SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND 360 FEDERAL CREDIT UNION UNDER THE AMERICANS WITH DISABILITIES ACT

ADOPTION AND IMPLEMENTATION OF EFFECTIVE COMMUNICATION POLICY

18. Within thirty (30) days of the effective date of this Agreement, to ensure equal access for persons with disabilities, THE CREDIT UNION shall adopt, implement, and thereafter maintain the "360 Federal Credit Union Policy for Ensuring Effective Communication with Individuals with Disabilities" (Effective Communication Policy), attached to this Agreement as Exhibit A and incorporated herein by reference.

19. Within thirty (30) days of the effective date of this Agreement, THE CREDIT UNION shall distribute the Effective Communication Policy to all employees and contractors who have contact with the public either in person, through the telephone, via the computer, or by any other distribution channel. Within sixty (60) days of the effective date of this Agreement, THE CREDIT UNION shall furnish to the United States documentation confirming the implementation and distribution of the Effective Communication Policy to THE CREDIT UNION's employees and contractors.

20. THE CREDIT UNION shall distribute the Effective Communication Policy to all newly hired employees and contractors who have duties involving contact with the public either in person, through the telephone, via the computer, or by any other distribution channel within three (3) days of the date on which each such employee or contractor is hired.

21. THE CREDIT UNION shall post and maintain a copy of the Effective Communication Policy in all THE CREDIT UNION locations in a conspicuous location where employees and the public can readily read it, such as the employee lounge and an area adjacent to public entrances. The Effective Communication Policy posted in THE CREDIT UNION locations shall be printed in a bold font no smaller than 20 points on a contrasting background. The heading on the posted Effective Communication Policy shall be printed in capital letters in a bold font no smaller than 26 points. Physical copies of the posted Effective Communication Policy will be maintained and refreshed, as needed, for the life of this Agreement. If THE CREDIT UNION maintains a website within the term of this Agreement, THE CREDIT UNION shall post and maintain a copy of the Effective Communication Policy on its website in a location that is easy for the public to find (i.e., directly linked to the primary web portals used by the public with an appropriate description of the Effective Communication Policy at the link located on those portals (e.g., ADA Policy/Effective Communication)), in a format accessible to persons with disabilities (e.g., HTML). Within sixty (60) days of the effective date of this Agreement, THE CREDIT UNION shall provide the United States with proof of posting the Effective Communication Policy in all THE CREDIT UNION locations and on its website (if applicable).

22. Within sixty (60) days of the effective date of this Agreement and at least once per year, during the term of this agreement THE CREDIT UNION shall provide an educational training program regarding its obligations under title III of the ADA, this Agreement, and the Effective Communication Policy to all THE CREDIT UNION employees and contractors who have contact with the public as well as those who make decisions affecting the public. The training program, the materials for which shall be approved in advance by the United States, shall be no less than one hour in duration, shall be conducted separately from any training on nondiscrimination in employment, shall provide employees and contractors an opportunity to ask questions and get them answered, and shall be conducted by a person or organization with a high level of expertise regarding the requirements of title III of the ADA. THE CREDIT UNION shall bear all costs associated with the development and delivery of this training program to its employees and contractors. Within sixty (60) days of the effective date of this Agreement, THE CREDIT UNION shall provide the United States with proof that such training has occurred and that all employees and contractors have received it.