collected is used by LESPFCU personnel only to provide products or services requested by a member and it will not be disclosed to anyone, except as permitted by law.

LESPFCU restricts access to a member’s personal and account information to those employees who need to know that information to provide products or services. LESPFCU maintains physical, electronic, and procedural safeguards that comply with federal regulations to guard our members’ nonpublic personal information.

LESPFCU will provide an initial notice of the privacy policy at the time a “continuing relationship” with a member is established (when the account is open) and it will be enclosed with the Welcome letter that is sent to new members. Another notice of the privacy policy will be sent to all the membership once a year.

Notice of LESPFCU’s Privacy Policy

[1] The Lower East Side People’s Federal Credit Union (LESPFCU) respects your privacy, and therefore we do not disclose any nonpublic personal information about you to anyone, except as permitted by law.

[2] If you decide to terminate your membership or become an inactive member, we will adhere to the privacy policies and practices described in this notice.

[3] LESPFCU restricts access to your personal and account information to those employees who need to know that information to provide products and services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.

Children’s Online Privacy Protection Rule

The Children’s Online Privacy Protection Act (COPPA) was passed to give parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowingly collect information from, children under the age of 13.  LESPFCU websites and online services are not directed to children under the age of 13, nor is information knowingly collected from them.

For additional information on COPPA protections, please see the FTC website at www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online

Web Site

LESPFCU’s website currently provides general information about the credit union’s products and services, locations, and hours. The site is not designed to collect personally identifying data on visitors and does not require the disclosure of any personally identifying information, except through home banking and online loan applications initiated by the member

 Web Site Notice of LESPFCU’s Privacy Policy

[1] The Lower East Side People’s Federal Credit Union (LESPFCU) respects your privacy. Through our Web site, we strive to provide valuable information to you about how we may serve you, and whether you are a valued existing member or someone looking for community financial services, we hope our site answers your questions about our products and services, locations, and hours.

[2] As a visitor to our Web site, you need not be concerned about the privacy of your personal information. Our site is not designed to collect personally identifying data on visitors.

[3] Our Website does not require you to disclose any personally identifying information. If, however, you choose to contact us via e-mail, please keep in mind that your e-mail address, and any other information your e-mail header shows about you, such as your name or organization, will be revealed to us in the e-mail. We pledge, however, that when you communicate with us via e-mail, we will use your e-mail information only for the specific purpose of responding to your comments or questions. Your e-mail address will not be sold, nor will it be shared with others outside the credit union unless we are compelled to do so by law.

Lower East Side People’s Federal Credit Union Excessive or Luxury Expenditure Policy

A. Purpose

The Board of Directors of The Lower East Side People’s Federal Credit Union, (the “Credit Union”) adopted this Excessive or Luxury Expenditure Policy (“Policy”) to be in compliance with the requirements under the American Recovery and Reinvestment Act of 2009 (“ARRA”). The ARRA, which amends certain sections of the Emergency Economic Stabilization Act of 2008, requires each recipient of funds under the Community Development Capital Initiative Program of the Troubled Assets Relief Program to have in place a company-wide policy regarding excessive or luxury expenditures, as identified by the Secretary of the Department of the U.S. Treasury.

It is the Credit Union’s policy to prohibit excessive or luxury expenditures on

1. entertainment and events, 2. office and facility renovations, 3. aviation or other transportation services, and 4. other activities or events that are not reasonable expenditures for conferences, staff development, reasonable performance incentives, or other similar measures conducted in the normal course of our business operations.

This Policy applies to all directors and employees of the Credit Union. Additionally, this Policy specifies prohibited expenditures, approval procedures for expenditures which require prior approval, certification requirements of the Chief Executive Officer (“CEO”) and Chief Financial Officer (“CFO”), the reporting of actual or suspected violations, and compliance monitoring.

B. Scope

The types and categories of expenditures covered by this Policy are as follows:

Entertainment: Entertainment is deemed as an activity that an employee or executive officer would use corporate funds for business development purposes relating to a current customer or prospective customer or to further enhance the Credit Union’s marketing efforts. Our policy is that all expenses incurred by the Credit Union should be for Credit Union purposes and used to develop the business of the Credit Union. Events and parties focused on members for the purpose of attracting or retaining their business are not deemed as “luxury” or a violation of this Policy. These expenses should be documented and detailed as to the benefit derived by the Credit Union through the normal accounts payable process.

Conferences: We encourage our employees and officers to attend conferences that are appropriate educational opportunities. These conferences must be related to the financial services industry and have a direct correlation to their job.

Employee Recognition/Holiday Parties: Employee recognition/holiday parties are part of the Credit Union’s employee appreciation process. These events should be local in geographic nature and reasonable in cost.

Board/Management Retreats: Retreats shall only be used for educational or business-planning purposes. Board education is a vital part of maintaining and keeping a dynamic director base, and this Policy should not limit a retreat that is focused on strategic planning or education.

Office and Facility Renovations: Renovations of facilities and office spaces should be relative to the approved project and 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 customer use.

Aviation or Other Transportation Services: The Credit Union will reimburse employees and directors for reasonable transportation expenses incurred for travel to and from pre-approved conferences, planning retreats or other business purposes. Reasonable airfare is considered coach travel class. The Credit Union will not reimburse for first or business class travel. Private air services are not allowed under any circumstances. The Credit Union will not reimburse employees or directors for aviation or other travel-related expenses associated with any spouse or guest that may accompany them on a business trip. This would include travel, food and lodging.

C. Prohibited Expenditures

The following expenditures are deemed excessive and are prohibited:

Office and Facility Renovations: Expenditures for office furnishings, remodeling, or redecoration for any senior executive officer as deemed in the EESA (“SEO”), the aggregate cost of which exceeds $25,000. This prohibition does not extend to a corporate relocation or remodeling impacting a majority of the corporate offices or a newly-constructed branch, branch renovation, or branch relocation.

Aviation Services: Expenditures for the use of a private airplane are prohibited.

D. Expenditures Requiring Prior Approval

General: The following expenditures require the pre-approval of the CEO or the CFO if the amount exceeds $1,000 and are not otherwise prohibited by Section C of this Policy:

1. entertainment, conferences, board/management retreats, or other events; 2. office and facility renovations; 3. aviation or other transportation services; and 4. other similar items, activities, or events for which the Credit Union may reasonably anticipate incurring expenses or reimbursing an employee for incurring expenses.Employee Recognition/Holiday Parties: Any expenditure, regardless of amount, for employee recognition or holiday parties must be approved in advance by the CEO or CFO.

Exceptions: Notwithstanding the foregoing, prior written approval is not required for the following expenditures:

1. to remediate emergency or hazardous conditions; 2. to comply with building codes and ordinances; 3. to satisfy legal, contractual, or regulatory requirements; and 4. under the Board-approved annual operating budget.

E. Administration and Certifications

The CFO is responsible for the day-to-day administration of this Policy, and the CEO is accountable for overall adherence to this Policy and must approve any exceptions. Strict adherence to this Policy is mandated for all Credit Union employees.

Within 90 days of the completion of each fiscal year of the Credit Union, the CEO and CFO of the Credit Union shall certify that the Credit Union and its employees have complied with this Policy during the fiscal year or since the date of enactment of this Policy and that any expenses requiring approval were properly approved.

F. Reporting of Violations

Anyone who becomes aware of a suspected or actual violation of this Policy, whether intentional or inadvertent, shall report such violation in writing to the Chairperson of the Credit Union’s Supervisory Committee. Employees are expected to self-report any violations concerning the employee. The Chairperson will discuss the suspected or actual violation at the next regularly-scheduled meeting of the Supervisory Committee, who will investigate the suspected or actual violation of this Policy in accordance with its procedures established for investigating complaints regarding improprieties in the Credit Union’s accounting, internal accounting controls, or auditing matters, and report to the Board at its next regularly scheduled meeting with respect to any reported violations and any recommended corrective actions. Approved: September 27, 2010


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