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    Control System And Bank Audit

    1

    INTRODUCTION

    BANK AND CONTROL

    AUDITING

    BANK AUDIT

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    INTRODUCTION TO BANK AND CONTROL SYSTEM

    BANKING:

    Banking has been defined in section 5 of the act as the accepting,for the purpose of lending or investment, of deposits of money from the public, repayable

    on demand or otherwise, and withdraw able by cheque, draft, order or otherwise.

    A Banking company or a Bank means any company, which transacts the

    business of banking in India, and includes a foreign company, engaged in the business of

    banking in India.

    There are four types of banking institutions in India. These are:

    1) Commercial banks

    Commercial banks are the most prevalent banking

    institutions in India. Commercial banks operating in India can be divided into two

    categories based on their ownership-public sector and private sector banks.

    2) Regional rural banks (RRBs) -

    RRBs have been established with a view to

    developing the rural economy by providing credit and other facilities, particularly

    to the farmers.

    3) Co-operative Banks -

    Co-operative banks are the banks in the Co-operative

    sector, which cater predominantly to the needs of the farming, and allied sectors.

    Co-operative banks include central Co-operative banks, state Co-operative banks,

    primary Co-operative banks and land development banks.

    4) Development banks -

    Development banks were started for providing only long-

    term finance for development purposes; they are also referred as Term-lending

    institutions.

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    Important features

    Banks have the following characteristics, which distinguish them from most other

    commercial enterprises.

    1. They have custody of large quantum of monetary items, Including cash and

    negotiable instruments, whose physical security has to be ensured This applies to

    both the storage and the transfer of monetary items and makes banks vulnerable to

    misappropriation and fraud. They, therefore, need to establish formal operating

    procedures, well-defined limits for individual discretion and rigorous systems of

    internal control

    2. They engage in a large quantum and variety of transactions in terms of both

    number and value. This therefore requires complex accounting and internal

    control systems.

    3. They generally operate through a wide network of branches and departments

    which are geographically dispersed.

    4. Banks are regulated by governmental authorities and the resultant regulatory

    requirements often influence accounting and auditing practices in the banking

    sector.

    Regulatory framework

    There is an elaborate regulatory framework governing banks in

    India. The principal enactments which govern the functioning of various types of banks

    are:

    Banking Regulation Act, 1949

    Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970

    Banking Companies (Acquisition and Transfer of Undertakings) Act, 1980

    SBIAct, 1955

    SBI (Subsidiary Banks) Act, 1959 Regional Rural Banks Act, 1976

    Companies Act, 1956

    Co-operative Societies Act, 1912 or the relevant state Co-operative Societies Act.

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    INTRODUCTION-an overview of Auditing

    Economic decisions in every society must be based upon the information available

    at the time the decision is made. For example, the decision of a bank to make a loan to abusiness is based upon previous financial relationships with that business, the financial

    condition of the company as reflected by its financial statements and other factors

    If decisions are to be consistent with the intention of the decision makers, the information

    used in the decision process must be reliable. Unreliable information can cause inefficient

    use of resources to the detriment of the society and to the decision makers themselves. In

    the lending decision example, assume that the bank makes the loan on the basis of

    misleading financial statements and the Borrower Company is ultimately unable to

    repay. As a result the bank has lost both the principal and the interest. In addition,

    another company that could have used the funds effectively was deprived of.the

    money.

    As a means of overcoming the problem of unreliable information, the decision-

    maker must develop a method of assuring him that the information is sufficiently reliable

    for these decisions. In doing this he must weigh the cost of obtaining more reliable

    information against the expected benefits.

    A common way to obtain such reliable information is to have some type of verification

    (audit) performed by independent persons. The audited information is then used in the

    decision making process on the assumption that it is reasonably complete, accurate and

    unbiased.

    The word Audit is derived from the Latin word Audire which means to

    here. In olden days, whenever the owner of the business suspects the frauds, they

    appoint independent and impartial person who uses to hear the explanation given by the

    accountant. Such person was known as Auditor.

    Auditing may be defined as,

    A careful and critical examination of books of accounts by a

    properly qualified person on the basis of proper evidence so as to express an opinion (i.e.

    views) about the truth and fairness of financial statements.

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    TYPES OF AUDIT

    The entire process of audit depends upon the type of audit. Type of audit to be

    conducted is to be selected carefully, keeping in mind the objects of audit in each and every

    case. Hence it is essential to study the various types of audit before laying down the

    programme for any audit work.

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    CHART SHOWING DIFFERENTCLASSES OF AUDIT

    BASED ON

    AUTHORITY

    Y

    BASED ON

    SCOPE

    BASED ONTIME

    BASED ON OTHEROBJECT TYPES

    Statutory Non-Statutory InternalAudit Audit Audit

    Complete PartialAudit Audit

    Continuous Final InterimAudit Audit Audit

    Special Cost Management SocialAudit Audit Audit Audit

    Balance Sheet Occasional Audit In Cash Operational

    Audit Audit Depth Audit Audit

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    BASED ON AUTHORITY:

    1) Statutory Audit

    It is the audit, which is compulsory under the law*Appointment ofauditors,

    removal, Remuneration, rights, duties, and liabilities are governed as per the

    provisions 'of the respective law applicable to the organisation. Scope of audit work

    and all other terms are as laid down by the law. It can be conducted only by a

    qualified Chartered Accountant.

    2) Non-Statutory Audit

    Non-statutory audits are voluntary audits. These audits are not compulsory under

    any law. Terms and conditions of audit are determined as per the agreement made between

    the auditor and proprietor for e.g. financial audit of a sole trader or partnership firm. It also

    includes non-financial audits e.g. internal audit, management audit, Operational audit,

    Social audit, etc.

    a) Private Audit

    The audit which is done for the satisfaction of the owner Is called

    private audit. This type of audit is not compulsory at all. It may be conducted by

    sole proprietors, partnership firms, family trusts, private trusts, etc. The various types of

    private audit are

    i) Audit of Sole Proprietor

    Audit of accounts of a sole-proprietor is not compulsory. However, he

    may get his books audited for various reasons. Some of the reasons are: -

    1) For obtaining loan from bank and financial institutions.

    2) For presenting authentic data to income tax and Sales tax authorities.

    3) For his own satisfaction that his employees have written the books of accounts

    properly and that there are no frauds and errors.

    ii) Audit of partnership firms

    1) Under partnership Act it is not compulsory to audit the accounts. However in actual

    practice it is not only advisable but even necessary to get them audited

    2) It helps to prevent disputes among the partners.

    3) It facilitates borrowing frombanks

    4) Audited accounts are preferred by income tax and sales tax departments.

    5) Audited accounts can be helpful in case of litigation.

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    3) Internal Audit

    This type of audit is also optional. It is conducted by the internal auditor who is

    appointed by the proprietor. Even the employee of the organisation may be appointed as

    an internal auditor to examine the books of accounts. All the terms and conditions of audit

    work are determined by the agreement. The basic purpose of internal audit is not only to

    examine the books of accounts but also to review the present working and make valuable

    suggestions to improve it.

    BASED ON SCOPE:

    1) Complete Audit

    In complete audit the auditor have to check each and every transaction,

    voucher document etc. relating to the transactions of business. This types of audit

    is not possible in case of large business organizations.

    2) Partial Audit

    Sometimes auditor may be called upon to audit few books and give his

    finding thereon. Sometimes he may be called upon to audit only the payment

    side of cashbook or receipts side only. This is called as Partial Audit. Auditor has

    to be very careful when he undertakes this type of audit. Usually this type ofaudit is called for when a fraud or misappropriation is" suspected. While

    submitting the report auditor should clearly mention -the scope and documents

    or books made available to him for his audit. Partial audit is not practical. Such

    an audits possible where audit is not a legal necessity.

    BASED ON TIME:

    1) CONTINUOUS AUDIT

    One where the auditor, or his staff, is constantly engaged in checking the

    accounts during the whole period or where the auditor or his staff attends at regular or

    irregular intervals during the period.

    Continuous audit means an audit at regular intervals throughout the

    accounting year. Continuous audit, accounting and auditing work is done side by

    side.

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    (2) FINAL /ANNUAL /PERIODICAL / COMPLETED AUDIT:

    Periodic audit is also known as 'final or completed audit'. Final audit is carried out

    continuously until it is completed. It is a past accounts audit. In case of a final audit, the

    auditor gets hold of all the books of accounts and the vouchers for the, accountingPeriod. He is in possession of all the facts and figures relating to the accounting period for

    which the audit is being conducted. In case of this audit, the auditor visits the clients place

    only once and remains there till the audit is over.

    Generally this type of audit is appropriate for smaller business concerns. Generally

    majority of audits are in the nature of Final Audits.

    (3) INTERIM AUDIT:

    It is a kind of audit, which is conducted in between the annual or final audits. It is

    conducted to find out the interim profit and know the financial 'position at the end of a

    part of the accounting year. This is usually carried out at half yearly intervals. Hence, this is

    also called as half yearly audit.

    BASSED ON OBJECT :

    1) SPECIAL AUDIT

    Under section 233 A of companies Act, the central government has power to direct

    special audit under following circumstances:

    a) When the affairs of any company are not managed as per the sound business

    principles.

    b) When the financial position of the company is such as to endanger its solvency.

    c) When company is being managed in a manner which is likely to cause serious

    injury or damage to the interest of trade or industry

    The auditor appointed by the government is required to report to the government.

    2) COST AUDIT

    It is a type of audit, which involves verification of cost records maintained by the

    organisation. Under section 233 B of the companies Act, 1956 the central government may

    direct an audit of cost records by a person who is qualified. Appointment of auditor is done

    by the board of director subject to the approval of the central government. The auditors repot

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    to the government, the copy of the report is send to the company. It has been defined as the

    verification of the correctness of cost accounts and of adherence to the cost accounting plan.

    3) Management audit:-

    'Management auditing is concerned with review of operations and performance of

    management to improve efficiency and effectiveness of the organisation. It is, thus, an

    extension of internal audit function. Some authors use the terms management auditing

    and operational auditing interchangeably because of the close resemblance of

    methodology employed. But it may be noted, although operational auditing is also

    concerned with review of operations of an entity, management auditing, in addition to it

    also includes review of managerial performance. Secondly, the frame of reference of a

    management audit is derived, generally, from the expectations of the external

    participants and not of organisation's management as in case of operational auditing.

    4) Social audit

    Social audit is a recent development in the field of at it is based on the

    modern concept of social responsibility of business. Social audit examines to what extent

    the business is discharging the social responsibilities. It examines the contribution of the

    concern to the society at large.

    Other types:

    1) Balance sheet Audit

    Balance Sheet audit is of a recent origin. It has acquired popularity in U.S.A.

    As the very name suggests, balance sheet audit consists of verification of all the items

    appearing in the balance sheet such as assets, capital, reserves and liabilities of the business.

    Under 'balance sheet audit, the auditor commences audit on the basis of the Balance sheet,

    and he works back to the books of original entry and other evidences. Though balance sheet

    audit concentrates mainly on balance sheet items, it also includes an examination of those

    transactions, which are appearing in the Profit and Loss Account because balance of Profit

    and Loss Account appears in the balance sheet. Thus, in balance sheet audit all the items

    contained in the balance sheet and other related or allied items are verified completely. The

    auditor' will check up general ledger also

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    (2) Occasional audit: -

    This type of audit is carried out occasionally as per the need of the business, T1V

    applicable to the proprietary concerns such as sole traders and partnerships, it is just a need-

    based audit. It is conducted at the desire of the owner of the business. This of audit is not

    possible in case of Joint Stock Company as the annual au; compulsory as provided in

    Companies Act, 1956.

    (3) Audit in Depth

    Under this type of audit, the auditor examines thoroughly selected transactions

    right from their origin to the conclusion. All records and documents pertaining to the

    transactions are checked in detail. The basic purpose of this type of audit is to

    whether the system of internal check or control system is effective. This type of audit

    enables the auditor to suggest to the management a better procedure for recording the

    transactions to avoid any loopholes for committing frauds.

    4) Cash Audit

    Here the auditor examines only cash transactions. He examines cash receipts and cash

    payments. Cash transactions are checked with the help of receipts and vouchers and other

    evidences. The receipts and payments may be capital or revenue in nature.

    5) Operational Audit

    Operational audit goes beyond financial audit. It is conducted to see that the business

    operations are improved in future. It guides the management in achieving

    organizational objectives

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    INTRODUCTION TO BANK AUDIT

    Bank Audit is a time bound exercise and it is full of challenges and

    responsibilities. For those who approach this exercise with scientific methods and properplanning The auditor has very limited option as far as the availability of time is

    concerned, therefore, the only option he has is to carry out the audit in a very scientific

    manner so that he is able to conduct a purposeful audit in the limited time.

    Generally, the appointment letters are received in second or third week of March

    and the auditors are expected to commence the audit in the first week of April and to

    complete the audit, in one visit and in all respect, by the end of second week of April.

    Therefore, the time available for the completion of audit in all respects is generally in the

    range of 4-5 days to a maximum of a week or 10 days, irrespective of the size of the

    branch, volume of business and nature of activities.

    The banks are taking effective measures to address this issue and some banks

    have allowed the auditors of large and very large branches to visit the respective branches

    before the close of the year. Such visits help the auditors to gather lot of first hand

    information and insight about the branch and its business profile, performance, NPA

    profile, client profile, level of computerization, etc.

    Generally, banks circulate detailed closing instructions to the branches and the

    auditors well in advance. It is important to review the instructions and to incorporate the

    significant instructions in the audit plan/programme/checklist.

    With the latest information available at the touch of button, it is very important that to

    keep update about the significant developments in the banking sector and to incorporate

    all the significant developments in the audit programme/checklist.

    As the concept of Peer Review is already put in place, it is important that while

    carrying out the attest function due emphasis is given to Auditing & Assurance Standards

    and other pronouncements of the Institute while discharging the attest function. Apart

    from this, it is also important to preserve all the required documents/representations etc.

    for future reference.

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    2

    CONTROL SYSTEMS

    BANKING REGULATION ACT, 1949

    CORPORATE GOVERNANCE

    GOSH COMMITTEE RECOMMENDATIONS

    AUDITING & ASSUARANCE STANDARDS(AAS)XX

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    Controls and Regulations (banking regulation act, 1949)

    CAPITAL RESERVES

    Section 11 of the Banking Regulation Act lays down the requirements regarding

    the minimum paid-up share capital and reserves of banking companies. Similar

    requirements in the case of cooperative banks are laid down in section 56(h). These

    provisions are not applicable to rural banks, nationalised banks, and the State Bank Of

    India and its subsidiaries.

    Under section 12(1), the subscribed capital of a banking company should not be

    less than one-half of its authorized capital and the paid-up capital not less than one-half of

    the subscribed capital. If the capital is increased, it should comply with these conditions

    within a stipulated time period. Further, the capital of a banking company should consist

    of ordinary shares alone, the only exception being in the case of preference shares issued

    prior to July 1, 1944. These provisions do not apply to a banking company incorporated

    before January 15, 1937 or to a nationalised bank, a regional rural bank, a cooperative

    bank, and the State bank Of India and its subsidiaries.

    A banking company incorporated outside India is required to deposit with the

    Reserve bank in the form of cash and/or approved securities, (a) an amount not less than

    the minimum paid-up capital and reserves as prescribed under section 11(2) of the

    Banking Regulation Act (1949), and (b) an amount equal to 20 percent of its profits for

    each year in respect of all business transacted through its branches in India. However, the

    central government may, on the recommendation of the Reserve Bank, exempt a banking

    company from these requirements for a specified period having regard to the adequacy of

    the total amounts deposited by it with the Reserve Bank in relation to its deposit

    liabilities.

    Restriction on commission, brokerage, discount, etc. on sale of shares.

    Notwithstanding anything to the contrary contained in 3[Secs. 76 and 79 of the

    Companies Act, 1956 (1 of 1956)], no banking company shall pay out directly or

    indirectly by way of commission, brokerage, discount of remuneration in any form in

    respect of any shares, issued by it, any amount exceeding in the aggregate two and one-

    half per cent. of the paid-up value of the said shares.

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    Cash reserve.

    Every banking company, not being a scheduled bank, shall maintain in India by

    way of cash reserve with itself or by way of balance in a current account with the Reserve

    Bank or by way of net balance in current accounts or in one or more of the aforesaid

    ways, a sum equivalent, to at least three percent Of the total of its demand and time

    liabilities in India as on the last Friday of the second preceding fortnight and shall submit

    to the Reserve Bank before the twentieth day of every month a return showing the amount

    so held on alternate Fridays during a month with particulars of its demand and time

    liabilities in India on such Fridays or if any such Friday is a public holiday under the

    Negotiable Instruments Act, 1881(26 of 1881), at the close of business on the preceding

    working day.

    Restrictions on loans and advances.

    (1) Notwithstanding anything to the contrary

    contained in Sec. 77 of the Companies Act, 1956 (1 of 1956), no banking company shall,

    (a) Grant any loans or advances on the security of its own shares, or

    (b) Enter into any commitment for granting any loan or advance or advance to or on

    behalf of

    (i) Any of its directors,

    (ii) Any firm in which any of its directors is interested as partner, manager,

    employee or guarantor, or

    (iii) Any company (not being a subsidiary of the banking company or a company

    registered under Sec. 25 of the Companies Act, 1956 (1 of 1956), or a Government

    company)] of which 2[or the subsidiary or the holding company of which] any of the

    directors of the banking company is a director, managing agent, manager, employee or

    guarantor or in which he holds substantial interest, or

    (iv) Any individual in respect of whom any of its directors is a partner or

    guarantor.

    (2) Where any loan or advance granted by a banking company is such that a commitment

    for granting it could not have been made if Cl.(b)of sub-section (1) had been in force on

    the date on which the loan or advance was made, or is granted by a banking company

    after the commencement of Sec. 5 of the Banking Laws (Amendment) Act, 1968 (58 of

    1968), but in pursuance of a commencement of Sec. 5 of the Banking Laws (Amendment)

    Act, 1968(58 of 1968), but in pursuance of a commitment entered into before such

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    commencement, steps shall be taken to recover the amounts due to the banking company

    on account of the loan or advance together with interest, if any, due thereon within the

    period stipulated at the time of the grant of the loan or advance, or where no such period

    has been stipulated, before the expiry of one year from the commencement of the said

    Sec. 5:

    (3) No loan or advance, referred to in sub-section (2), or any part thereof shall be remitted

    without the previous approval of the Reserve Bank, and any remission without such

    approval shall be void and of no effect.

    (4) Where any loan or advance referred to in sub-section (2), payable by any person, has

    not been repaid to the banking company within the period specified in that sub-section,

    then such person shall, if he is a director of such banking company on the date of the

    expiry of the said period, be deemed to have vacated his office as such on the said date.

    CONTROL OVER MANAGEMENT

    36-AA. Power of Reserve Bank to remove managerial and other persons from office .

    (1) Where the Reserve Bank is satisfied that in the public interest or for preventing the

    affairs of a banking company being conducted in a manner detrimental to the interests

    of the depositors or for securing the proper management of any banking company it is

    necessary so to do, the Reserve Bank may, for reasons to be recorded in writing, by

    order remove from office, with effect from such date as may be specified in the order

    3[any chairman, director,] chief executive officer (by whatever name called) or other

    officer or employee of the banking company.

    (2) No order under sub-section (1) shall be made 4[unless the chairman, director] or chief

    executive officer or other officer or employee concerned has been given a reasonable

    opportunity of making a representation to the Reserve Bank against the proposed

    order:

    Provided that if in the opinion of the Reserve Bank, any delay would be detrimental to

    the interests of the banking company or its depositors the Reserve Bank may, at the

    time of giving the opportunity aforesaid or at any time thereafter, by order direct, that

    pending the consideration of the representation aforesaid, if any 5[the chairman or, as

    the case maybe director or chief executive officer] or other officer or employee, shall

    not, with effect from the date of such order.

    (a) 6[act as such chairman or director] or chief executive officer or other officer or

    employee of the banking company;

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    (b) in any way, whether directly or indirectly be concerned with, or take part in

    the management of, the banking company.

    (3) If any person in respect of whom an order is made by the Reserve Bank under

    subsection (1) or under the provison to sub-section (2) contravenes the provisions of

    this section, he shall be punishable with fine which may extend to two hundred and

    fifty rupees for each day during which such contravention continues.

    (4) Any person appointed as 1[chairman, director or chief executive officer] or other

    officer or employee under this section shall

    (a) Hold office during the pleasure of the Reserve Bank and subject thereto for a

    period not exceeding three years or such further periods not exceeding three years at a

    time as the Reserve Bank may specify;

    (b) Not incur any obligation or liability by reason only of his being a 5[chairman,

    director or chief executive officer] or other officer or employee or for anything done

    or omitted to be done in good faith in the execution of the duties of his office or in

    relation thereto.

    (5) Notwithstanding anything contained in any law or in any contract, memorandum or

    articles of association, on the removal of a person from office under this section that

    person shall not be entitled to claim any compensation the loss or termination of

    office.

    Power to inspect.

    (1) The Reserve Bank shall, on being directed so to do by the Central Government or by

    the High Court, cause an inspection to be made by one or more of its officers of a

    banking company which is being wound up and its books and accounts.

    (2) On such inspection, the Reserve Bank shall submit its report to the Central

    Government and the High Court.

    (3) If the Central Government, on consideration of the report of the Reserve Bank, is of

    opinion that there has been a substantial irregularity in the winding-up proceedings, it

    may bring such irregularity to the notice of the High Court for such action as the High

    Court may think fit.

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    CORPORATE GOVERNANCE:

    Goodcorporate governance is the only alternative available before the Indian

    corporate sectary and more particularly, banks both commercial and co-operativesector to come atpar with international standards. But, some seriousthought has to

    be given to bring certain amount of norm in governanceof the countryspolitical

    system.

    Corporate Governance has been defined in different ways by different thinkers

    and experts.

    According to noble Laureate Milion Friedman "Corporate Governance is to

    conduct the business in accordance with owner or shareholders' desires, which generally

    will be to make as much money as possible, while conforming to the basic rules of the

    society embodied in law and local customs". This definition is narrow in scope as it gives

    more importance to the owners' stake. Over a period of time, with fast developments in

    the world, the .scope of the corporate governance has widened. It now encompasses the

    interest of not only the owners but also many other stakeholders.

    The OECD experts have defined, "Corporate Governance as the system by which

    corporations are directed and controlled. The corporate governance specifies the

    distribution of rights and responsibilities among different parties in the corporation, such

    as, the Board, managers, shareholders and other stakeholders, and spell out the rules and

    procedures for making decisions on corporate affairs. In simple words, corporate

    governance is not just profit making, but behaving responsibly, protecting environment,

    promoting healthy competition and preventing networth erosion. Corporate governance

    cannot be explained by a set of hard and fast rules or standards. The crux of corporate

    democracy lies in the accountable business leadership. Its main aim-is to maintain a

    balance between economic and social goals and between individual and commercial

    goals. According to Mr. J. Wclfensohn, President, World Bank, "Corporate Governance is

    about promoting corporate fairness, transparency and accountability".

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    HISTORICAL BACKGROUND:

    The emergence of modern corporate governance is traced back to the Watergate

    Scandal in USA. At that time, on investigation, the U.S. regulatory and legislative bodies

    were able to highlight control failures that had allowed several major corporations to

    make illegal political contributions and to bribe government officials. As a consequence

    to this. Foreign and Corrupt Practices Act of 1977 was introduced in USA. that contained

    specific provisions regarding the establishment, maintenance and review of a system of

    internal controls. Thereafter, a number of other measures were initiated for internal

    financial controls and the most important was Headway Commission after the collapse of

    Savings and Loans in USA. The 'Headway Commission submitted its report in 1987 and

    stressed for the need for a proper control environment, independent audit committees and

    an objective Internal Audit Function.

    The corporate world in India cannot remain indifferent to the development around

    the world. The collapse of South East Asian economies in 1997 made corporate

    governance a very vital issue for corporate world. With the fast growth of economy,

    corruption is bound to emerge and it is considered as a part of growing economy. In

    developing countries, the resources have to be prioritized as required by the policy

    makers. Corruption and economic development cannot go hand in hand. If a country is

    considered to be corrupt, it may not attract foreign investment. Good corporate

    governance is important for running a business on sound ethical values. In the words of

    Mr. Deepak Parekh, ethics means, "Not doing a thing one would be ashamed of if it

    becomes public".

    The only good governance available in the banking sector was the ground rules

    and Code of Ethics known as G R A CE, indection of professional directors, redressal of

    custom complaints through Ombudsman and functioning of Audit committee of the

    Board. The banks enjoyed full protection. They were not exposed to any competition and

    there was hardly any concept of transparency and accountability. This became a breeding

    ground for malpractices and led to inefficiency due to economic compulsions and

    pressure, the Government of India compelled to open Indian economy and introduce

    prudential Accounting Norms, as suggested by Narasimham Committee in its report

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    submitted to RBI in 1990. A new challenge emerged, which led to reform in the Indian

    banking system so as to bring it at par to international standards as required under BIS

    norms.

    CRITICAL ISSUES: -

    Apart from the emerging challenges, a few issues having policy implications

    continue to remain shrouded in controversy. primarily, they relate to the following areas:

    a) Government Ownership: government ownership of the banking sector creates a

    number of problems for RBI as the regulator. The problems are particularly

    complex because the government often acts as quasi-regulator. Therefore, it is to

    be decides whether good governance is compatible with government ownership.

    b) Checks and Balances: in India, in most banks, the chairman and CEO positions

    are combined. This may create concentration of power in a single individual. It

    has been suggested that the roles of the Chairman and CEO be separated.

    c) RBI and Government nominee directors: whether RBI can effectively perform

    its role as supervisor, when it is also represented on the board through its nominee

    director, which may lead to conflict of interest with its regulatory function. More

    so, since the nominee of RBI and government are treated as superior to other

    directors.

    d) Sectoral representation: considering the current trend of liberalization, the

    reorientation given to various interest groups in the board for protection of there

    sectional economic interests, may have to be reviewed.

    e) Quality and proportion of non-executive director: only individuals of proven

    professional competence and experience and with special insight into specific

    economic activities may be appointed as non-executive directors. The optimum

    proportion of executive and non-executive directors continues to be a matter of

    debate.

    f) Delay in Filling up vacancies in the board: In many cases There is long delay in

    filling up the vacancies in the board, which cripples its efficient functioning.

    g) Ceiling on number of members in board: the size of the board should be too un

    wieldy so as hamper its cohesiveness.

    h) Disparities in remuneration of whole time directors: normally, the whole time

    directors of PSU banks are remunerated very poorly compared to there private

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    3.4 Precautions for averting frauds in

    areas of letters of

    credit, issue of

    guarantees and co-

    acceptance facilities

    The RBI vide its Cir. No. DBOD. No. GC.

    SIC. BC. 97/C.408(A)-83 date 26-11-1983 has

    advised the banks to follow the following

    precautions for opening LCs, issuing BGs

    and co-acceptance of Bills.

    (a) LCs, BGs facility should be given only

    to the customers having regular credit

    facilities and if the customers do not

    have regular credit facilities, the

    proposal should be appraised like any

    other credit proposal.

    (b) Before establishing LC, the bank

    should examine the financial position

    of the customer, his ability to meet the

    required funds for retirement of bills onpresentation.

    (c) The bank should obtain suitable margin andother security.

    (d) If the customer is enjoying credit facilities orhaving account with other banks, withoutreference and concurrence of such other

    bank, LC should not be opened.

    (e) LC should not be established on theguarantee of another bank.

    (f) For performance guarantee, the bank shouldexamine the capacity and means to

    perform the obligation under guarantee.(g) With respect to co-acceptance of

    bills, the following guide-lines are

    given by RBI.

    i) The need for sanctioning such

    facility should be thoroughly

    examined and sanctioned only

    to the customers having other

    credit facilities.

    ii) Genuine trade bills only to be

    co-accepted, it should be

    ensured that the stocks covered

    bills are reflected in the stock

    statements of the customer.

    iii) Accommodation bills, house bills,

    bills of group concerns should

    not be co-accepted.

    iv) Proper records are to bemaintained for recording the bills

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    8.14 Monthly certificateof assisted units and

    on stocks pledged/

    hypothecated to

    bank.

    co-accepted.v) The powers to co-accept bills,

    beyond certain limits must beexerc ised by two officers jointly.

    The RBI vide its circular No. DBOD. No.

    Com. BC. 28/C.408(A)-81 dated 23-02-1981

    has advised the banks to lay down a system

    of submitting periodical returns/certificates

    to the controlling offices, say monthly,containing the information to show name of

    the borrowers, limits sanctioned, short

    description and value of the securities

    charged to the bank, date of inspection

    thereof names and signatures of the officials

    who carried out the inspection as also

    serious defects if any, observed by the

    officials during such inspection. The auditor

    should examine whether the branch is

    submitting such return to the controlling

    office every month.

    9.10 Fraud cases up to Rs.25,000/-having

    involvement of an

    insider should not

    be reported to Police,

    where the recovery isnot doubtful.

    With a view to expedite cases and award of

    punishments, the Committee desired that

    where a fraud for an amount not exceeding

    Rs. 25,000/- involving an employee of the

    bank is detected, and the recovery of the

    amount is not in doubt, the matter shouldnot be reported to the police.

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    AUDITING AND ASSUARANCE STANDARD (AAS) XX:

    The auditor should obtain an understanding of internal control relevant to

    the audit. The auditor uses the understanding of internal control to identify types of

    potential misstatements, consider factors that affect the risks of material misstatement,

    and design the nature, timing, and extent of further audit procedures. Internal control

    relevant to the audit is discussed below.

    Internal control, consists of the following components:

    (a) The control environment.

    (b) Control activities.

    (c) Monitoring of controls.

    Controls Relevant to the Audit

    1) There is a direct relationship between an entity's objectives and the controls it

    implements to provide reasonable assurance about their achievement. The entity's

    objectives, and therefore controls, relate to financial reporting, operations and

    compliance; however, not all of these objectives and controls are relevant to the audi-tor's risk assessment.

    2) Ordinarily, controls that are relevant to an audit pertain to the entity's objective of

    preparing financial statements for external purposes that give a true and fair view (or

    are presented fairly, in all material respects) in accordance with the applicable

    financial reporting framework and the management of risk that may give rise to a

    material misstatement in those financial statements. It is a matter of the auditor's

    professional judgment, subject to the requirements of this AAS, whether a control,

    individually or in combination with others, is relevant to the auditor's considerations

    in assessing the risks of material misstatement and designing and performing further

    procedures in response to assessed risks. In exercising that judgment, the auditor

    considers the circumstances, the applicable component and factors such as the

    following:

    The auditor's judgment about materiality.

    The size of the entity.

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    The nature of the entity's business, including its organization and ownership

    characteristics.

    The diversity and complexity of the entity's operations.

    Applicable legal and regulatory requirements.

    The nature and complexity of the systems that are part of the entity's internal control,

    including the use of service organizations.

    3) Controls relating to operations and compliance objectives may, however, be relevant

    to an audit if they pertain to data the auditor evaluates or uses in applying audit

    procedures. For example, controls pertaining to non-financial data that the auditor

    uses in analytical procedures, such as production statistics, or controls pertaining to

    detecting non-compliance with laws and regulations that may have a direct and

    material effect on the financial statements, such as controls over compliance with

    income tax laws and regulations used to determine the income tax provision, may be

    relevant to an audit.

    4) Internal control over safeguarding of assets against unauthorized acquisition, use, or

    disposition may include controls relating to financial reporting and operations

    objectives. In obtaining an understanding of each of the components of internal

    control, the auditor's consideration of safeguarding controls is generally limited to

    those relevant to the reliability of financial reporting. For example, use of access

    controls, such as passwords, that limit access to the data and programs that process

    cash disbursements may be relevant to a financial statement audit. Conversely,

    controls to prevent the excessive use of materials in production generally are not rel-

    evant to a financial statement audit.

    Control Activities

    1) The auditor should obtain a sufficient understanding of control activities to assess the

    risks of material mis-statement at the assertion level and to design further audit

    procedures responsive to assessed risks. Control activities are the policies and

    procedures that help ensure that management directives are carried out; for example,

    that necessary actions are taken to address risks that threaten the achievement of the

    entity's objectives. Control activities, whether within IT or manual systems, have

    various objectives and are applied at various organizational and functional levels.

    Examples of specific control activities include those relating to the following:

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    Authorization, Performance reviews, formation processing, Physical controls,

    Segregation of duties

    2) General IT-controls are policies and procedures that relate to many applications and

    support the effective functioning of application controls by helping to ensure the

    continued proper operation of information systems. General IT-controls that maintain

    the integrity of information and security of data commonly include controls over the

    following:

    Data centre and network operations.

    System software acquisition, change and maintenance.

    Access security.

    Application system acquisition, development, and maintenance.

    The auditor should document:

    The manner in which these matters are documented is for the auditor to

    determine using professional judgment. In particular, the results of the risk assessment

    may be documented separately, or may be documented as part of the auditor's

    documentation of further procedures. Examples of common techniques, used alone or in

    combination include narrative descriptions, questionnaires, check lists and flow

    charts. Such techniques may also be useful in documenting the auditor's assessment of

    the risks of material misstatement at the overall financial statement and assertions level.

    For example, documentation of the understanding of a complex information system in

    which a large volume of transactions are electronically initiated, recorded, processed, or

    reported may include flowcharts, questionnaires, or decision tables. For an information

    system making limited or no use of IT or for which few transactions are processed (say,

    long-term debt), documentation in the form of a memorandum may be sufficient.

    Ordinarily, the more complex the entity and the more extensive the audit procedures

    performed by the auditor, the more extensive the auditor's documentation will be. AAS 3,

    "Documentation" provides guidance regarding documentation in the context of the audit

    of financial statements.

    Effective Date

    This Auditing and Assurance Standards is effective for audits related to

    accounting periods beginning on or after 1st April, 2007.

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    Control System And Bank Audit

    PREPARATION AND PLANNING FOR AUDIT

    The audit preparation and planning should start immediately on receipt of the

    appointment letter and the auditor should not wait until actual commencement of audit forthe same. The various stages involved in audit preparation and planning and the other

    related issues have been discussed below in detail.

    STAGE I: AT THE OFFICE

    UNDERSTANDING THE BASIC SCOPE OF AUDIT:

    Broadly the scope of audit can be divided into three main parts:

    1.Authentication of closing returns such as:

    a) Balance Sheet.

    b) Profit and Loss Account either for the full year or for two half years.

    c) Master Summary of advances containing asset classification.

    d) Statement of furniture/fixtures, computers, etc.and depreciation.

    e) Statement of Capital Adequacy.

    f) Statement of maturity pattern of loans & advances and deposits.

    g) Statement of maturity pattern of foreign currency assets and liabilities.

    h) Statement of maturity pattern of borrowings.

    i) Statement of cash and bank balance on twelve odd dates.

    j) Statement of lending to sensitive sectors.

    k) Statement of movements in NPA.

    1) Statement of advances made by rural branches.

    2. Issuance of certificates in relation to:

    a) Claim for PMRY subsidy.

    b) Refund of DICGC claim.

    c) Asset classification, income recognition and provisioning.

    d) Memorandum of Changes (MOC) for previous year.

    e) Investments, if any, held on behalf of Head office.

    3. Issuance of reports including special purpose reports/certificates such as:

    a) Auditors Report.

    b) Long Form Audit Report.

    c) Tax Audit Report.

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    d) Compliance certificate in respect of implementation of recommendations of Ghosh

    & Jilani Committees.

    The scope is illustrative and not exhaustive and it may differ from bank to bank.

    COMMUNICATION WITH THE BRANCH

    Generally, the appointment letter issued by the HO/CO also contains the details

    like complete postal address and contact numbers of the branch, name of the branch head,

    business portfolio of the branch, etc. If these details are not mentioned in the appointment

    letter, the same must be obtained.

    Depending upon the business profile of the branch, the auditor must issue written

    communication for all the audit requirements to the branch.

    PREPARATION OF AUDIT PROGRAMME

    1. While preparing/updating audit programme due importance must be given to

    a) Auditing & Assurance Standards and other pronouncements of the Institute.

    b) Provisions of the governing statutes.

    c) Latest closing instructions.

    d) Latest business profile.

    e) Audited and un-audited financial statements.

    f) LFAR for the previous year.

    g) Guidelines and circulars issued by RBI.

    h) Past experience of bank audit.

    2. Generally, the information about the closing returns to be signed and certificates and

    reports to be issued is mentioned in the appointment letter and/or the closing instructions

    issued by the HO/CO. It must be ensured that all this information is properly

    updated/incorporated in the audit programme and all the related instructions for the

    closing returns, certificates, reports, etc., are incorporated in the audit checklist.

    3. As most of the branches/operations are computerized, due emphasis must be given

    to the level of computerization at the branch level. The audit approach in case of a

    computerized branch is totally different from the one adopted in case of the branch

    maintaining manual records.

    4. The audit programme must be flexible and have substantial scope for

    modification/revision during the course of audit.

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    Control System And Bank Audit

    EXECUTION OF AUDIT

    During execution of audit, following important aspects must be borne in mind:

    1. The audit programme and the checklists must be suitably updated/ modified in the

    light of the understanding gathered about the overall functioning of the branch.

    2. The audit observations must be discussed on a daily basis.

    4. The documentation and proper filing must be given due importance. All the audit

    memos along with the supporting documents must be systematically filed on a daily

    basis.

    5. The final issues affecting the true and fair view and other disclosures must be

    discussed with the branch management.

    COMPLETION OF AUDIT

    At the final stage, the following important aspects must be borne in mind:

    1. The auditor must ensure that all the audited closing returns, reports and certificates

    have been duly signed and stamped.

    2. It must be ensured that LFAR has also been prepared and discussed with the branch.

    3. Tax audit must also be completed during the course of statutory audit, as no separate

    visit is allowed for the same.

    4. The copies of the audited closing returns, reports and certificates are obtained for the

    purpose of filing.

    5. Necessary representation letter must be obtained from the branch management.

    6. In case the Bank requires Attendance Certificate to be submitted along with the bill,

    ensure that the same has been obtained in the prescribed format.

    AUDIT OF BL. AND P&L:

    The statutory audit of banks and their branches is generally described as Balance

    Sheet Audit.The audit procedures followed in case of banks are to some extent different

    from those followed in case of other entities. The reason being the system of accounting

    followed and the nature of records maintained by the banks. Before we proceed with the

    Balance Sheet and the Profit & Loss Account, it is advisable to gain an understanding of

    accounting system and the nature of records of the branch.

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    SPECIFIC AUDIT APPROACH FOR MAJOR ITEMS OF BALANCE SHEET

    PART I: ASSETS

    1. Cash

    a) Evaluate the effectiveness of internal controls being exercised by the branch by

    making enquiries about the daily verification of cash at the opening and the

    closing hours, maintenance of cash related registers and vault regi'ster, safety of

    cash cabin, dual custody of cash, safe keeping of vault and cash box keys,

    recording of movements of keys, dual custody of the keys, security arrangements

    for cash movements, decoy money, daily cash holding and retention limit, etc.

    b) Review the reports of the concurrent auditors to ascertain the level and

    effectiveness of internal controls and also ascertain the frequency of cash

    verification carried out by the concurrent auditors.

    c) Verify the closing cash balance at the branch and the extension counter/ATM

    center connected to the branch as on the last day of the year or as of any day

    during the course of audit in the presence of the cashier and the manager.

    2. Balances with Reserve Bank of India, State Bank of India and other Banks

    Verify the balances as per the books with the balance confirmation certificates

    received from these banks.Ensure that the matters to be reported in LFAR have been duly

    verified and incorporated.

    3. Money at call and short Notice

    Generally these assets are not held or dealt with at the branch level.

    4. Investments

    Generally these assets are not held or dealt with at the branch level.

    5. Advances

    The audit approach in respect of advances is covered in detail in audit of

    advances

    6. Furnitures, fixtures, computers and office equipments

    a) Evaluate the effectiveness of internal controls over acquisition, recording,

    identification, safeguarding and periodic verification of these items.

    b) Verify the major additions and deletions/disposals with the related supporting

    documents such as invoices, challans, etc.

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    7. Other asset - Inter Office adjustments (NET)

    a) Understand the basic nature of such transactions, the relevance thereof for the

    overall presentation of financial statements and the procedure for recording such

    transactions.

    b) Ensure that the closing balance shown in the statement of the last day of the year

    tallies with the corresponding balance in General Ledger.

    c) Comment of very old and high value un-reconciled items.

    8. Other asset - Interest accrued

    Ascertain the system of accruing interest on advances in the computerized branch

    in the light of RBI guidelines for monthly charging of interest.

    9. Other asset - Suspense account

    a) Understand the guidelines issued by HO for operating suspense account.

    b) Obtain the details of entries/items outstanding as at the year-end.

    c) Identify the provision to be made in respect of very old entries.

    d) Ensure that the matters to be reported in LFAR have been duly verified and

    incorporated.

    10. Other asset - Stationery and stamps

    Evaluate the effectiveness of internal controls exercised by the branch for

    acquisition, recording, usage, physical verification, dual custody, access, etc., for stamps,

    deposit receipts, drafts, pay-orders, cheque books, traveller's cheques, gift cheques, etc.

    12. Other asset - Miscellaneous debits in Government accounts

    Generally the balance outstanding in this account indicates the pending claims to

    be received from the Government towards pension, provident fund, etc., paid by the

    branch on behalf of the Government.

    13. Other asset - Security deposits

    It relates to telephone deposit, mobile deposit, electricity deposit, deposit paid to

    the landlord for leased premises, etc.

    PART II: LIABILITIES

    1. Deposits

    a) Ensure that the balances as per the subsidiary ledgers of various deposit accounts

    are duly balanced and tallied with the respective balances in the general ledger. Any

    difference in the balancing should be reported in the audit report.

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    b) Understand the types of various deposits held by the branch and the salient

    features of those deposits with reference to the due dates for application, accrual,

    compounding and payment of interest.

    c) Ascertain that the branch has complied with the RBI guidelines related to opening

    and maintenance of deposit accounts including NRI deposit accounts. More

    emphasis should be given to KYC norms, operations in new accounts, heavy cash

    deposits and withdrawals, etc. Any serious discrepancy in this regard should be

    reported.

    2. Borrowings

    Generally borrowings are not held or dealt with at the branch level.

    3. Bills payable

    a) Generally bills payable relates to pay-order (PO), demand draft (DD),

    telegraphic transfer (TT) and mail transfer (MT) and banker's cheque issued by the

    branch. The balances in these accounts indicate progressive balance that is subject

    to reconciliation at HO level.

    b) Ensure that the details of lost demand drafts, if any, circulated by RO/HO is

    readily available with the branch.

    4. Inter-office adjustment (NET) For details refer item 7 of PART I.

    5. Interest accrued

    Ascertain the system of accruing interest on deposits in the computerized branch.

    Generally interest on deposits is accrued at the last day of the month and is reversed on

    the first day of the succeeding month.

    7. Other liabilities - Rebate on Bills discounted

    a) Ascertain that the branch has complied with the related accounting policy and

    necessary accounting has been done in respect of discount received in advance for

    the un-expired period of the bills outstanding as at the year-end.

    b) In case the bill-wise details are not made available and the amount of rebate is

    material, report the fact in the audit report.

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    8. Other liabilities - Tax deducted at source

    `Normally tax is deducted at source as per the Income Tax Act, 1961 in respect of

    interest on term deposit, staff salaries, rent, professional charges and payments made

    to the contractors, etc.

    9. Other Liability - unrealized interest on NPA

    a) This account is also referred to as Interest Suspense, De-recognized Interest, etc.

    b) Generally the branches are required to maintain subsidiary ledger/register for

    recording account-wise details of unrealized interest.

    10. Other liabilities Others

    a) This could include sundry deposits, staff security deposit, margin money and

    statutory dues such as deduction of professional tax, provident fund, ESI, etc.

    b) In respect of the statutory dues, ensure that proper reporting has been done in the

    Tax Audit Report.

    PART III: CONTINGENT LIABILITY

    1. Claims against the Bank not acknowledged as debts

    a) Generally this includes disputed amounts of lease rent, property tax, etc., in respect

    of premises taken on lease.

    b) Obtain suitable representation from the branch about the completeness of the

    disclosure of such contingent liabilities.

    2. Guarantees and acceptances, endorsements & other obligations

    Obtain the list of un-expired guarantees and letters of credit. In case the list is not

    made available, report the fact in the audit report.

    PART IV: BILLS FOR COLLECTION (CONTRA ITEMS)

    a) Obtain the list of bills /or collection (inward and outward) outstanding as at the

    year-end and verify the same with the related registers maintained by the branch.

    b) Ascertain that age of the outstanding bills and the reasons for old items.

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    SPECIFIC AUDIT APPROACH FOR MAJOR ITEMS OF PROFIT AND LOSS

    ACCOUNT

    PART I: INCOME

    1. Interest/discount on advances/bills

    a) Evaluate the overall effectiveness of internal controls through the reports of

    concurrent auditors and other agencies.

    b) Ascertain the nature and the extent of revenue leakage detected by the

    concurrent auditors.

    c) Ascertain that the branch has complied with HO instructions for recognizing

    penal interest and overdue interest.

    2. Other income - commission, exchange and brokerage

    a) It normally includes commission/exchange on letters of credit, guarantees,

    remittances and transfer of funds through DD, TT, MT, etc., bills for collection and

    Government business.

    b) Ensure that the branch has complied with the provisions of Service Tax and

    other taxes applicable on services.

    3. Other income - profit on sale of fixed assets

    a) It normally includes profit or loss (net) on sale of motor vehicle, furniture and

    fixtures, computers and other fixed assets held by the branch.

    b) Ensure that proper accounting has been done for the depreciation till the date

    of disposal as per the accounting policy framed by the bank.

    4. Other income - miscellaneous income

    a) It normally includes locker rent, recovery of godown rent, income from bank's

    property, security charges, etc.

    b) In case locker rent is recovered in advance for a year or more, ensure that the

    same is properly apportioned on time period basis or as per the accounting policy

    advised by HO.

    PART II: EXPENDITURE

    1. Interest on deposits

    a) Evaluate the overall effectiveness of internal controls through the reports of

    concurrent auditors and other agencies.

    b) Obtain copies of applicable interest rate circulars issued by HO and verify the

    rate applied for certain deposit accounts. More emphasis should be given to changes

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    in the rates, premature closures, back-dated renewals, high value deposits, short-

    term deposits, staff deposits, special category of deposits, tax deduction at source,

    etc.

    2. Salary & allowances to staff

    a) Generally monthly salary and allowances to staff are processed centrally

    either at RO or at any other main branches and the related records are also

    maintained there. The monthly salary sheets are then passed on to the

    respective branches and the payment is made by those branches. In such a situation,

    it must be ensured that the branch has properly accounted the payments for the

    entire year.

    3. Rent

    a) Obtain the details of the rented premises used by the branch either for the

    branch operations or for the officers/managers and the copies of the rent

    agreements.

    b) In case the lessor has availed loan against the rent payable by the branch ensure

    that the rent is properly appropriated towards the loan outstanding.

    4. Electricity

    a) Obtain the details of connections that are used for the branch premises and for

    the staff premises.

    b) Ensure that the payment is made as per the original bills held by the branch.

    5. Printing & stationery

    Generally HO or any centralised department of the bank ! supplies major

    stationery items like security items, etc., to the branches. At branch level, these items are

    recorded in the memorandum registers for the purpose of internal control. In case these

    items are recorded in the main books, ensure that the same are properly accounted as per

    the advices received from the HO.

    6. Depreciation

    a) Ensure that the depreciation has been charged as per the rates and the method

    prescribed in the HO instructions especially with reference to additions and

    deletions during the year. More emphasis should be given to inter branch transfer of

    assets and the depreciation thereon.

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    b) Generally the branches commit mistakes in identifying revenue and capital

    expenditure. In case such mistakes are observed during the course of audit, it is

    advisable to identify the corresponding impact on the depreciation.

    7. Legal charges

    Ensure that these payments are made on the basis of the bills and other supporting

    documents. More emphasis should be given to the approval/sanction of higher authorities

    required for making such payments.

    8. Postage, telegram & telephone

    a) Obtain the list of telephone connections used in the branch premises and

    residential premises of the staff, as per the policy of the bank.

    c) Ensure that the payments are made as per the original bills held by the branch.

    9. Repairs & Maintenance

    Normally it includes expenditure incurred on repairs and maintenance of vehicles,

    furniture, fixtures, premises, etc., and annual maintenance contracts (AMC) for

    computers, air conditioners, etc.

    10. Insurance

    a) Normally it includes expenditure incurred on insurance of office equipments

    installed at the branch like computers, air conditioners, etc.

    d) Obtain the details of insurance policies, if any, held by the branch.

    11. Other expenditure

    It includes all other expenditure including professional charges, concurrent audit fees,

    etc., that is not included in any of the specific heads.

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    PART III: IMPORTANT ASPECTS OF PRUDENTIAL NORMS

    While verifying compliance of the prudential norms issued by RBI give more

    emphasis on:

    a) Operations in the accounts of the borrower.

    b) Possibility of window dressing in the account.

    c) Reversal of unrealised interest.

    d) Identification of the date of NPA.

    e) Valuation of security.

    f) Accounts upgraded from NPA category to standard category.

    g) Potential NPA.

    h) Standard accounts with lowest credit rating

    i) Standard accounts with negative net worth/under BIFR.

    j) Asset classification by the other consortium members.

    PRUDENTIAL NORMS ON ASSET CLASSIFICATION, INCOME

    RECOGNITION AND PROVISIONING

    I. VERIFICATION OF COMPUTERIZED CLOSING RETURNS

    a) Presently many of the banks are using customised software for generation of master

    summary and account-wise report on asset classification, income recognition and

    provisioning. Such software facilitates more accuracy and consistency in compilation

    of data on prudential norms, provided the same are thoroughly tested and approved.

    b) As regards the system generated returns it is important to note that these returns do

    not substitute the normal audit procedures that are to be performed by the auditor.

    These returns only facilitate the audit to certain extent and hence the same must be

    accepted after performing normal audit procedures.

    c) Generally the system-generated returns contain lot of information that may be

    relevant only for the purpose of management information. As this information is not

    to be audited, it is advisable to state the fact in the relevant return that is to be

    certified.

    II. SALIENT FEATURES

    1. Non-performing Assets :

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    a) An asset, including a leased asset, becomes non-performing when it ceases to generate

    income for the bank. In other words, a non-performing asset (NPA) shall be a loan or

    an advance where;

    I) Interest and/ or installments of principal remain overdue for a period of more than

    90 days in respect of a term loan;

    II) The account remains 'out of order' as indicated below, in respect of an

    Overdraft/Cash Credit (OD/CC);

    III) The bill remains overdue for a period of more than 90 days in the case of bills

    purchased and discounted;

    IV) Interest and/or installment of principal remains overdue for two harvest seasons

    but for a period not exceeding two half years in the case of an advance granted for

    agricultural purposes; and

    V) Any amount to be received remains overdue for a period of more than 90 days in

    respect of other accounts.

    e) The credit facilities backed by guarantee of the Central Government though overdue

    may be treated as NPA only when the Government repudiates its guarantee when

    invoked.

    f) An account where the regular/ad hoc credit limits have not been reviewed/renewed

    within 180 days from the due date/ date of ad hoc sanction will be treated as NPA.

    d) In respect of accounts where there is potential threat of recovery due to erosion in the

    value of security or no availability of security and existence of other factors, say,

    fraud committed by the borrower, etc., the account should be classified as doubtful

    asset or loss asset as appropriate, irrespective of the period for which it remained as

    NPA.

    2. Out of order

    An account should be treated as 'out of order' if the outstanding balance remains

    continuously in excess of the sanctioned limit/ drawing power. In cases where the

    outstanding balance in the principal operating account is less than the sanctioned limit/

    drawing power, but there are no credits continuously for 90 days as on the date of

    Balance Sheet or credits are not enough to cover the interest debited during the same

    period, these accounts should be treated as 'out of order'.

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    c) There is no objection to the banks using their own discretion in debiting interest

    to an NPA account taking the same to Interest Suspense Account or maintaining

    only a record of such interest in memorandum accounts.

    5. Provisioning

    Minimum Provision

    a) Standard Asset:

    The banks should make a general provision of a minimum of 0.25 per cent on

    standard assets on global loan portfolio basis.

    b) Sub-standard Asset:

    A general provision of 10 per cent on total outstanding should be made without

    making any allowance for DICGC/ECGC guarantee cover and securities available.

    The 'unsecured exposures' that are identified as 'substandard' would attract additional

    provision of 10 per cent, i.e., a total of20 per cent on the outstanding balance. Unsecured

    exposure is defined, as an exposure where the realisable value of the security, as assessed

    by the bank/ approved valuers/Reserve Bank's Inspecting Officers, is not more than 10

    per cent, ab-initio,of the outstanding exposure. 'Exposure' shall include all funded and

    non-funded exposures (including underwriting and similar commitments).

    c) Doubtful Asset:

    i) 100 per cent of the extent to which the advance is not covered by the realisable

    value of the security to which the bank has a valid recourse and the realisable value is

    estimated on a realistic basis.

    ii) In respect of the secured portion, provision has to be made on the following basis

    at the rates ranging from 20 per cent to 100 per cent of the secured portion depending

    upon the period for which the asset has remained doubtful.

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    Period for the asset has remained in

    doubtful category

    Provision to be made (%)

    Up to 1 year (Dl category)

    More than 1 year but less than 3 years (D2

    category)

    More than 3 years (D3 category)

    a) Outstanding in D3 category as on

    31/03/2004

    b) Classified in D3 category on or after

    1/04/2004

    20

    30

    50 (as on 31/03/2004)

    60 with effect from 31/03/2005

    75 with effect from 31/03/2006

    100 with effect from 31/03/2007

    100 with effect from 31/03/2005

    iii) Banks are permitted to phase the additional provisioning consequent upon the

    reduction in the transition period from sub-standard to doubtful asset from 18 to 12

    months over a four-year period commencing from the year ending March 31, 2005, with a

    minimum of 20 % each year.

    Floating Provision

    Some of the banks make a 'floating provision' over and above the specific

    provisions made in respect of accounts identified as NPA. The floating provisions,

    wherever available, could be set-off against minimum provisions as per above stated

    provisioning guidelines. Considering that higher loan loss provisioning adds to the overall

    financial strength of the banks and the stability of the financial sector, banks are urged to

    voluntarily set apart provisions much above the minimum prudential levels as a desirable

    practice.

    Treatment of Interest Suspense AccountAmounts held in Interest Suspense Account should not be reckoned as part of

    provisions. Amounts lying in the Interest Suspense Account should be deducted from the

    relative advances and thereafter, provisioning as per the norms, should be made on the

    balances after such deduction.

    Advances Covered By ECGC

    In the case of advances guaranteed by ECGC, provision should be made only for

    the balance in excess of the amount guaranteed by ECGC. Further, while arriving at the

    provision required to be made for doubtful assets, realisable value of the securities should

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    first be deducted from the outstanding balance in respect of the amount guaranteed by

    ECGC and then provision made.

    IMPORTANT ASPECTS

    1. Advances under consortium arrangement

    Asset classification of accounts under consortium should be based on the record of

    recovery of the individual member banks and other aspects having a bearing on the

    recoverability of the advances.

    The banks participating in the consortium should, therefore, arrange to get their share of

    recovery transferred from the lead bank or get an express consent from the lead bank for

    the transfer of their share of recovery, to ensure proper asset classification in their

    respective books.

    2. Accounts where there is erosion in the value of security

    i) An NPA need not go through the various stages of classification in cases of serious

    credit impairment and such assets should be straightaway classified as doubtful or loss

    asset as appropriate. Erosion in the value of security can be reckoned as significant

    when the realisable value of the security is less than 50 per cent of the value assessed by

    the bank or accepted by RBI at the time of last inspection, as the case may be. Such

    NPA may be straightaway classified under doubtful category and provisioning should

    be made as applicable to doubtful assets.

    ii) If the realisable value of the security, as assessed by the bank/ approved valuers/RBI is

    less than 10 per cent of the outstanding in the accounts, the existence of security should

    be ignored and the asset should be straightaway classified as loss asset. It may be either

    written off or fully provided for by the bank.

    3. Loans with moratorium for payment of interest

    In the case of housing loan or similar advances granted to staff members where

    interest is payable after recovery of principal, interest need not be considered as overdue

    from the first quarter onwards. Such loans/advances should be classified as NPA only

    when there is a default in repayment of installment of principal or payment of interest on

    the respective due dates.

    4. Agricultural advances

    A loan granted for short duration crops will be treated as NPA, if the installment of

    principal or interest thereon remains overdue for two crop seasons. A loan granted for

    long duration crops will be treated as NPA, if the installment of principal or interest

    thereon remains overdue for one crop season.

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    4

    TECHNOLOGY IN BANK AUDIT

    AUDITING IN COMPUTERISED ENVIRONMENT

    SYSTEM AUDIT

    USE OF CAAT TOOLS : IDEA 2004

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    AUDITING INCOMPUTERISED ENVIRONMENT

    Technology and its progress has often been linked to progress of civilization.

    From the time man learnt to control fire to the iron and Bronze Age, we have notedthat the control over inventions like guns and cannons have given certain civilizations

    the upper hand over the ones they conquered. It is not necessary for the inventions and

    progress to be restricted to the field of military or defence. Progress in Banking is an

    equal parameter of the cultural development of a civilization and like any other field;

    this sector is not spared from the technical revolution, which has taken over other

    sectors. This delves into the necessity of value added APPROACH to the traditional

    audit and not solely dependent on the system auditors. These approaches are general

    and can be applied to any environment whether LAN Branch or a core banking

    situation.

    Is the burden shifted to the system auditor?

    There is unlikely any professional who will take this stand of shifting the burden

    to the other auditor. There are a few checks you can do without undergoing intensive

    training and examination! Please note that the computer system environment referred to

    here is a minimum of LAN (Local Area Network) or even a Core system where the data

    hub is at a Central Location and the branches/offices are connected to this data hub

    despite being many cities away. Apart from the large corporations and multinationals,

    many Banks, even large co-operative Banks have taken this option. Even the branch

    auditor, thus, has to take certain precautions to ensure he gives justice to his work.

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    PHYSICAL

    ACCESS

    CONTROL

    In case the site is a LAN, the Server should be secure since thesoftware and data is located in this device. Access to theServer room should be restricted and only senior managementshould permit 'outsiders' like software and hardware vendors

    to enter the server room. Many of the frauds that have alreadyoccurred in India would have been prevented only if thisaccess was closely monitored.

    ENVIRONMENTAL

    SECURITY

    Apart from protecting the server from bad intentionedpersons, we have to ensure it is protected from accidents offire and water by installation of smoke alarms in the serverroom and extinguishers outside the server room. In case ofcore banking, the devices used for communication should beaccorded the status of protection of the server.

    SAFEGUARDING

    OF ASSETS -UPS

    Computers require electrical power for working and when the

    environment is live, work comes to a standstill unless power isprovided though a UPS (Uninterrupted Power Supply) Thishas battery bank and is activated immediately when the powerfails providing a continuous power without any interruption.These machines heat when generating power and if properventilation is not provided, these UPS will provide service forshorter durations not only compromising the work but alsowasting the investment of the company. Simple rules ofmaintenance should also be followed and monitored.

    OPERATING

    SYSTEMCONTROLS

    While all pay attention to the application software access,

    many forget to police the access to the operating system. Filecopy, deletion even data manipulation (especially underdatabase environments) etc. are some potential disasters thatare possible unless controlled. You will have to ensure that thecompany holds the original license for using the operatingsystem software. Ensure whether the original OperatingSystem Media supplied by the vendor is available in theCompany. This is necessary to ensure reloading in case ofaccidental corruption. Only if the company has the system canit be loaded without waiting for the vendor's representative.

    APPLICATIONSYSTEM

    CONTROL

    The application developed for the company should be encodedand not left in a manner that can be re-programmed by theuser. This will enable any person knowing a bit of

    programming of that language to design trapdoors for fraudand these are later very difficult to identify. Over here,'Prevention is easier than the cure'.

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    PASSWORD AND

    ACCESS

    CONTROL

    Password control is the 'logical' access to the computer. Thesystem should have passwords and these should be demanded

    by the system to changed frequently ensuring that the lastpassword is not accepted, (not accepting last 12 is the least)Along with this, the 'internal control' should be ensured by the

    system ensuring that the person creating the voucher shouldnot be permitted to authorize the voucher and withoutauthorization, no voucher (other than system generated vouch-ers) should be accepted by the system. The corollary of thisrequirement is to ensure (check) that each user has only oneidentity in the system otherwise one person will take theidentity of the clerk and with a change in short name takeanother identity of an officer thus effectively compromisingthe system.

    Checklist for Audit of Computerized Operations

    ENVIRONMENT

    1. Securing thecomputers

    The machines should be locked at the end of the day. Ensure thateither the furniture, which is adjusted for locking, is locked or thatthe hardware lock of the computer is used. This is a simple pointoften ignored. Unlocked computer means any one can start it andthe only hurdle after that is the password. Poor passwordmaintenance further compounds risk of unlocked computers.

    2. Securingduringoperations

    During computer operations especially during service hours, it isnot uncommon for the operator to leave his/her seat. The operatorand thus you as an auditor should ensure that the operator either

    exits form the system or leaves it at a point where it cannot proceedwithout a password.

    Password

    Password is a key to something more valuable than cash - data

    No. Check for Discussion on checkpoint

    1, Passwordallotment

    register

    When a password is allotted, entry is made in this register. This issimilar to the key register where entries are made at time of giving

    keys. Check here whether the password level is also specified.Authority to give password is to the branch manager and those whohold supervisor password.

    2. PasswordChangeregister

    Where software does not control change in password (where notonly warnings are given but user is disabled unless the password ischanged after specified date) a register has to be shown to you withdates of change of password. In absence of this register, you do nothave evidence that the passwords are changed frequently.

    3. Two tothree

    supervisorsonly

    Supervisor password level permits the holder of this passwordunlimited access. Ensure there are a minimum of two and a

    maximum of three such holders. Check the systems and proceduremanual of the Bank in case they specify a different figure.

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    OBJECTIVES OF SYSTEMS AUDIT

    The basic objectives of Systems Audit are to ensure:

    a) The assets are safeguarded in the system

    b)Data integrity is maintained throughout the system

    c) Organisational goals are effectively achieved by the system

    d)Resources in the system are being consumed efficiently

    Computer System Vs. Manual System

    Any system, manual or computerised, must have some internal controls. These

    internal controls ensure Asset Safeguarding, Data Integrity, Achievement

    of Organisational Goals and Efficient Consumption of Resources within the

    Organisation. However, nature of these internal controls and their

    implementation may vary widely in Manual System and Computerised

    System, for the following factors:

    a) Separation of duties

    b)Authority and responsibility

    c) Dependable and skilled personnel

    d)Authorisation

    e)Availability of documents and records

    f) Custody of assets and records

    g)Management by supervisio

    h)Verification of performance

    Assessment of Controls :

    In any system, controls play a very important role. They reduce possible losses by reducing

    probabilities of component failure and also by reducing the amount of losses, if component

    fails at all.

    Auditor's task in a computerised system is complex because number and range of controls

    are increased. A systems auditor should assess the following controls:

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    CONTROL CONTROL FUNCTIONS

    To ensure correct identification of

    objects

    (e.g. the users, programs) by the system

    To ensure correctness of data and accurate

    processing in the system

    To ensure protection