No, we are not aware of any laws or regulations that require bank employees or officers to take vacation.

The FDIC (your primary regulator) does expect that banks require its officers and employees “to be absent from their duties for an uninterrupted period of not less than two consecutive weeks . . . in the form of vacation, rotation of duties, or a combination of both activities.” However, the FDIC also has recognized that, in practice, many banks cannot follow this policy — due to the small number of staff in a small bank, for example — and suggests compensating controls, as well as having exceptions reviewed and approved by the board of directors.

For resources related to our guidance, please see:

• FDIC, Risk Management Manual of Examination Policies, Section 4.2 – Internal Routine and Controls, page 4 (“Banks should have a policy that requires all officers and employees to be absent from their duties for an uninterrupted period of not less than two consecutive weeks. Absence can be in the form of vacation, rotation of duties, or a combination of both activities. Such policies are highly effective in preventing embezzlements, which usually require a perpetrator’s ongoing presence to manipulate records, respond to inquiries, and otherwise prevent detection. The benefits of such policies are substantially, if not totally, eroded if the duties normally performed by an individual are not assumed by someone else.”)

• FDIC FIL-52-1995, FDIC’s Position on the Role of Vacation Policy as an Important Internal Safeguard (August 3, 1995) (“The FDIC endorses the concept of a vacation policy that allows active officers and employees to be absent from their duties for an uninterrupted period of no less than two weeks . . . . The FDIC recognizes, however, that exceptions to a two-week policy can occur. In those situations, it is important for the institution to have adequate compensating controls — such as an effective rotation of personnel — that are strictly enforced. When the vacation policy does not conform to the recommended two-week absence, the institution’s board of directors should review and approve the policy actually followed and the exceptions allowed.”)