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OKLAHOMA CITY – No, July 4 was not a normal business day, so it doesn’t count toward the mandatory five-day vacation rule.
Human resources director Shannon Sullivan at Valliance Bank has been fielding a lot of questions about that state banking rule lately. So has the Oklahoma Bankers Association, spokesman Jeremy Cowen said. It’s an issue that rarely comes up in the middle of the week like it did this month.
“It would have been a great way to take five days and only lose four days of productivity,” Sullivan said. “Instead, several employees had to take an additional Monday or Friday on the other side of the weekend to meet the requirement.”
The rule might seem odd outside the industry, but it still serves a good purpose, Banking Commissioner Mick Thompson said. An extended break keeps employees from maintaining questionable processes by hand and avoiding scrutiny.
The banking rule states that all internal control programs adopted by banks must include a requirement that each officer and employee be absent from the institution at least five consecutive business days each calendar year unless otherwise approved by the bank’s bonding company. During that absence, the duties must be performed by other bank officers and employees.
The objective is to ferret out wrongdoing such as embezzlement or sloppy processes, Thompson said, such as tucking away loan applications without processing. The OBA legal staff’s guidance to members encourages cross-training to ensure full coverage throughout an institution.
The department used to require a 10-day break, Thompson said. The Federal Deposit Insurance Corp. recommends two consecutive weeks, according to its online materials.
“This basic control has proven to be an effective internal safeguard in preventing fraud. In addition, such a policy is viewed as a benefit to the well-being of the employees and can be a valuable aid to the institution’s overall training program,” the FDIC says.
Dick Beshear at First Security Bank in Oklahoma City said he still hasn’t scheduled his own five-day break, something he usually puts off until later in the year. Even with all the electronic technology advancements in the industry, he said, it’s important to get people out of their nooks physically.
Sullivan explains the rule to every employee during new-hire orientation. There are no exceptions.
And now she’s using the holiday as a reminder to prompt employees to look ahead to Dec. 31. It’s not unusual for executives to put off the responsibility until the last minute and overlap each other’s schedules. She said CEO Brad Swickey is often her biggest challenge because he hates to be away from the work he loves to do.