Saturday, July 20, 2024

Week of July 2

In This Issue…

Clarifying language on ‘five-day rule’
Answer leadership’s call: OBA Emerging Leaders Academy accepting applications
Emerging Leaders lunch-and-learn scheduled
OBA education corner …

Clarifying language on ‘five-day rule’

The OBA has received questions from bankers recently related to the mandatory annual five consecutive days of leave rule, particularly in how it relates to holiday days, such as this week’s July Fourth.

Here is the response from the OBA’s legal team:

10-5-3. Minimum control elements for bank internal control program

All internal control programs adopted by banks shall contain as a minimum the following:
(1) A requirement that each officer and employee, when eligible for vacation, be absent from the institution at least five consecutive business days each calendar year, unless otherwise approved in writing by the bank’s bonding company for bank officers and employees generally and then each officer and employee who may be excepted from this requirement must be specifically approved by the bank’s board of directors and it shall be recorded in the board of directors minutes, that the officer or the employee may be absent less than the five consecutive banking days. During the absence of an officer or employee, the duties of the absent officer or employee must be performed by other bank officers and employees…

(This week) Wednesday is NOT a business day.

The FDIC’s recommendation is two weeks, but offers alternatives. (See link below.)

The objective is that employee shall not have direct nor indirect have control (i.e., the substitute should call or email) over his/her duties for a consecutive period as a matter of internal control to ferret out wrong-doing such as embezzlement and the like, including an employee who was putting loan applications into his/her drawer without processing. I applaud cross-training since I get a ton of calls when the employee in charge of garnishments, subpoenas, CTRs, etc. is off, and the employee filling the gap has little or no training.

If you have any further questions, please feel free to contact the OBA legal team at

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Answer leadership’s call: OBA Emerging Leaders Academy accepting applications

Take note the OBA 2018-19 Emerging Leaders Academy is currently accepting applications.

We’re looking for the best and brightest bankers who seek to sharpen their leadership skills. The Academy will help you reach new heights with powerful speakers offering information leaders need for effectively maneuvering in today’s business climate. Each session helps participants become true leaders by understanding those around you through non-traditional methods.

The OBA extends an invitation to any employee of a bank that is a member of the OBA to apply. A panel of bankers will review the applicants and choose those accepted into the Academy. Participants must attend all sessions to successfully graduate from the program.

There are six sessions to the Academy: Oct. 12, Nov. 9, Dec. 6, Jan. 11, Feb. 26, March 29. Graduation will take place at the 2019 OBA Annual Convention (registration fee waived upon completion of the Academy)

Click here for more information or to apply! For more information, please contact Megan McGuire at (405) 424-5252 or

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Emerging Leaders lunch-and-learn scheduled

Join your banking peers for a lunch-and-learn at the Oklahoma City Branch of the Federal Reserve of Kansas City. Lunch will be provided by the Fed, and there is no registration fee. Click here to register.

If you have any questions, contact Megan McGuire at the OBA at or (405) 424-5252.

Date: Friday, Aug. 17 at 11:30 a.m.
Location: Oklahoma City Branch, Federal Reserve Bank of Kansas City
Address: 211 North Robinson, Two Leadership Square, Suite 300, Oklahoma City, OK 73102

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OBA education corner …

Hot enough for ya, yet?! Stay inside, where it’s cool – and while you’re in there, take advantage of one of the OBA’s many webinar offerings this summer! Take note of the following:

  • ATM Cashout Scams, July 12, webinar —  This session is intended to ensure that ATM security has moved up on your radar and been properly integrated into your risk assessment program/
  • Dealing with Subpoenas, Summonses, Garnishments, July 17, webinar — If you find these documents confusing and intimidating, attend this webinar to learn the best practices of how to deal effectively with these documents and the parties who serve them upon you.
  • Advanced Commercial Loan Documentation, July 18, webinar — Everything a commercial loan officer should know about the core commercial loan documentation package, including perfecting security interests on commercial collateral, loan agreements, signature requirements, loan closings and more.
  • Customer Due Diligence & Beneficial Owners: Two-Month Checkpoint, July 18, webinar — Gain help on formalizing and enhancing your due diligence program.
  • 2018 Loan Structure Documentation and Compliance, Aug. 15, Oklahoma City; Aug. 16, Tulsa — This full-day seminar will discuss loan structures for the bank.
  • 2018 CECL Update, Aug. 22, Oklahoma City — This half-day seminar will touch on what’s new involving CECL.
  • 2018 FDIC Outreach, Aug. 23, Oklahoma City — This full-day seminar will have information from the FDIC.
  • 2018 OBA Compliance School, Aug. 27-31, Oklahoma City — This school is designed to provide an extensive body of knowledge and information on consumer compliance that can contribute to the development of compliance officers and to their associated functions, both of which have become an integral and essential part of our evolutionary banking industry.

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