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.