The federal Fair Labor Standards Act (FLSA) does not have any vacation time requirements, nor do any Illinois laws. Instead, vacation time generally is a matter of contract. However, the Federal Reserve Board’s Commercial Bank Examination Manual does state that employees “in sensitive positions” should take vacation, or at least rotate to a different position in lieu of vacation, for at least two consecutive weeks each year. FRB Examination Manual § 5017.1. The manual states that each bank’s senior management is responsible for creating a system of internal controls to safeguard its assets, and mandatory leaves of absence are one of the “basic tenets of internal control.”  Examiners are also instructed to calculate risk from internal control deficiencies into their overall rating. See also SR-96-37, which emphasizes the need for a bank to conduct an assessment of significant risk areas before developing a policy on required absences from sensitive positions.