Baird Holm LLP
Kelli P. Lieurance
January 5 2011
The Office of Federal Contract Compliance Programs (OFCCP), a division of the Department of Labor (DOL), has recently stepped up its enforcement efforts related to affirmative action. Indeed, since President Obama’s inauguration, the OFCCP has nearly doubled in size and budget—which means that it has more manpower and funds to conduct compliance reviews and audits. In 2008 alone, prior to any change in administration, the OFCCP conducted more than 5,000 compliance reviews which resulted in a record recovery of $67.5 million dollars in financial remedies. For FY 2009, although the OFCCP changed the way in which it reported monetary recovery, its actions nevertheless showed aggressive enforcement. Such aggressive enforcement will only continue into 2011.
What is Required?
As you may know, a financial institution that serves as a depository of government funds in any amount, or who acts as an issuing and paying agent for U.S. Savings Bonds and Notes, is required to prepare and put into place Affirmative Action Programs (AAPs) pursuant to Executive Order 11246, as are federal contractors with 50 or more employees and federal contracts of at least $50,000.
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