Expenditures related to other items not listed in the preceding categories, in individual and annual amounts reasonable and customary, are exempt from this policy. (5) Other similar items, activities, or events for which the Credit Union may reasonably anticipate incurring expenses or reimbursing an employee for incurring expenses. This category does not apply to tax equalization agreements for employees subject to tax from a non-U.S. This category includes any reimbursement of taxes owed with respect to any compensation. The CEO may establish or delegate to an appropriate executive officer the authority to establish processes for reimbursement of reasonable travel expenditures, which processes must be reviewed by executive management no less frequently than annually. Transportation services, in individual and annual amounts reasonable and customary, are exempt from this policy. Mileage reimbursable according to current Internal Revenue Service mileage rates is exempt from this policy. This category includes charter fees, tickets, slip or docking fees, vehicle installment payments, reservation and travel agent expenses, and similar expenditures associated with transportation services (e.g., airline, train, rental cars, or vans). (3) Aviation or other transportation services. Office and facility renovations expenditures, in individual and annual amounts reasonable and customary, are exempt from this policy. This category includes costs and allowances for office renovation, including expenditures related to furniture, art, office personalization, interior finishing, design and decoration, and similar expenditures. Entertainment or events expenditures, in individual and annual amounts reasonable and customary, are exempt from this policy. Expenditures for charitable contributions and charitable events are not prohibited under this policy. This category includes fees, dues, tickets costs related to social, athletic, artistic and dining clubs, activities, celebrations or other events, and similar expenditures. “Excessive or luxury expenditures” means excessive expenditures on any of the following to the extent not reasonable or appropriate expenditures for business development, staff development, reasonable performance incentives, or other similar reasonable measures conducted in the normal course of the Credit Union’s business operations: In making any expenditure on behalf of the Credit Union, employees, officers, and directors should consider whether the expenditure is an excessive or luxury expenditure that is prohibited under this policy. This policy applies to all employees, officers, and directors of the Credit Union with regard to any expenditure of the Credit Union. This policy is the responsibility of the Credit Union’s board of directors (“Board”). This policy establishes a prohibition on expenditures that are excessive or luxury expenditures as required by the Department of the Treasury’s Emergency Capital Investment Program regulations (31 CFR Part 35), and as may be required by other statutes and regulations. The Credit Union has authority to provide compensation and benefits that are reasonable. Routine operating expenses, capital expenditures, and other reasonable expenses are not prohibited by this policy. This policy identifies expenditures that are excessive or luxury expenditures, creates processes that are reasonably designed to eliminate such expenditures, and establishes accountability for compliance. Expenditures of the Credit Union should be customary, prudent, consistent with applicable laws and regulations, and reasonably related to the Credit Union’s business objectives and needs. The purpose of this policy is to establish parameters and internal controls governing the expenditures of Freedom First Federal Credit Union (together with its subsidiaries and controlled affiliates, referred to hereafter as the Credit Union).
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