Compliance Blog

Dec 31, 2007

Five Consecutive Days; NAFCU Holiday Schedule

Many credit unions have a policy that requires all employees to be away from the credit union for (insert number here ) consecutive days at some point during the year.  We get a few questions on whether this is a requirement, and if so, what rationale underpins it.  Since many of your employees (including myself) are out of the office today, I thought it would be a good topic to discuss.

There is no law or regulation that requires such a policy.  (Your insurance policy, however, may.)  That being said, NCUA does consider it to be a good practice. 

NCUA issued a letter to credit unions in 1996 that discusses internal controls.  NCUA indicated that "embezzlements usually require the embezzler's ongoing attention; therefore, policies that require managers and employees to take at least one and preferably two weeks' vacation (not a day here and there) reduce the risk of embezzlements."

In Chapter 4 of NCUA's Examiner's Guide, NCUA indicates that certain control activities help manage risk.  One of the listed controls is this: "The requirement that officers and employees in sensitive positions take two consecutive weeks of out-of-office vacation each year, if practical."


NAFCU will be closed today and tomorrow.  For those of you celebrating this evening, please be careful.  Use a designated driver, public transportation, or a taxi. (Hey, I'm just trying to protect my readership!)