No, we are not aware of any Illinois law that requires two consecutive weeks of vacation time. As you noted, the federal banking agencies, including the FRB, strongly recommend that bank employees and officers take two consecutive weeks of vacation per year, although this requirement is not found in any law or regulation. We are aware that many institutions do not follow this recommendation (i.e., by requiring only one consecutive week of vacation per year).

For citations related to our guidance, please see below:

• FRB Commercial Bank Examination Manual, Section 5017.1 (“One of the many basic tenets of internal control is that a bank needs to ensure that its employees in sensitive positions are absent from their duties for a minimum of two consecutive weeks.”)

• FRB Supervisory Guidance on Required Absences from Sensitive Positions, SR 96-37 (December 20, 1996) (“In brief, the guidance is intended to ensure that each banking organization conducts an assessment of significant risk areas.  After conducting this assessment, the organization should, with few exceptions, require that employees in sensitive key positions, such as trading and wire transfer, not be allowed to transact or otherwise carryout, either physically or through electronic access, their assigned duties for a minimum of two consecutive weeks.”)