New York State Department of Financial Services (DFS) Acting Superintendent Adrienne A. Harris today issued a request for information (RFI) to banking organizations regarding the 1996 DFS Guidance Letter, “Vacation Policy as an Internal Control Safeguard.”  

The RFI is being issued after feedback received during a roundtable discussion with several New York State-chartered Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs) in November 2021. The purpose of the discussion was to encourage on-going collaboration to support the important roles these organizations play in providing access to financial services to the underserved communities in New York. 

DFS is seeking information with respect to the 1996 “Vacation Policy as an Internal Control Safeguard” - in order to consider flexibility for banking organizations that may have operational challenges in complying with the two-week absence requirement outlined in the Guidance Letter, while ensuring that a comprehensive system of internal controls is in place for the organization to safeguard its assets and capital and to avoid reputational, legal or regulatory risks. 

“In our November conversation with CDFIs and MDIs, it came to our attention that the 1996 DFS Guidance Letter, “Vacation Policy as an Internal Control Safeguard,” as it currently stands, may create significant operational challenges for small financial institutions which are critical sources of access to financial services and products in underserved communities,” said Acting Superintendent Harris. “Implementation of the vacation policy continues to be an internal control safeguard, but we are taking swift action to better understand how the policy impacts our regulated institutions – especially CDFIs and MDIs - which will inform potential updates to our guidance.”  

For a copy of the RFI, please go to the DFS website.