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Unfortunately yes, that is the case. Vacation is not legally required in the U.S. and because of that employers have a great deal of discretion in how they operate that leave program.
Now, some states have done away with the "use it or lose it" concept, meaning that once you have vacation in your bank, that can't be taken away. However, even in the most employee friendly states, they all still agree that an employer can cease further accrual (called an accrual cap). While it is semantics, the courts see a legally significant difference between taking away vacation that you have in a bank and discontinuing accrual on the back end.
Fair or not, that is the current condition of the law in even the most employee favorable states.
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