Hello BOL World,

Let's hear some thoughts on this topic. What does everyone thing about exempting part time employees from the FDIC Vacation Rule ?

For employees that have a limited number of PTO days each year, this requirement could be burdensome.

Do any of you have a policy or practice that works better? Maybe 3 days as opposed to 5 days out?

Thanks,

Garret - read that section carefully, it's a recommendation of an internal control. It states that for banks that don't have such a policy, the FDIC recommends that the Board annual review and approve the policy and any exceptions. If you search the threads you'll find that there are probably just as many banks that have the 2 week requirement than don't. We don't require it here. We have a 5 day requirement for Officers and people with certain levels of signing authority, but not the majority of staff. This can also be accomplished by rotation of duties and other internal/dual controls. The key is to know what the risks are, know your internal controls and be very able to explain to examiners why you have established your policy whatever it is.

Good point. Thanks. We have developed a policy that takes into account part time workers.