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Handling ACH Origination Exception Issues
Shelly Simpson

April 17
Fair Lending - Internal Monitoring
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April 22
A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
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HSA Basics
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April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht



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#1867926 - 11/04/13 11:01 AM PTO Use for Sick
BLMMR Offline
New Poster

Registered: 10/29/13
Posts: 2
Loc: Midwest
At the beginning of 2013, we switched our Vacation and Sick plans to a combined PTO plan. One unintended consequence is that employees are reluctant to use their PTO for when they are sick, so they come to work instead. This means that I have employees at work with a fever, cough, etc. At what point can I make an employee go home sick so they are not here infecting the other employees and customers?

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Human Resources
#1867964 - 11/04/13 11:52 AM Re: PTO Use for Sick [Re: BLMMR]
osucpa Offline
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Registered: 05/13/11
Posts: 471
Check with HR and possibly have HR send out an memo to employees.

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#1867986 - 11/04/13 12:08 PM Re: PTO Use for Sick [Re: BLMMR]
80's Lady Online
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Registered: 04/26/07
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#1868069 - 11/04/13 02:02 PM Re: PTO Use for Sick [Re: BLMMR]
Springtime Offline
Junior Member

Registered: 03/24/09
Posts: 44
Loc: MO
After reading the initial question, I have an additional question. We have vacation time and PTO. Vacation time is to be used for vacation (of course). PTO is to be used for sick time and personal time. It is a use it or lose it benefit. We have this because we require employees to take their 2 week vacation consecutively. Are we allowed to offer both vacation and PTO?

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#1868128 - 11/04/13 02:45 PM Re: PTO Use for Sick [Re: BLMMR]
Truffle Royale Offline

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Registered: 07/09/03
Posts: 13743
Springtime, we do the same thing here and I know it's ok to do it this way.
PTO is for sick time, appts, refrigerator deliveries, kids' school stuff, etc. whatever you need it for. Certain amounts of it carryover for use for maternity leaves, etc. I had a bunch built up that I used when I needed to be at the hospital for my husband's surgeries.
Vacation is a seperate entity. Because there's no longer a mandate on time away from bank, management elected to reduce time away to 5 consecutive days which can include conferences, etc.

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#1868156 - 11/04/13 03:34 PM Re: PTO Use for Sick [Re: 80's Lady]
BLMMR Offline
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Registered: 10/29/13
Posts: 2
Loc: Midwest
Thanks for the article Lady!

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#1868164 - 11/04/13 03:47 PM Re: PTO Use for Sick [Re: BLMMR]
HappyGilmore Online
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Registered: 06/11/04
Posts: 17220
Loc: Moron, Mongolia
I always seen that if you have PTO, it is used for all absences from the bank - vacation, sick, personal, nice sunny day and i own a convertible, etc. You are given X days per year for PTO, if you use all of them by June, any days off from that point are on your dime...normally when converting from standard vacation/sick to PTO, a company will make a determination on how many days of PTO an employee has based on title, years of service, etc. So, if you get 5 sick days and 10 vacation days and 2 personal days, you may end up with 17 PTO. Some may allow you to bank a few days per year and carry over to the next year, some require you to take it. If you are never sick, PTO is great as it give you more vacation time. If you call in for every hangnail or bad hair day, PTO is not going to be to your liking...
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#1869085 - 11/06/13 03:55 PM Re: PTO Use for Sick [Re: BLMMR]
ahkcompliance Offline
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Registered: 09/10/08
Posts: 1642
Loc: Midwest
We use a PTO system. We run into the same boat that there are some employees who come to work when they are sick because they don't want to use PTO as sick time and want to leave it as fun days off.

Usually HR will send a memo out regarding when you should stay home from work. I remember one time we actually had the employee leave work for the day because they were so bad.

I agree with Happy, PTO will most likely be your friend or enemy. I personally like it. It flexible where you can use the days you need. I usually save 5 days as sick days and will start using them here and there in November and December if haven't needed. We lose them at the end of year if still on the table. I wish we were able to carry over a few days.

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#1869118 - 11/06/13 04:39 PM Re: PTO Use for Sick [Re: BLMMR]
Truffle Royale Offline

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Registered: 07/09/03
Posts: 13743
And that^^^ would be why running a system that separates PTO from vacation time eliminates the problem of people not staying home sick when they should.

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#1869122 - 11/06/13 04:44 PM Re: PTO Use for Sick [Re: BLMMR]
HappyGilmore Online
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Registered: 06/11/04
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Loc: Moron, Mongolia
if you separate PTO from sick, what is the purpose of classifying as PTO? after all, PTO stands for paid time off...if you segregate for sick days, which are also paid time off, you haven't really changed anything, have you?
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#1869129 - 11/06/13 04:57 PM Re: PTO Use for Sick [Re: BLMMR]
ahkcompliance Offline
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Registered: 09/10/08
Posts: 1642
Loc: Midwest
I agree Happy. I think some people just to see they have X number of sick days so at the beginning of the year they know they have X number of sick and X number of vacation/personal.

It's all paid time off...you just have to be diciplined to segregate it yourself when using an all PTO system.


Edited by ahkcompliance (11/06/13 04:58 PM)

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#1869136 - 11/06/13 05:17 PM Re: PTO Use for Sick [Re: BLMMR]
Springtime Offline
Junior Member

Registered: 03/24/09
Posts: 44
Loc: MO
Thanks for the responses. I really haven't seen too many come in sick just so they can use their PTO at a later date for "fun". Ours is a use it or loose it benefit too so I am seeing more employees trying to use it right now that we are coming to the end of the year. My concern with that though, is too many trying to use their remaining PTO at the same time. We do offer them to roll unused PTO over into the first quarter of the next year only if their request for PTO is denied due to time restraints or conflict of multiple employees being off at the same time. Another feature of our PTO is that it should be "earned" in order to use it. Each month employees earn 1/2 day of PTO so that by the end of the year they will have accumulated 6 days.

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#1869141 - 11/06/13 05:22 PM Re: PTO Use for Sick [Re: BLMMR]
Truffle Royale Offline

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Registered: 07/09/03
Posts: 13743
Maybe roll-over is why the split works for us so well. There's never a rush to use up PTO before end of year because any unused PTO is rolled over. I've seen women stockpile it for maternity leave and a few have had it to use for catastrophic illnesses of themselves or a spouse or child thereby never having to go to FMLA.
Only a certain percentage of vacation time can be carried over.

It's all about what works best for your organization.

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#1875355 - 12/02/13 04:47 PM Re: PTO Use for Sick [Re: BLMMR]
fun grandma Offline
Member

Registered: 11/21/08
Posts: 80
Loc: midwest
My previous employer used your hired date/month as when your PTO started accruing.
This avoided the rush in November/December to try and take time off so as not to lose it.
They did allow a small portion to carry over.
It also had to be earned before it could be used.

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#1875931 - 12/04/13 11:39 AM Re: PTO Use for Sick [Re: BLMMR]
Summer Nights Offline
New Poster

Registered: 05/29/08
Posts: 19
Loc: Land of the Green & Gold
Our PTO & Sick time are seperate, in order to use sick time you need to be out for 3 or more days and need a doctors excuse, if only out 1-2 days you have to use PTO or unpaid. They used to allow us to use sick time for family members but alas no more because people were taking advantage of it (their thinking). You can take FMLA, but have to use PTO if you want to be paid. Hubby had heart issues and being able to use my sick time was a godsend since I had no PTO time left.

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#1879011 - 12/16/13 03:05 PM Re: PTO Use for Sick [Re: Truffle Royale]
P*Q Offline

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Registered: 05/29/01
Posts: 7322
Loc: By the ocean
Originally Posted By: Truffle Royale
Because there's no longer a mandate on time away from bank, management elected to reduce time away to 5 consecutive days which can include conferences, etc.
Bank eliminated mandate or that old FDIC good practice?

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#1879888 - 12/18/13 12:39 PM Re: PTO Use for Sick [Re: BLMMR]
Truffle Royale Offline

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Registered: 07/09/03
Posts: 13743
There's never been a regulatory requirement. Time away was based on guidelines used by FRB, our examining body. When those guidelines eased from two weeks, our bank elected to ease up to five consecutive days that can be a combination of seminar/vacation/holiday.

After rereading this thread, I feel the need to clarify that for us, PTO includes all types of time off other than vacation. You can use it for sick, dr appts, new appliances being delivered, whatever. Vacation is tracked seperately. All left-over PTO can be carried over but only a certain amount of vacation time can carry over.

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#1879963 - 12/18/13 01:53 PM Re: PTO Use for Sick [Re: BLMMR]
EdAudit Online
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Registered: 07/18/08
Posts: 2606
Loc: You are here
Vacation Policies
All banks should have a vacation policy, which provides that officers and employees be absent from their duties for an uninterrupted period of not less than two consecutive weeks. Such a policy is considered an important internal safeguard largely because perpetration of an embezzlement of any substantial size usually requires the constant presence of the embezzler in order to manipulate records, respond to inquiries from customers or other employees, and otherwise prevent detection. Examiners and bank management should recognize that the benefits of this policy may be substantially, if not totally, eroded if the duties performed by an absent individual are not assumed by someone else. Where the bank's policy does not conform to the two-week recommended absence period, examiners should encourage the board of directors to annually review and approve the policy actually followed and the exceptions allowed. In such cases it is important that adequate compensating controls be devised and strictly enforced. If after consideration of all relevant facts and circumstances it is determined that the vacation policies are deficient, the matter should be discussed with the chief executive officer and the board of directors. Comments and recommendations on the supplemental Internal Routine and Controls schedule may be appropriate.

http://www.fdic.gov/regulations/safety/manual/section4-2.html


Is this still in effect?
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#1879984 - 12/18/13 02:17 PM Re: PTO Use for Sick [Re: Truffle Royale]
AA_G Offline
10K Club

Registered: 07/21/04
Posts: 18913
If you're using five consecutive days as an internal control (which, I fully agree is a strong control for fraud), then in my opinion, it makes no sense to include holidays. If the bank isn't open for business, the person isnt going to be able to keep the fraud going on those days anyways - so that really brings you down to four days.

Also, regarding seminars, etc. - the person needs ALL remote access rights terminated during his or her absence. Otherwise, what's the point of having the 5 consecutive day policy in place if someone has systems access?
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#1879989 - 12/18/13 02:24 PM Re: PTO Use for Sick [Re: EdAudit]
AA_G Offline
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Registered: 07/21/04
Posts: 18913
I'm pretty sure that it is, Ed.

Here is the FRB's statement - an SR Letter from 1996.

http://www.federalreserve.gov/boarddocs/srletters/1996/sr9637.htm

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#1879992 - 12/18/13 02:28 PM Re: PTO Use for Sick [Re: BLMMR]
Truffle Royale Offline

10K Club

Registered: 07/09/03
Posts: 13743
Ed, you quoted from an examination policy manual. It's not a reg or requirement but WAS a strong recommendation that has in practice in recent years been lighted up on considerably.

Happy/Krampus, I think this is definitely a case of interpretation and adaptation to the needs of various areas within a bank. What works for us and meets all our FRB quidelines and exam rigors, obviously wouldn't work for you.

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#1879995 - 12/18/13 02:32 PM Re: PTO Use for Sick [Re: Truffle Royale]
AA_G Offline
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Registered: 07/21/04
Posts: 18913
I'm not happy.

And I'm not disagreeing with you. It's risk-based, like most other things today. We've successfully defended why we don't require all positions to take two consecutive weeks to the FRB examiners.

The SR letter explicitly states:

In the attachments, we emphasize that each banking organization should assess its significant risk areas before developing a policy regarding this matter. After making this assessment, the organization should require that employees in sensitive key positions, such as trading and wire transfer, not be allowed to transact or otherwise carryout, either physically or through electronic access, their assigned duties for a minimum of two consecutive weeks. The prescribed period of absence should, under all circumstances, be sufficient in duration to allow all pending transactions to clear. It should also require that an individual's daily work be processed by another employee during the employee's absence.
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#1879999 - 12/18/13 02:35 PM Re: PTO Use for Sick [Re: BLMMR]
Truffle Royale Offline

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Registered: 07/09/03
Posts: 13743
Just to muddy the waters a tad more, the time off from their position does not necessarily mean the employee has to take vacation time IF the bank has the ability to successfully rotate them into some other position at the bank that would not allow them access to their normal daily routine. I've not seen this in practice but I have discussed it at length with examiners.

My apologies to the OP for derailing their thread.


Edited by Truffle Royale (12/18/13 02:36 PM)
Edit Reason: aplology

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#1880027 - 12/18/13 03:34 PM Re: PTO Use for Sick [Re: BLMMR]
EdAudit Online
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Registered: 07/18/08
Posts: 2606
Loc: You are here
Is there periodic unannounced rotation of duties for employees
or vacation requirements that ensure their absence for at least a
two-week period?

www.occ.gov/publications/publications-by-type/.../intcntrl.pdf‎



I see what you are saying (clearer in the OCC) but my institution takes guidance as if they are regs
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#1880665 - 12/20/13 01:20 PM Re: PTO Use for Sick [Re: Truffle Royale]
HappyGilmore Online
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Registered: 06/11/04
Posts: 17220
Loc: Moron, Mongolia
Originally Posted By: Truffle Royale
There's never been a regulatory requirement.


at the federal level this may be true, but state banking regulations in several states that i'm familiar with require it
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