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#193013 - 05/21/04 09:07 PM consecutive vacation days
Anonymous
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I am in the middle of an HR audit and I seem to remember the requirment for consecutive vacation days was repealed awhile back. I used to be with an FDIC bank and now am with a NCUA credit union. Is this a requirment anymore or is it up to the governing body or each individual financial institution. Thank you.

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#193014 - 05/22/04 05:45 PM Re: consecutive vacation days
rlcarey Offline
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The FDIC still has that requirement - see this FIL:

FIL 52-95


Whether the NCUA has the same, you may have to call them.
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#193015 - 05/24/04 12:37 PM Re: consecutive vacation days
Retread Offline
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Retread
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Quote:

The FDIC still has that requirement




It's not a requirement. It's a recommendation. If you don't do it, you cannot be written up for a violation, but you may be subject to criticism for not following the recommendation.
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#193016 - 05/24/04 12:47 PM Re: consecutive vacation days
rlcarey Offline
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Quote:

If you don't do it, you cannot be written up for a violation, but you may be subject to criticism for not following the recommendation.





And the difference being??
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#193017 - 05/24/04 01:21 PM Re: consecutive vacation days
Dvorak Offline
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Delaware
In 2002, research was conducted regarding the NCUA's policy on consecutive days. I don't know if it is still the current policy. Below is the results:

National Credit Union Administration
NCUA Examiner’s Guide, Chapter 13 Internal Controls (June 1997) – “All credit unions should have a vacation policy which provides that all employees be absent from their duties for an uninterrupted period of at least one week during which time they have no access to records.”

The Examiner’s Guide chapter on Internal Controls expands on Section 1761b 113 (19) of the Federal Credit Union Act which states that “Among other things, the board of directors shall establish and maintain a system of internal controls consistent with the regulations of the Board.”

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#193018 - 05/24/04 01:47 PM Re: consecutive vacation days
Retread Offline
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Quote:

And the difference being??




Non compliance with regulation can result in an enforcement action. Non compliance with a recommendation cannot result in an enforcement action because no regulation has been violated and no law has been broken.
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#193019 - 05/24/04 01:56 PM Re: consecutive vacation days
Uncle_Milty Offline
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New Jersey
You might want to check with your blanket bond insurer - they may have something to say on the matter as well.

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#193020 - 05/24/04 02:03 PM Re: consecutive vacation days
rlcarey Offline
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Well, that's not necessarily true. The lack of or breakdown in internal control requirements can result in enforcement actions and this is just one piece of appropriate internal controls. I wouldn't paint it into such a small corner as the failure to have an adequate policy to address this internal control may just be a symptom of larger problems and may very well be part of the ammunition for citing the institution for a regulatory violation.
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#193021 - 05/24/04 02:14 PM Re: consecutive vacation days
Retread Offline
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Quote:

Well, that's not necessarily true. The lack of or breakdown in internal control requirements can result in enforcement actions and this is just one piece of appropriate internal controls. I wouldn't paint it into such a small corner as the failure to have an adequate policy to address this internal control may just be a symptom of larger problems and may very well be part of the ammunition for citing the institution for a regulatory violation.





You are absolutely correct if this is a symptom of a greater problem, but the original question was whether the consecutive vacation days is a requirement. The answer is still no. It is a recommendation, not a requirement.
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#193022 - 05/24/04 02:21 PM Re: consecutive vacation days
rlcarey Offline
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Retread - You and I don't really disagree.

However, I have two specific FDIC regulated clients that would disagree with us regarding the impact of compliance this "recommendation" based on thier last exams and the comments they received in their exam reports.
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#193023 - 05/24/04 02:32 PM Re: consecutive vacation days
Retread Offline
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Quote:

Retread - You and I don't really disagree.




Yeah, you're right. This is one of those situations like when a loan officer violates the bank's loan policy and makes a loan that is later determined to violate the law. The violation of bank policy is not a violation of the law, but if the loan officer made the "illegal" loan in violation of the bank's policy, that just gives the prosecutor more ammunition in prosecuting the case.

Likewise, the recommended vacation policy by itself would not result in an enforcement action, but if there were serious internal control problems, and/or frequent losses from internal theft, the lack of a vacation policy would strengthen the regulator's case for a possible enforcement action.
Last edited by Retread; 05/24/04 02:44 PM.
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#193024 - 05/24/04 06:06 PM Re: consecutive vacation days
J2C Offline
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Big Brother knows and that's a...
We did away with 2 consecutive week vacation a few years ago and nothing was ever said. Now this past year, the OCC recommended we put this practice back in place. It was reported in our ROE under Internal Audit, because it is an internal control issue- so they say. We changed our policy, but it is limited to only senior officers and individuals that hold high risk jobs (ie. system administrator's). They are all now required to take 2 weeks consecutively. It seemed to satisfy the regulators.
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