Looking for some guidance on the regulatory requirements for taking vacation (ie must take two weeks off if in a key position). I know guidance was issued in some FIL letters from the early 90's, just wondering if anything has been updated since then?

Still the same: Vacation Policies

Regulators other than the FDIC have not, to my knowledge, ever issued any written guidance. My experience with the OCC and Fed are that they are not as rigid with a set time frame, but rather would look at controls to make sure fradulent activities can be caught. With the speed of information these days, sophisticated audit programs could catch some things in a day or two. All that said, the local regulators give this uneven levels of scrutiny.

Still the 2 week "suggested" period. I have had indepth conversations with the FDIC on this and even when exceptions are made (and approved by the BOD in our case,) it is highly suggested that the employee be removed from their job during a 2 week period. So, if the employee takes one week off, for the week before they leave or for the week after they return, they are not assigned to their regular jobs. That actually becomes a logistic nightmare. Best to have a 2 week off required vacation policy.

We are FDIC regulated and we don't require 2 weeks. It is a suggestion - not a law. That suggestion clearly states: "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 followed and the exceptions allowed. It is important in such cases that adequate compensating controls be devised and strictly enforced. "

Where strong internal controls exist that would be considered adequate compensating controls, it isn't necessary.