Members Credit Union

Excessive or Luxury Expenditures

Policy August 2023

Purpose

The purpose of this policy is to establish parameters and internal controls governing the expenditures of Members Credit Union

(Members CU). Expenditures of Members CU should be customary, prudent, consistent with applicable laws and regulations,

and reasonably related to Members CU's business objectives and needs. 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. Routine operating expenses, capital expenditures, and other reasonable expenses are not prohibited by this policy.

Authority

Members CU has authority to provide compensation and benefits that are reasonable. 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.

Responsibility

This policy is the responsibility of Members CU's board of directors (board). The board has approved this policy and will review

compliance with this policy no less frequently than annually, and summary data on excessive or luxury expenditures will be

reported to the board as part of the compliance review.

Scope

This policy applies to all employees, officers, and directors of Members CU with regard to any expenditure of Members CU.

In making any expenditure on behalf of Members CU, employees, officers, and directors should consider whether the expenditure

is an excessive or luxury expenditure that is prohibited under this policy.

Excessive or Luxury Expenses

“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 Members CU's business operations:

 Entertainment or events. This category includes fees, dues, tickets costs related to social, athletic, artistic and dining clubs,

activities, celebrations or other events, and similar expenditures. Expenditures for charitable contributions and charitable

events are not prohibited under this policy. Entertainment or events expenditures in an amount less than $500 per instance,

and $2,000 on an annual aggregate basis per individual, are exempt from this policy.

• Office and facility renovations. 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. Office and

facility renovations expenditures in an amount less than $10,000 per instance, and $10,000 on an annual aggregate basis per individual,

are exempt from this policy.

Aviation or Other Transportation Services

• 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). Mileage reimbursable

according to current Internal Revenue Service mileage rates is exempt from this policy. Transportation services in an amount

less than $1,500 per instance, and $10,000 on an annual aggregate basis per individual, are exempt from this policy.

• For the avoidance of doubt, reasonable capital investments in technology, equipment, and similar items that expand the

long-term capability of an ECIP recipient to provide products and services to its customers and community are not

excessive or luxury expenditures.

• The principal executive officer may establish or delegate to an appropriate executive officer the authority to establish

processes for the evaluation and approval of expenditures in the preceding categories that are not luxury or excessive

expenditures. and that are not otherwise exempt from this policy. These processes must be reviewed by executive

management no less frequently than annually, as well as any additional threshold expenditure amounts per item,

activity, or event, or a threshold expenditure amount per employee receiving the item or participating in the activity

or event under this policy. Such approvals must be reported to the board of directors (which may be in an appropriate

summary form) no less frequently than annually.

Exceptions or Violations

Any exception or violation of this policy must be promptly reported to Members CU's (i) principal executive officer, (ii) officer

with primary responsibility for Members CU's compliance function, or (iii) officer designated with primary responsibility for

overseeing the administration, monitoring, and compliance with this policy. Exceptions and violations must be reported to the

board of directors no less frequently than annually, or more frequently as the nature and severity of violation may warrant. All

employees, officers, and directors of Members CU must adhere to this policy and will be held accountable for compliance. Any

employee or officer who violates this policy may be subject to disciplinary action up to and including termination of employment.

Any employee or officer that is aware of any circumstance that may indicate a violation of this policy is required to report such

circumstance to their supervisor or Members CU's principal compliance officer or compliance group. Members CU prohibits

retaliation against any employee or officer for making a good faith report of actual or suspected violations of Members CU's code

of conduct, laws, regulations, or other Organization policies, including this policy. A finding of retaliation against any such

employee or officer may result in disciplinary action up to and including termination. Failure to promptly report known

violations by others may also be deemed a violation of Members CU's code of conduct.

Certifications

On an annual basis, the ECIP recipient will deliver to the Department of the Treasury a certification, executed by two senior executive

officers (one of which must be either the ECIP recipient's principal executive officer or principal financial officer) certifying that

(i) Members CU is in compliance with this policy and (ii) the approval of any expenditure requiring the prior approval of any

senior executive officer, any executive officer of a substantially similar level of responsibility, or the board of directors

(or a committee of such board), was properly obtained with respect to each such expenditure.