The Board of Directors of Gateway Community Federal Credit Union pursuant to the provisions of Section 111(d) of the Emergency Economic Stabilization Act of 2008, as amended by the American Recovery and Reinvestment Act 2009 ("EESA"), is adopting this Excessive and Luxury Expenditure Policy. This policy sets standard for expenditures by Gateway Community Federal Credit Union, (collectively the "Credit Union") that would be deemed excessive or luxury expenditures which are not permitted and would violate this policy against such excessive or luxury expenditures in four categories of activities: (1) entertainment or events, (2) office and facility renovations, (3) aviation or other transportation services, and (4) other items, activities or events which the Credit Union reasonable anticipates incurring expenses. The Secretary of the U.S. Department of the Treasury has adopted interim final regulations implementing Section 111(d) of ESSA, and may adopt future regulations which may require modification of this policy.

     The Credit Union’s historic practice has been to carefully control expenses and avoid unnecessary or excessive expenditures of the Credit Union funds. We expect officers and employees to continue this practice. With respect to the matters specifically referenced in Section 111(d) of ESSA, the Board of Directors of the Credit Union provides the following guidance:

1. Customer and Goodwill Entertainment or Events. The Credit Union supports events in its service area at a level consistent with the Credit Union’s maintaining and appropriate public image and support of worthy causes. Use of Credit Union funds for such purposes shall be approved as provided in the Credit Union policies. If a particular expenditure for an event exceeds $10,000.00, the expenditure must be approved by the president of the Credit Union. Entertainment of customers or potential customers of the Credit Union must be conducted in accordance with the Credit Union’s expense policies and no expenditure for the benefit of a customer as entertainment may exceed $2,500.00 per event, per individual entertained without approval of the president of the Credit Union.

2. Employee Recognition/Holiday Parties. Management of the Credit Union may plan employee recognition events and holiday parties to continue to support employee morale. These events shall be held within the State of Montana to the extent reasonable or adjacent states at a cost consistent with past practices and generally not to exceed $100.00 per person for a single event without the approval of the president of the Credit Union.

3. Board/Management Retreats. Board and management retreats should only be held where the focus is educational and business related and should be geographically within the State of Montana or its adjacent states, except where educational or business events hosted by third parties are in other locations. Attendance at meetings of Credit Union associations or similar professional or trade functions are encouraged and permitted by this policy even if they are outside the geographical boundaries set forth above.

4. Aviation and Other Transportation Services. Except where circumstances require, employees, officers and directors using aviation transportation for the Credit Union’s business are to use scheduled commercial air services wherever possible. All domestic scheduled flights should be arranged using economy fares, unless the president of the Credit Union approves the use of business or first class bookings. Use of the mode of transport should be determined based upon the purpose of the trip, convenience and overall cost.

5. Office and Facility Renovations. Office and facility renovations should be evaluated based upon the official status of the person occupying the space, and whether the space is generally accessible by customers of the Credit Union. The renovations must be consistent with the performance of the officer or employer of his or her functions at the Credit Union. Expenditures in excess of $25,000.00 for offices and facility renovation require the approval of the president of the Credit Union. Maintenance and repair of office space, whether on an emergency basis or in the ordinary course of business, is exempt from this requirement.

     Where expenditures requiring the approval of the president of the Credit Union are to be incurred by the president of the Credit Union, the president shall obtain such approval from a director of Gateway Community Federal Credit Union who is not an officer or employee of the Credit Union. The president of the Credit Union shall have the authority to interpret and implement this policy with respect to all employees and officers of the Credit Union, and the chairman of the board of the Credit Union shall interpret and implement this policy with respect to the president of the Credit Union.

     The principal executive officer of the Credit Union and principal financial officer of the Credit Union shall require the Credit Union to retain appropriate records to demonstrate compliance with this policy, including periodic certifications to the board of directors of Gateway Community Federal Credit Union that approvals require by this policy were obtained.

     If any employee of the Credit Union becomes aware of a violation of this policy, such employee shall report such violation to the principal executive officer or principal financial officer of the Credit Union. 

     All employees of the Credit Union shall adhere to the requirements of this policy. Breach of this policy by an employee may result is disciplinary actions by the Credit Union, including but not limited to, termination of employment.