Bank Branch Audit Manual
Bank Branch Audit Manual
Bank Branch Audit Manual
Naveen ND Gupta
GUIDANCE PAPER
ON
Particulars Bank Branch Statutory Audit Important Audit Checks Income Recognition & Asset Classification Norms At a Glance Asset Classification At a Glance Audit working paper and documentation Draft Engagement Letter to be sent to the Appointing Authority of the Bank Draft Letter of Requirements to be sent to the Branch Draft Bank Audit Program for the year ended March 31, 2010 Draft of Management Representation Letter to be obtained from the Branch Management Draft Audit Sampling Checklist for Verification Of Advances & reporting in LFAR CBDT Circular no. 3/2010 dated 02.03.2010 on TDS on payment of interest on time deposits under Section 194A of the Income Tax Act, 1961 by banks following Core- Branch Banking Solutions (CBS) software Glossary to Irregularities
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Verify if the specimen signature cards of dormant accounts are kept separately under joint custody of Manager/Officer. Any cash withdrawal/debits to dormant account should be authorized by the Branch incharge. o Interest calculations Verify interest on all schemes of deposits on test check basis e.g. Verify the fields like interest rate, different Interest Rates prevalent in the year, period of interest, Amount of Deposit and accrual of interest in the account, Interest Calculation on Premature Deposit withdrawal/ Recurring Deposits/ Back Dated Renewals
Accrual of Interest specially policy on Interest Accrual on Matured/ Overdue Term Deposit (also note CBDT circular no. 3/2010 dated 02.03.2010 on TDS on interest; copy attached) Ascertain reasons for authorization for the same frequent reversal of interest and the
RBI Norms for Nonresident deposits & its operations with due importance to opening and operation of accounts like NRE, NRNR, FCNR, RFC, etc Examine interest trends as compared to average annual deposits (monthly average figures) In case of deposits Frozen by Revenue/ Regulatory/ Government, etc, procedure given in Master Circular on Interest Rates on Rupee Deposits held in Domestic, Ordinary NonResident (NRO) and Non Resident (External) (NRE) Accounts should be followed for Interest credit Verify that Interest on the FD matured and remaining unpaid will attract saving bank account rate of interest. Tax Deducted at Source
Verify that TDS returns have been uplinked as per schedule laid down in the Incometax Act, 1961. Also ensure if the Form 15G and Form 15H are filed with the Income Tax department within the specified time schedule Overdue Term deposits & banks policy for its renewal & interest provision thereon.
RBI Norms for Nonresident deposits & its operations with due importance to opening and operation of accounts like NRE, NRNR, FCNR, RFC, etc Interest on various types of deposits including savings account; Tax Deducted at Source and year end interest provisions. Large deposits placed at the end of the year (probable window dressing) Examine unusual trend in account opening or account closing, dormant accounts that have suddenly been reactivated by heavy cash withdrawals or deposits, over drawings, etc Examine interest trends as compared to average annual deposits (monthly average figures) 2. Advances Extent of Checking : PLEMINARY INFORMATION BEFORE AUDIT OF ADVANCES: o Obtain the Head Office Delegation of power and duties & limit fixed for Branch and its executives o Study the various reports issued by the concurrent auditors, RBI Inspection reports, and RO inspectors. Gain understanding of various audit points and material discrepancies and irregularities reported and compliances of the same. Review monitoring reports (irregularity reports) sent by the branch to the controlling authorities in respect of irregular advances. o Obtain the detailed list of advances to identify major borrowers, period since when granted, nature of advances and clients, major defaulters, lending under various schemes, industry wise lending, probable NPA, highly sensitive accounts, CDR & BIFR cases, Advances in D1 and D2 (which requires calculation of Asset Shortage), Restructured accounts, OTS proposals, possibility of window dressing in the account, up gradation as well as down gradation of accounts. Compare the list with previous audit to find out major recoveries Verify: o All the advances whose balance is lower of 5% of total advance or Rs.2 Cr.
o Advances which are sanctioned during the year and other advances on test check basis depending on the balance outstanding. o Advances which are adversely commented by RBI inspection team, concurrent auditors, banks internal inspection
Some of the important areas to be examined /reviewed in respect of advances are: Pre- sanction stage: o Review of credit appraisal system before sanction of loan, system of renewal/review of loan. Post sanction stage: o Whether terms of sanction have been complied with in case of new advances o Verify whether any sanction is beyond the delegation power and if so, whether reporting and confirmation of the same to the higher authorities is done/ obtained o Verify whether any advances have been disbursed without fulfilling the conditions in the sanction Documentation o Review of ROC forms on test check basis to confirm whether charges have been registered o Verify whether as per the Master circular No. DBOD No. BP. BC.46/ 08.12.001/200809 dated 19 September, 2008; DBOD No. BP. BC.110/ 08.12.001/200809 dated 10 February, 2009; bank has obtained declaration and certification by a professional, regarding compliance of various statutory prescriptions from the borrower enjoying the Consortium/Multiple Banking Arrangements o Insurance policies with bank clause should be obtained for stocks and collateral, (residence, office premises, etc.) and for stocks held by third parties on Jobwork basis o Verify the consortium advances accounts with regard to: Status on Joint Documentation, Inspection of unit, Updated minutes of consortium, confirmation from lead bank that they are holding valid documents, monthly updating of drawing power based on lead banks advice o Whether the borrower is regular in submission of stock statements, book debt statements, insurance policies, annual accounts, half yearly results, etc and whether penal interest is charged in case of default/delay in submission of such data (whether branch is marking the date of receipt on the statement). Whether the bank verifies these statements critically and seeks clarification wherever required e.g. (format is proper, details are adequate, etc). Whether year end stock statement matches with Audited Accounts Stock figure
Review and Monitoring of advances: o Whether the borrower is regular in submission of the stock & book debt statements and same are scrutinized by an officer and Drawing Power correctly calculated. o Whether insurance policies are on record and assets which are charged as security are adequately insured. o Whether regular inspection/stock verification of the borrowers is done by the Bank/ by a firm of CA as per laid down procedure of the Bank. o Whether frequently overdrawn accounts are properly monitored and reported to the Controlling Office. o Whether the borrower regularly submits its quarterly reviewed results (in case of listed companies) and annual audited financial statements. Whether they are scrutinized by the Officer to verify that actual results match with the projections. If not, whether clarification is sought. o Review the operations in the accounts on test check basis
o Whether interest and penal interest in case of delayed submission of stock statements, overdrawn accounts etc. is charged. o Verify if any Letter of Credit (L/C) limit is availed, the stocks under L/C are separately shown in the stock statements, to prevent double financing o Verify that the unit submits separate stock statements for Packing Credit (PC) facility and the liquidation is out of export proceeds (if not, concessional interest has to be revised to normal interest charged to the party). Verify whether exchange translation is done regularly to check whether overall exposure is within limits in case of Foreign Currency denominated PC o Verify if agewise analysis of book debts is submitted
o If stocks are kept at rented godowns, Nolien letters should be obtained from the concerned owners/landlord o o Verify that nonmoving stocks are reduced when calculating the DP Check classification of advances, income recognition and provisioning as
o Status of other banks to ensure there is no excess financing against the stock/book debts o Verify whether Nonperforming accounts reported to the Head office promptly o Whether Branch is following the Recovery policy and legal action is taken on the advances whenever required as per the Policy of the Bank o Review the monitoring system; i.e., monitoring end use of funds, analytical system prevalent for the advances, cash flow monitoring, branch followup, consortium meetings, inspection reports, stock audit reports, market intelligence (industry analysis), securities updating, etc. o In case of advances against shares verify that branch has not given loan against Banks own shares and any other partly paid up shares o Verify whether branch has complied with Master Circular No. DBOD.
o (Specified period means period of one year from the date when the 1st payment of interest or installment of principal falls due under the terms of restructuring) o Verify the Financial viability and reasonable certainty of repayment of each account restructured o Verify that advance covered under restructuring should be from other than capital market exposure, personal/ consumer loan o Verify whether borrowers indulging in frauds and malfeasance are not taken for restructuring. As per circular they remain ineligible for restructuring
o In case of standard asset: May be treated as standard asset, up to a period of one year after the first interest/ principal payment o In case where prerestructuring facilities were classified as substandard and doubtful: On cash basis only o Conversion of principal into debt/ equity and conversion of unpaid interest into Funded Interest Term Loan (FITL), Debt or Equity Instruments specific guidelines to be followed
o Miscellaneous income like locker rent, income on forex business etc on test check basis. o Proper authority in sanction and disbursement of expenses as also the correctness of the accounting treatment given as to revenue & capital expenditure o Check accrual of income/ expenditure especially for the last month of the financial year o Verify the significant systematic reversal of income and expenditure with proper reasons. o Verify the computation of Guarantee Commission and its application over the period of the Guarantee Divergent Trends
o Divergent trends in income/ expenditure of the current year may be analysed with the figures of the previous year o Wherever a divergent trend is observed, obtain an explanation along with supporting evidences like monthly average figures, composition of the income/ expenditure, etc 4. Balance Sheet Cash & Bank Balances o Physically verify the Cash Balance as on March 31, 2010 or reconcile the cash balance from the date of verification to March 31, 2010 o o Confirm and reconcile the Balances with banks as on March 31, 2010 Verify that the cash is held in dual custody
o Check instances of cash exceeding the retention limit as set by the Controlling Authorities. Frequent excesses should be reported in the Long Form Audit Report (LFAR)
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o Check whether the surprise verification of cash by the independent officer or the branch manager is carried out and frequency of the same Investments o Physically verify the Investments held by the branch on behalf of Head Office and issue certificate of physical verification of investments to banks Investments Department o Check receipt of interest and its subsequent credit to be given to Head Office Fixed Assets Check that accounting of fixed assets is done in accordance with AS-10. Also check accounting of major capital expenditure especially in branches located in leased premises
Check Interbranch transfer memos relating to Fixed Assets and whether they have been correctly classified in the accounts and depreciation correctly provided thereon
Check if Dead Stock Register is duly updated and signed by the concerned Manager Ascertain the Branch managers power to acquire new fixed assets and frequency of physical verification Verify the suspense account to identify any amount paid to vendor but still unadjusted.
Inter Branch Reconciliation (IBR) o Understand the IBR system and accordingly prepare an audit plan to review the IBR transactions. The large volume of Inter Branch Transactions and the large number of un-reconciled entries in the banking system makes the area fraud prone o Check up head office inward communication to branch to ascertain date up to which statements relating to interbranch reconciliation have been sent Check and report
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o Test Check accuracy and correctness of Daily statements which are prepared by the branch and sent to IOR department Further, vide its circular no. DBOD No. BP.BC. 73 /21.04.018/200203 dated February 26, 2003, the Reserve Bank (RBI) advised the banks to maintain categorywise (headwise) accounts for various types of transactions put through interbranch accounts so that the netting can be done categorywise. Further, RBI advised banks to make 100 percent provision (categorywise) for net debit position in their interbranch accounts arising out of the un-reconciled entries, both debit and credit, outstanding for more than six months [Refer to the master circular (www.rbi.org.in)]
Suspense Accounts, Sundry Deposits, etc Suspense accounts are adjustment accounts in which certain debit transactions are temporarily posted whose authorisation is pending for approval Sundry Deposit accounts are adjustment accounts in which certain credit transactions are temporarily posted whose authorisation is pending for approval As and when the transactions are duly authorised by the concerned officials they are posted to the respective accounts and the Suspense account / Sundry Deposit account is credited/ debited respectively
o o o o o
Ask for and analyse their yearwise breakup Check the nature of entries parked in such Accounts
Check any movement in such old balances and whether the same is genuine and has been properly authorised by the competent authority Check for any revenue items lying in such accounts and whether proper treatment has been given for the same Provision should be recommended against old debit balances which are unexplained or in opinion of the auditors is non recoverable. o o Auditors Report & Memorandum of Changes The Auditors Report should be a self contained document and should
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contain no reference of any point made in any other report including the LFAR o o o Include Audit Qualifications in the Auditors Report and not in the LFAR Quantify the Audit Qualifications for a better appreciation of the point For suggesting any changes in the financial statements of the branch, quantify the same in the Memorandum of Changes (MOC) and make it a subject matter of qualification and annexe it to the Auditors Report
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Auditing in CBS/
o Overall scope of audit does not change but audit procedure is affected. Conduct audit as per AAS 29- Auditing in CIS environment
Computerised o Familiarize with EDP/CBS system; gain the understanding of the flow of environment transactions and specific control procedures by reviewing sample reports. o Review system audit report to understand the system, weakness in the system and suggestions made to improve the system o Verify various controls like a) control in respect of access to system, password protection, b) input control in respect of rate of interest, value of security, drawing power etc. o o Verify how start of (SOD) and End of Day ( EOD) procedure is handled. Verification of system of uploading of transactions during down time.
o Verify controls during transfer of data from CBS to software used for preparation of financial statements. o Verify controls in respect of access to data base, restriction on change in master data and back up controls o 6. Verify Exceptional Reports
Auditors o The Auditors Report should be a self contained document and should Report & contain no reference of any point made in any other report including the LFAR Memorandum o Include Audit Qualifications in the Auditors Report and not in the LFAR of Changes o Quantify the Audit Qualifications for a better appreciation of the point made to the reader o For suggesting any changes in the financial statements of the branch, quantify the same in the Memorandum of Changes (MOC) and make it a subject matter of qualification and annexe it to the Auditors Report
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o The LFAR questionnaire is a useful tool for planning the statutory audit of a branch o o Complete & submit the Auditors Report as well as the LFAR simultaneously Comments in LFAR should be specific and not vague.
o Give instances of shortcomings/ weaknesses existing in the respective areas of the branch functioning in the LFAR o The LFAR should be sufficiently detailed and quantified so that they can be expeditiously consolidated by the bank 7. General o Send a Letter of your Requirements to the Branch before commencing the audit [Draft Letter enclosed herewith] o Obtain the latest status of cases involving fraud, vigilance and matters under investigation having effect on the accounts and its reporting requirement. Review the Master circular on FRAUDS CLASSIFICATION AND REPORTING issued by RBI (Master Circular No. RBI/2009-10/76 DBS.CO.FrMC.BC..No. 2 / 23.04.001/2009-10 dated July 01, 2009) Jan 5, 2004, Sept 1 2004 (in respect of consumer and housing loan), dated Sept 9, 2005 at www.rbi.org.in. o Obtain a Management Representation Letter (MRL) [Draft MRL enclosed herewith] o Banks are advised to strictly comply with the extant regulations and in particular of Master circular on Issuance of Guarantee, not to provide guarantees or equivalent commitments for issuance of bonds or debt instruments of any kind. (Master circular on Issuance of Guarantee DBOD. No. Dir. BC.18/ 13.03.00/ 2008 09 dated July 1, 2009, RBI/2009-2010/70 DBOD.No.Dir. BC.14/13.03.00/2009-10 dated July 1,2009.)
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Interest or instalment remains overdue for a Overdue: An amount due to the period of more than 90 days from end of the quarter bank under any credit facility is Overdue if it is not paid on the Agricultural Advances: In respect of advancesdue date fixed by the bank granted for agricultural purposes where interest and/ or instalment of principal remains overdue for a period of more than two crop seasons for short duration crops and one crop season for long duration crops, the advance should be treated as NPA The account remains continuously out ofBanks may not classify an order for a period of more than 90 days i.e.account merely due to existence Outstanding balance remains continuously in excessof some deficiencies, which of the sanctioned limit/ drawing power or there areare of temporary nature such as of adequate no credits continuously for a period of 90 days as onnonavailability power, balance the date of Balance Sheet or credits are not enoughdrawing to cover the interest debited during the same period outstanding exceeding the limit, nonsubmission of stock statements and nonrenewal of the limits on the due date, etc However, outstanding in an account based on stock statements older than three months would be deemed irregular. Such account will become NPA if such irregular drawings are permitted in the account for a continuous period of 90 days even though the unit may be working or the borrowers financial position is satisfactory Further, an account where the regular/ adhoc credit limits have not been reviewed/ renewed within 180 days from the due date/ date of adhoc sanction respectively, will be treated as NPA
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Bills The bills purchased/ discounted remains overdue forOverdue interest should not be Purchased k a period of more than 90 days charged and taken to income Discounted account in respect of overdue bills unless it is realized Other Accounts Any amount to be received in respect of that facility State Government guaranteed remains overdue for a period of more than 90 days advances in respect of which guarantee has been invoked and has remained in default for more than 90 days The credit facilities backed by guarantee of Central Government though overdue may be treated as NPA only when the Government repudiates its guarantee when invoked. However, income shall not be recognised if the interest or instalment has remained overdue or the account has remained continuously out of order or the bills or any other facility has remained overdue for a period of more than 90 days Government State Government guaranteed advance would attractCredit facilities backed by guaranteed asset classification and provisioning norms, if interestguarantee of Central advances and/ or principal or any other amount due to theGovernment though overdue bank remains overdue for more than 90 days may be treated as NPA only when the government repudiates its guarantee when invoked. However, income shall not be recognised if the interest or instalment has remained overdue or the account has remained continuously out of order or the bills or any other facility has remained overdue for a period of more than 90 days
Notes:
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4. Till the time the account is identified as NPA, income is recognised irrespective of
whether realised or not. Where an account is identified as NPA during the year, unrealised income should not be recognised for the year. Also, interest accrued and credited to income account in the previous year should be reversed or provided for if the same is not realized 5. Partial Recovery in respect of NPA accounts should be generally appropriated against principal amount in respect of doubtful assets till the irregularity is completely regularised 6. If the accounts of the borrowers have been regularised before the balance sheet date by repayment of overdue amounts, the same should be handled with care and without scope for subjectivity. Where the account indicates inherent weakness on the basis of the data available, the account should be deemed as a NPA. In other genuine cases, the banks must furnish satisfactory evidence to the Statutory Auditors about the manner of regularisation of the account to eliminate doubts on their performing status 7. If the debits arising out of devolvement of letters of credit or invoked guarantees are parked in a separate account, the balance outstanding in that account also should be treated as a part of the borrowers principal operating account for the purpose of application of prudential norms on income recognition, asset classification and provisioning 8. In cases of substantial time overrun in the projects under implementation, the asset classification, income recognition and provisioning should be done as per master circular
9. Fees and commissions earned by the banks as a result of renegotiations or rescheduling of outstanding debts should be recognised on an accrual basis over the period of time covered by the renegotiated or rescheduled extension of credit
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17. In case of Takeout Finance, if the asset is classified as NPA while taking over the
asset, the branch should make provisions treating the account as NPA from the actual date of it becoming NPA even though the account was not in its books as on that date mechanism, c) restructuring of SMEs and d) restructuring of projects under implementation, the classification of advances should be done as per Para 4.2.14 ,4.2.15,4.2.16 and 4.17 of the aforesaid master circular (www.rbi.org.in)
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AT A GLANCE
Category Stand ard Assets Conditions to be satisfied Does not disclose any problem and which does not carry any more than normal risks attached to business Provision Amount General Provision on standard assets as per RBI MASTER
Remarks
Such an asset is not a NPA
CIRCULAR - PRUDENTIAL NORMS ON INCOME RECOGNITION, ASSET CLASSIFICATION AND PROVISIONING PERTAINING TO ADVANCES
RBI/2009-10/39 DBOD.No.BP.BC.17/21.04.048/ 200910, dt. July 1, 2009 is as under: Direct advances Agricultural and SME 0.25% Residential Housing over Rs.20 lac 1.00% to
Loan
Personal loans, credit card, capital market exposure, commercial and real estate loans, and loans to systemically important NBFCs ND 2.00% All other loans and advances not included in above categories 0.40% A general provision of 10% In respect of of total outstanding. accounts where there are potential threats of An unsecured exposure i.e. recovery on account of an exposure where the erosion in the value of realizable value of security is security or non not more than 10% ab-initio of availability of security the outstanding exposure, an and existence of other additional provision of 10% i.e. factors such as frauds total of 20% of the outstanding committed by balance .( Refer Para 5.4 of the borrowers, it will not master circular) be prudent for banks to first classify them as substandard and then as doubtful after expiry of twelve months from the date the account has become NPA. Such
Sub Classified as NPA Standard for a period less than Assets or equal to 12 months Classification of an asset should not be upgraded merely as a result of rescheduling, unless there is satisfactory compliance of the required conditions at least for one year
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Remarks
accounts should be straightaway classified as doubtful asset (when realizable value of security is less than 50% of the total value of security) or loss asset (when realizable value of security is less than 10% of the value of security), as appropriate, irrespective of the period for which it has remained as NPA
100% to the extent to which the advances are not covered by the realisable value of the security to which the bank has a valid recourse Over and above the aforesaid, depending upon the period for which the asset has remained doubtful, provision on the secured portion to be made on the following basis: Upto 1 year 20% 1 to 3 years 30% Over 3 years 100%
o o o Loss Assets Loss asset is one where loss has been identified by bank, external or internal auditors or RBI inspectors, but amount has not been written off (wholly or partly)
It has all the weaknesses inherent in that of a sub standard asset with the added characteristic that the weaknesses make the collection/ liquidation in full, highly questionable and improbable, on the basis of current known facts, conditions and values
100% of the outstanding If the assessed should be provided for/ written realisable value of the off security is less than 10 per cent of the outstanding amount, the existence of security should be ignored and the asset should be straightaway classified as loss asset
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You have requested that we audit the balance sheets of __________ Branch & __________ Branch of _________ Bank as at March 31, 2010 and the related profit and loss account for the year ended on that date. We are pleased to confirm our acceptance and our understanding of this engagement by means of this letter. Our audit will be conducted with the objective of our expressing an opinion on the financial statements We will conduct our audit in accordance with the auditing standards generally accepted in India and with the requirements of the Banking Regulation Act and the Reserve Bank of India Act and the guidelines issued under the said statutes from time to time. Those Standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatements. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation However, having regard to the test nature of an audit, persuasive rather than conclusive nature of audit evidence together with inherent limitations of any accounting and internal control system, there is an unavoidable risk that even some material misstatements of financial statements, resulting from fraud, and to a lesser extent error, if either exists, may remain undetected In addition to our report on the financial statements, we expect to provide you with a separate letter concerning any material weaknesses in accounting and internal control systems which might come to our notice in the form of a Long Form Audit Report The responsibility for preparation of financial statements on a going concern basis is that of management. Management is also responsible for selection and consistent application of appropriate accounting policies, including implementation of applicable
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_______________________ Partner
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As you are aware, we have been appointed as the Statutory Auditor to report on the accounts of your Branch for the year 2009-2010 In order to enable us to finalise the audit programme and furnish our report on the audit of the accounts for the year 20092010 of your branch, may we request you to keep the following information/ clarification ready and make the same available to our audit team at the earliest:
1. Latest Reports
The following latest reports on the accounts of your Bank, and compliance by the Bank on the observations contained therein may be kept ready for our perusal: Latest RBI Inspection Report; Internal/ Concurrent Audit Reports; Head Office Inspection Reports; Internal Inspection Reports; Revenue Audit Report (if any); Income and Expenditure Control Report (if any); Report on any other Inspection/ Audit that may have been conducted during the course of the year relevant to the financial year 20092010
2. Circulars in Connection with Accounts Please let us have a copy of the Head Office circulars/ instructions in connection with the closing of your accounts for the year, to the extent not communicated to us or incorporated in our letter of appointment
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5. Deposits a. Please let us have the Interest rate structure, applicable for the current year,
for all the types of deposits accepted by the branch
Account Deposit. If not, details/ particulars of credit balances comprising Overdue/ Matured Term Deposits as at the yearend which continue to be shown as Term Deposit, particularly where the branch does not have any instructions/ communication for renewal of such deposits from the account holder and amount of provision of interest made on such overdue/ matured term deposits, should be separately marked out and be kept ready for our reference
6. Advances a. Kindly confirm whether in respect of the advances against tangible securities,
the branch holds evidence of existence and latest market value of the relevant securities as at the yearend
b. Kindly inform the yearend status of the accounts, particularly those which
have been adversely commented upon in the latest reports of RBI/ Internal Auditors/ Concurrent Auditors/ Statutory Auditors, etc on the branch as also accounts in respect of which provisions have been made/ recommended as at the previous yearend Information in relation to such advances accounts where provision computed/ recommended may please be prepared indicating:
i. ii. iii.
Name of the borrower Type of facility * Total amount outstanding as at the yearend (both for principal and interest) specifying the date upto which interest has been levied and recovered
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Bank Branch Audit-Guidance Paper By CA. Naveen ND Gupta iv. v. vi. vii. viii.
Particulars of securities and value on the basis of latest report/ statement Nature of default and action taken Brief history and present status of the advance * Provision already made/ recommended NPA since when (please specify the date)
at the end of the previous year has been changed to a better classification, stating reasons for the same revenue, contrary to the norms of income recognition notified by the Reserve Bank of India and/ or Head Office circulars issued in this regards; and particularly where the chances of recovery/ realisablity of the income are remote
f. Kindly also confirm whether any income has been adjusted/ recorded to
Kindly also confirm whether any income has been recorded on NonPerforming Accounts other than on actual realisation
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8. Interbranch/ Office Accounts/ Head Office Account a. Please let us have a statement of entries (headwise) which originated prior
to the yearend at other branches, but were responded during the period after March 31, 2010 at the branch b. Datewise details of debits in various subheads relating to Interbranch transactions and reasons for outstanding amounts particularly those, which are over 30 days as at the Balance Sheet date
9. Contingent Liabilities a. Kindly confirm whether other than for advances, there are any matters
involving the Bank in any claims in litigation, arbitration or other disputes in which there may be some financial implications, including for staff claim, municipal taxes, local levies etc If so, these may be listed for our verification, and you may confirm whether you have included these as contingent liabilities otherwise as at the yearend, and whether the expired guarantee where the claim year has also expired, continue to be disclosed in the Branch return. Please confirm specifically
10. Interest Provision a. Kindly confirm whether interest provision has been made on deposits etc in
accordance with the latest instruction of the RBI/ interest rate structure of the bank. A copy of such instructions/ rate structure may be made available for our scrutiny
b. Kindly confirm whether any amount recorded as income upto the yearend,
which remains unrecovered or not realisable, has been reversed from any of the income heads or has been debited to any expenditure head during the financial year. If so, please let us have details to enable us to verify the same interest/ other income recorded upto the previous yearend; and the amount reversed during the year under audit i.e. income of earlier years derecognised during the year
11. Foreign Currency Outstanding Transactions a. Kindly confirm whether amount outstanding as at the yearend have been
converted as at the yearend rates prescribed by FEDAI. An authenticated copy of the FEDAI rates applied may be given for our records which originated prior to the yearend from other banks, but could not be recorded as these were in transit and for which entries were made after the year end
b. Kindly confirm the amount of inward value of foreign currency parcels, if any,
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Bank Branch Audit-Guidance Paper By CA. Naveen ND Gupta 12. Investment/ Stationery
For Investment held by the branch:
b. Stock of unused security paper stationery/ numbered forms like B/Rs, SGL
forms, etc may please be produced for physical verification
d. It may be confirmed whether Investment Valuation has been done as per the 13. Long Form Audit Report Branch response to the Questionnaire
In connection with the Long Form Audit Report, please let us have complete information as regards each item in the questionnaire, to enable us to verify the same for the purpose of our audit
14. Tax Audit in terms of Section 44AB of the Incometax Act, 1961
Please let us have the information required for the tax audit under section 44AB of the Incometax Act, 1961 to enable us to verify the same for the purpose of our report thereon
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Name of the Bank Branch Region/ Zone in which the Branch is located Date of Commencement Date of Completion Audit Team : Partner/s
Seniors Name
Time Taken
Initials
Juniors Name
Time Taken
Initials
Details of the Authorised Persons of the Branch Manager bank Others (Specify)
Audit Aspects General 1. Reporting to the Branch 2. Review of previous year's audit report/ LFAR, current period's internal audit report/ Revenue Audit Report/ Concurrent Audit Report/ RBI inspection Report and any other report and their compliance
Covered By Whom
Extent of Check
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auditors, RBI/internal inspectors v) Review of suit filed and decreetal accounts and provision and progress thereof and Classification NOTE: 1) Following aspects of the advances to be Verified Pre sanction: System of credit Appraisal and review/renewal Post sanction: Compliance of terms of sanction, documentation, end use of funds Monitoring: Stock & Book statements, drawing power, insurance, inspection of stock/security,
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2. Casting of Balance Sheet and crosschecking with Balance Sheet schedules 3. Scrutiny of Balance sheet, particularly i) that all the balances are shown in proper heads ii) check in case of advances: a) that interest accrued but not due on loans is not included in advances b) that credit balances in O/D, C/C inoperative current accounts account's should not be netted off with advances and the same should be shown under demand deposits iii) Check in case of deposits: a) that overdue deposits, matured time deposits, cash certificates and certificates of deposits are shown in Demand deposits b) Interest accrued but not due should not be included in deposits but, should be shown under other liability
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Inter Office Reconciliation Accounts Verify Inter Branch Items In Transit (IBIT) account for old entries Compare on test Check basis, the balance and the entries in IOR Accounts with the copies of the statements submitted to the IOR department/s Critically verify the daily enquiry memos received from the respective IOR department/s for any old and odd items and action taken by the branch for the same
Checking of Profit and Loss Items 1. Test checking of interest on deposits, (particularly, Interest checking should be done on Test basis for the period subsequent to the period of revenue/ concurrent audit) 2. Test checking of interest/ commission various advances, bills, L.C., Guarantees etc on
3. Test checking of discount/ commission on bills discounted and others 4. Critical scrutiny of the Expenses/ Income accounts and checking of important vouchers 5. Provision For Expenses, Accrued interest on deposits and advances. (Particularly check whether or not interest has been provided/ charged on all types of deposits/ advances 6. Checking of interest in NOSTRO Accounts debit balances 7. Verification of recovery on account of Locker Rent, Staff Accommodation etc with details of arrears, if any 8. Commission income on account of Government Business i.e. collection as well as remittance of Income Tax, Sales Tax, Excise Duty, etc 9. Details of Prior Period items of Income as well as expenses and complete details of provisions to be made, if any
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2. Preparation of Memorandum of changes for changes to be made in classification of Advances and in any item of Asset/ Liability and profit and loss account with other remarks and/ or information which requires further attention at Regional/ Zonal Office level 3. Obtain detailed notes on above accounts 4. Preparation of Tax Audit Report 5. Preparation of Long Form Audit Report To Collect the following Certificates 1. Physical verification of the fixed assets carried out on March 31, 2010 2. Physical verification of the cash as on March 31, 2010 3. Physical verification of cash periodically by officers of Bank 4. Certificate from the Branch for the Persons attended the audit 5. Management Representation Letter To verify and issue the following certificates Certificate of Ghosh & Jilani committee recommendations Cash on 12 odd dates. Commitment Charges payable to IDBI/ SIDBI Subsidy claims for Nov.94 Riot affected borrowers Interest Claim on FOCNA (FCNR) Deposits Risk Weighted Assets as per the Capital Adequacy Report Certificate for treating an account as bad or doubtful of recovery as per the requirement of DI&CGC Average month end Rural branch Advances Subsidy Claim under Prime Minister Rojgar Yojna
Prepared by
Reviewed by
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April 7, 2010
Dear Sirs, Sub.: Audit for the year ended March 31, 2010
This representation letter is provided in connection with your audit of the financial statements of _____________ branch of _______________ BANK for the year ended March 31, 2010 for the purpose of expressing an opinion as to whether the financial statements give a true and fair view of the financial position of ___________ branch of _______________ BANK as of March 31, 2010 and of the results of operations for the year then ended. We acknowledge our responsibility for preparation of financial statements in accordance with the requirements of the Reserve Bank of India and recognised accounting policies and practices, including the Accounting and Auditing Standards issued by the Institute of Chartered Accountants of India We confirm, to the best of our knowledge and belief, the following representations:
1. ACCOUNTING POLICIES
The accounting policies which are material or critical in determining the results of operations for the year or financial position are set out in the financial statements and are consistent with those adopted in the financial statements for the previous year. The financial statements are prepared on accrual basis except as stated otherwise in the financial statements There are no changes in the accounting policies followed by the branch during the current year 2. ASSETS The branch has a satisfactory title to all assets and there are no liens or encumbrances on the branch's assets. The branch has not received any legal notices from the landlords asking them to vacate the premises that the branch is currently occupying as a lessee
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8.2 Other than for advances, there are no matters involving the branch in any claims in litigation, arbitration or other disputes in which there may be some financial implications, including for staff claim, branch rentals, municipal taxes, local levies etc except for those which have been appropriately included under contingent liabilities 8.3 Guarantees are disclosed net of margins as at the yearend, and expired guarantee where the claim year has also expired has been correctly removed from the branch return 8.4 Contingent liabilities disclosed in the notes to the financial statements do not include any contingencies, which are likely to result in a loss and which, therefore, require adjustment of assets or liabilities
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12. We have made available to you all the following latest reports on the accounts of
our branch, and compliance by the branch on the observations contained therein: a. Previous years Branch Audit Report; b. Internal Inspection Reports;
c. Report on any other Inspection Audit that has been conducted during the
course of the year relevant to the financial year 20092010 Apart from the above, the branch has not received any notice, show cause, inspection advice, etc from Government of India, Reserve Bank of India or any other monitoring or regulatory authority of India that could have a material effect on the financial statements of the branch during the year 13.BALANCING OF BOOKS The books of the accounts are computerized and hence the subsidiary records are automatically balanced with the relevant control records 14.OVERDUE/ MATURED TERM DEPOSITS All Overdue/ Matured Term Deposits are held as Matured Term Deposits
15.ADVANCES
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29. TAX AUDIT FOR THE YEAR ENDED March 31, 2010
TAX AUDIT IN TERMS OF SECTION 44AB OF THE INCOMETAX ACT, 1961 The information required for the tax audit under section 44AB of the Incometax Act, 1961 has been made available to you in order to enable you to verify the same for the purpose of your report thereon. In respect of the Tax Audit under section 44 AB
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PART B
29.4 There is no change in nature of business in current year as compared to preceding previous year 29.5 The books of accounts maintained by us have been correctly disclosed in clause 9(b) of Form 3CD 29.6 Our Profit & Loss account does not include profits and gains assessable on presumptive basis under section 44AD, 44AE, 44AF, 44B, 44BB, 44BBA, 44BBB, 172 of the IncomeTax Act, 1961 29.7 The method of accounting followed is as per clause 11(a) which has been consistently followed in the immediately preceding previous year. There was no change in the method of accounting employed visvis the method employed in the immediately preceding previous year 29.8 Sum received from employee towards contributions to any provident fund or super annuation fund or any other fund mentioned in section 2(24)(x) which is paid/ not paid within due dates to concerned authorities under section 36(1)(va) are mentioned in Clause 16 (b) of our Form 3CD and the same are correct 29.8 In Clause 17 of Form 3CD, there are no other amounts of such items debited to Profit & Loss Account 29.9 No payments are made to persons specified under section 40A (2) (b) 29.10 There is no amount of profit chargeable to tax u/s. 41 as disclosed under clause 20 of Form 3CD 29.11 Except for the items shown under clause 21 (ii) (B), no tax, duty or other sum as referred to u/s. 43B has been provided as at the year end 29.12 No expenditure/ income of an earlier year has been debited/ credited to the Profit & Loss Account except to the extent disclosed under clause 22 (b) of Form 3CD
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Sr. No.
Item
Total
1 2
Income Interest earn ed Other inco me Expenditur e Interest exp end ed Operating exp ense s Assets Cash and bala nce with RBI Money at call and shor 45
Bank Branch Audit-Guidance Paper By CA. Naveen ND Gupta t noti ce 3 Investments 4 Advances 5 Fixed assets 6 Other assets Liabilities 1 Deposits 2 Borrowings 3 Other Liab ilitie s and prov isio ns 4 Other Items Contingent Liab ilitie s 1 Bill for coll ecti on 2 Other Items 4.6 Checklist for verification of advances & reporting in LFAR 1. In respect of common irregularities, the Auditors can give their comments
borrowerwise in the LFAR in the format given hereunder: Name of Branch Region IRAC Status Sanctioning Authority Facility Name of Borrower Limit Amount o/s. as at the year end 8 Irregularity No.
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4.7
CBDT Circular no. 3/2010 dated 02.03.2010 on TDS on payment of interest on time deposits under Section 194A of the Income Tax Act, 1961 by banks following Core- Branch Banking Solutions (CBS) software CIRCULAR NO- 03/2010. F.No.275/66/2007-IT (B) Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes New Delhi, the 2nd March, 2010.
Sub: Tax Deduction at Source on payment of interest on time deposits under Section 194A of the Income Tax Act, 1961 by banks following CoreBranch Banking Solutions (CBS) software reg.
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Item 1 1.1 1.2 1.3 1.4 CREDIT APPRAISAL Loan application not on record at Branch
IRREGULARITY
The appraisal form was not filled up correctly and thereby the appraisal and assessment was not done properly Loan application is not in the form prescribed by Head Office The Bank did not receive certain necessary documents and Annexures required with the application
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1.10 Credit report on principal borrowers and confidential report from their banks are not insisted from the borrowers 1.11 The opinion reports of the associate and/ or sister concerns of the borrower are not scrutinised 1.12 The opinion reports of the associate and/ or sister concerns of the borrower are not called for 1.13 The opinion reports of the associate and/ or sister concerns of the borrower are not updated 1.14 The opinion reports of the associate and/ or sister concerns of the borrower are not satisfactory 1.15 The procedure/ instructions of head office regarding preparation of proposals for grant not followed 1.16 The procedure/ instructions of head office regarding preparation of proposals for renewal of advances not followed 1.17 The procedure/ instructions of head office regarding preparation of proposals for enhancement of limits, etc. not followed 1.18 No exposure limits are fixed for forward contract for foreign exchange sales/ purchase transactions
SANCTIONING AND DISBURSEMENT Credit facility sanctioned beyond the delegated authority or limit of the branch Certain proposals were sanctioned pending approval of higher authorities wherever required Adhoc limits were granted for which sanctions were pending since long Facilities were disbursed before completion of documentation Facilities were disbursed without following sanction terms Facilities were disbursed without any sanction Sanction letter was missing in the branch Guarantor as required in the sanction letter was not obtained
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2.10 Sanctions were made without proper appraisal 2.11 Security charge not created before disbursement as required by sanction letter/renewed letter 2.12 Full disbursement of the facility not made 2.13 Sanction terms were not complied with or were not recorded 2.14 Disbursement Made without proper sanction 2.15 Term loan was disbursed by creating the cash credit or savings account of the borrower
DOCUMENTATION The security against which the advance was sanction was not available/ was not on record Mortgage for the property given as security is not created Mortgage for the property given as security created, was inadequate, as compared to terms of sanction Second charge as required, on assets is not created in favour of the bank Documents of Second charge on assets is not on the record Documents pertaining to registration of charges with ROC or any other concerned authority requiring charging of assets is not obtained Copies evidencing lodgment of the original conveyance/ sale deeds with the SubRegistrars for registration not on record Authority letter/ Power of Attorney to the Bank to collect the original documents from the Sub Registrar not on record Documents pertaining to consortium advances not yet executed/ not available with bank
3.10 Documents signed by persons not duly authorised to sign or who have signed in other capacity accepted by the bank 3.11 Signatures of the executants were not found on all the pages of the documents 3.12 Some of the documents on record were blank, without signatures of Branch Manager, witnesses, or guarantors, etc 3.13 Revival letters in respect of documents to be reviewed from the borrowers not received 3.14 Guarantors have expired 3.15 Guarantors not on record 3.16 Guarantors not renewed 3.17 Guarantors not assigned 3.18 Worth of the Guarantors not available 3.19 Stamping not as per the amended Stamps Act 3.20 Documents have become mutilated, soiled, time barred or not obtained
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REVIEW/ MONITORING/ SUPERVISION The account is frequently overdrawn The account is continuously overdrawn The account is overdrawn and the branches have not taken sufficient steps to regularise the accounts promptly The balance outstanding have exceeded the drawing power Balance confirmation and acknowledgment of debt not obtained The stock, bookdebts statements not received regularly/ promptly The FFI/ financial statements/audited statements/FFR 1 & 2/ other operational data, etc., not received regularly/ promptly The stock, bookdebts statements, etc., not scrutinised and no suitable action is taken The FFI/ financial statements/ audited statements/FFR 1 & 2/ other operational data, etc., not received regularly/ promptly/ not scrutinised and no suitable action is taken
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BAD AND DOUBTFUL ADVANCES The IRAC norms for classification of advances were not followed and the same is implemented through Memorandum of Changes by auditors during audit Instalments were not received from the borrowers Interest was not received from the borrowers Legal action for recovery of advances was not taken although authorised by the Board/ Controlling Authority Discontinuance of application of interest not followed although authorised by the Board/ Controlling Authority Government guarantees have expired and fresh guarantees not obtained/not renewed Terms of the BIFR scheme not complied Payment from government not received although guarantees were unconditional, irrevocable and payable on demand Delays in the settlement/ repayment in respect of sanctioned proposals
5.10 The repayment accepted in case of compromise cases inadequate visvis value of security 5.11 Compromise proposals pending at various levels where local government/ outside agencies are involved as guarantors 5.12 Copy of Search Report not on record 5.13 Decree awarded but no further steps taken for recovery 5.14 DI&CGC claims submitted/ rejected/ pending data not available 5.15 Irregular/ sticky advance not reported to the controlling authority promptly 5.16 Compromise/ OTS proposal is recommended and is under negotiation since long but not finalised. Suit is filed in the court/ DRT and pending to be finalized 5.17 ECGC claim not submitted/ lodged for recovery
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