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#8298 - 12/28/01 04:49 PM vacation guidelines
prosperity Offline
Member
prosperity
Joined: Oct 2001
Posts: 82
Houston, TX
Has anyone seen or heard anything from regulators, particularly FDIC on the 2 consecutive week vacation rule?

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General Discussion
#8299 - 12/29/01 05:30 AM Re: vacation guidelines
MShelton Offline
Junior Member
MShelton
Joined: Jul 2001
Posts: 47
Arkansas
In our examination this year, I asked one of the examiners about that. He gave me a copy of FIL-52-95. If you don't have access to it I will be glad to fax it to you if you will email me your fax number. mshelton.trustbanc@mtnhome.com

Hope this is what your looking for.

_________________________
Marsha Shelton Opinions stated are not necessarily that of my employer.

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#8300 - 12/28/01 06:14 PM Re: vacation guidelines
KK Offline
100 Club
KK
Joined: Jan 2002
Posts: 249
Southern California
In our examination this year they made a "strong recommendation" for us to change our policy to include the two week vacation policy.

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#8301 - 12/28/01 07:01 PM Re: vacation guidelines
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
I don't think they can make you take two consecutive weeks, however, I think the Board should approve splitting the two weeks.

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#8302 - 12/28/01 09:07 PM Re: vacation guidelines
prosperity Offline
Member
prosperity
Joined: Oct 2001
Posts: 82
Houston, TX
Thanks for the comments. How do you all deal with the staffing issues that result? Let's say loan secretaries, operations clerks - do you make them take 2 consecutive weeks?

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#8303 - 12/28/01 09:12 PM Re: vacation guidelines
PBM Offline
Member
PBM
Joined: Aug 2001
Posts: 71
Wisconsin
Can I ask what job capacity everyone is referring to taking two consecutive weeks of vacation? I've worked for 3 companies during the last 5 years and for each of them I was given 3 weeks of vacation and I was never asked to take any of the time consecutively. Is this a new thing coming around? What would be the concern of a regulator if an employee took 2 or 3 separate weeks of vacation?

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Opinions stated are not necessarily that of my employer.

_________________________
Opinions stated are not necessarily that of my employer.

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#8304 - 12/28/01 09:37 PM Re: vacation guidelines
cboynefirstgabank Offline
100 Club
cboynefirstgabank
Joined: Apr 2001
Posts: 147
brunswick ga usa
We have in our employee policy that the employee is required to take one week consecutive and they can split the other. Regulators think that if the employee is doing something 'fishy' it will show up within a weeks time. Our OTS examiners at our last exam did make a point of asking about vacation time, and our internal auditor always checks, especially tellers, lenders, operations folks, IT folks, well you get the picture!

I want to know where you worked to get 3 weeks vacation right off the bat! I had to be at my bank for 10 years before I got three weeks!


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#8305 - 12/28/01 10:02 PM Re: vacation guidelines
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
If a lender is making phony loans they will probably get caught up with if they are gone for two consecutive weeks. I've see this happen and this particular lender had pocketed over $100,000 when they were caught and never even spent a day in jail!

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#8306 - 12/28/01 10:26 PM Re: vacation guidelines
AARONF Offline
New Poster
Joined: Dec 2001
Posts: 1
Kansas City, MO, USA
In keeping with FIL 52-95 (which is not a regulation or law by the way) and the "dead-horse" beating attention this issue seems to gather each examination, our small institution attempted a job-rotation program.

This program, in theory, satisfied the FDIC goal of having employees continuously absent from their duties.

It did not work so well for us, but I believe would satisfy the spirit of the regulation and the examiners we talked to did by off on it.

AF

The opinions expressed above are not necessarily those expressed by my employer.


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#8307 - 01/02/02 01:15 PM Re: vacation guidelines
Dana Turner Offline

Platinum Poster
Dana Turner
Joined: Dec 2000
Posts: 543
Pipe Creek TX - U.S.
Folks:

There's no regulation that I know of that requires an institution to remove an employee from normal duties for two (2) consecutive weeks. Any examining agency, however, may establish such a "field practice" if its examiner determines that this practice would reduce the loss potential. A "field practice" is usually determined by the regional head of the examining agency and carries with it the force of a regulation.

So here's an unpopular -- but extremely effective -- solution. I recommend that you require every employee to be absent from his/her facility (if possible) and duties, consecutively, for:
1. A weekend, followed by;
2. Five (2) working days, followed by;
3. A weekend.

Before the employee (from the president on down the organizational food chain, with no exceptions) leaves or is re-assigned, be certain to:
1. Explain that he/she may only return to the facility as a customer and that he/she may not enter his/her work area unaccompanied;
2. Have him/her sign and date a copy of your "leave policy" and keep it in your security file;
3. Collect his/her keys and other access devices;
4. Void or restrict his/her password in the institution's computer;
5. If the person has knowledge of any combination, change the combination;
6. Depending upon the position, audit his/her areas of responsibility; and
7. Consider running a continuing background investigation to insure that the employee's still fit for work.

This doesn't describe an "industry-standard security practice" but I wish it was. Now let's see what kind of response this "overkill" suggestion generates . . .

------------------
Dana Turner
Security Education Systems
danaturner@bankersonline.com
830-535-6500
Opinions expressed are always those of my employer.

_________________________
Celebrating 42 entertaining years of crime . . .
danaturner@email.com

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#8308 - 01/03/02 03:19 PM Re: vacation guidelines
Last Mango Offline
Gold Star
Joined: Mar 2001
Posts: 293
Too Far From the Beach
Dana, I took your suggestion to heart and made a recommendation to management. During our conversation, management asked for my shoe size. I later learned that management is going to present me with a new pair of shoes – some new brand called Concrete.

All kidding aside, compliance officers must remember that a regulatory policy is not a regulation. Although examiners may try to enforce a regulatory policy like a regulation, if the policy does not fit the institution, management should consider standing their ground using sound business principles.

While I agree with the need for a two-week vacation policy, it may not be practical for small shops that have limited vacation and limited staffing for rotation of duties. Management must look at the risk and set the control accordingly.

When reviewing risk and vacation policy, management needs to also consider other factors such as staff experience and workload. In addition, when considering rotating staff to fill in for a vacationing employee, management must determine if controls would be compromised by allowing the fill-in to assume new duties while maintaining authorities and access to other areas of the bank.

Dana, my heart is with ya but . . .

Any opinion expressed above is personal, certainly not the opinion of my employer, and may be worth as much as it cost.

_________________________
If you keep living straight from the heart, you will know when to stop and to start.

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#8309 - 01/03/02 04:25 PM Re: vacation guidelines
Anonymous
Unregistered

Internal controls and auditing should be used in conjunction with two weeks consecutive vacation, and controls and auditing can - to a degree - help to lessen your risk. However, no internal controls nor no auditing procedures are 100% effective. How many times have we read of embezzlements going on for months or years, only to be uncovered when the new accounts clerk is finally persuaded to take a two week vacation.

I am one that would love to be able to break my vacation up into one week incremenets, since no one fills in for me at my bank and this would make my life sooooo much easier. But on the other hand, since I do auditing, I also understand why it is best that I be gone for two weeks. I trust me but no one else here should.


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#8310 - 01/04/02 05:01 AM Re: vacation guidelines
prosperity Offline
Member
prosperity
Joined: Oct 2001
Posts: 82
Houston, TX
Thanks for all of the comments. Let's not beat this horse too too badly - we may need it again - like next exam.

Wanda Johnson


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