Guidance Note on Audit of Banks
(2019 Edition)
Section C - Bank Branch Audit
other than Foreign Exchange
Transactions
Attention
Members' attention is invited to relevant directions/circulars issued by the
Reserve Bank of India up to January 1, 2019 included in a Pen Drive/CD
accompanying this Guidance Note for ease of use and reference.
Members are advised to keep track of legislative/regulatory developments,
for example, circulars of the Reserve Bank of India, issued subsequent to
the aforementioned date and having a bearing on the statutory audit of
banks/bank branches for the year ended March 31, 2019.
The Institute of Chartered Accountants of India
(Set up by an Act of Parliament)
New Delhi
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January/2019/ (Revised)
Foreword
The banking sector in India is one of the largest in the world as far as its
extensive network of branches is concerned. The role of the sector in the overall
growth and development of the Indian economy is quite significant and laudable.
Over the years, the sector has been through a long journey and has also
achieved new heights with the changing times. The widespread use of
technology has completely changed the working of banks resulting in lesser
requirements for people to visit banks physically. Nevertheless, the fundamental
aspects of banking i.e. trust and confidence of people on banking sector remains
the same. This trust and confidence come on the back of strong quality of audit
system and practices in place in India.
The Guidance Note on Audit of Banks is issued by the Auditing and Assurance
Standards Board (AASB) of ICAI every year with the objective to provide detailed
and updated guidance to the members on various aspects of bank audits. The
Guidance Note is an important resource for the members carrying out audits of
banks and bank branches. I am happy that AASB has come out with this revised
2019 edition of the Guidance Note on Audit of Banks for the benefit of the
members. I am also happy that the Guidance Note is comprehensive and self-
contained reference document for the members.
I wish to place my appreciation for CA. Shyam Lal Agarwal, Chairman, CA.
Sanjay Vasudeva, Vice-Chairman and other members of AASB for bringing out
this revised Guidance Note to help the members in maintaining quality in bank
audits.
I am confident that the members would find the Guidance Note highly useful in
their professional assignments.
January 13, 2019 CA. Naveen N.D. Gupta
New Delhi President, ICAI
Preface
Every year, the Auditing and Assurance Standards Board (AASB) of ICAI
brings out the publication, "Guidance Note on Audit of Banks" to provide
detailed guidance to the members who undertake audits of banks and bank
branches. The Guidance Note is updated every year to incorporate the
impact of developments that have taken place in the banking sector which
require attention of statutory auditors, such as, master directions/circulars of
RBI, other relevant circulars issued by RBI, relevant pronouncements of ICAI
having bearing on bank audits, amendments/changes in applicable laws or
regulations.
I am happy to place in hands of the members, this revised 2019 edition of the
Guidance Note on Audit of Banks. The Guidance Note covers in detail
various aspects like knowledge of the banking industry, initial considerations,
special considerations in a CIS Environment, risk assessment and internal
control, various items of banks' financial statements and their peculiarities,
manner of disclosure in financial statements, the RBI prudential guidelines
thereon, audit procedures, reporting on Long Form Audit Reports both at
central and branch level, Ghosh and Jilani Committee recommendations,
special purpose reports and certificates, etc.
For benefit of the members, the pen drive/CD accompanying the Guidance
Note contains Illustrative formats of engagement letter, illustrative formats of
auditor's report both in case of nationalized banks and banking companies,
illustrative formats of management representation letter, Illustrative list of
special purpose/ exception reports in CBS, Illustrative audit checklist for
capital adequacy, Illustrative checklist on audit considerations in a CIS
Environment, Features of the Gold Monetization Scheme, Suggested
Abbreviations used in the Banking Industry, Basis of Selection of Advances
Accounts in case of bank branch audit, updated bank branch audit
programme for the year 2018-19, Verification of the aspects of the Treasury/
Investments of the Bank in Statutory Audit, Flow Charts for Use of Core
Banking Solution software in case of Bank Branch Audit, the text of Master
Directions, Master Circulars and other relevant Circulars issued by RBI.
Readers may note that this edition of the Guidance Note has been divided in
three separate sections as follows:
Section A - Statutory Central Audit.
Section B - Foreign Exchange Transactions and Integrated Treasury.
Section C - Bank Branch Audit other than Foreign Exchange Transactions.
At this juncture, I wish to place on record my gratitude to all the members of
Mumbai study group viz., CA. Dhananjay J. Gokhale (Convenor), CA. Viren
H. Mehta, CA. Shriniwas Y. Joshi, CA. Sandeep D. Welling, CA. Sanjay
Khemani, CA. Niranjan Joshi, CA. Abhijit Sanzgiri, CA. Vipul K. Choksi, CA.
Abhay V. Kamat, CA. N. Sampath Ganesh, CA. Sanat Ulhas Chitale, CA.
Gautam V. Shah, CA. Manish Sampat, CA. Nilesh Joshi, CA. Parag
Hangekar, CA. Shivratan Agarwal, CA. Vikas Kumar, CA Ketan Jogalekar,
CA. Nachiket Deo, CA. Parag V. Kulkarni, CA. Dilip Dixit, CA. Jitendra
Ranawat, CA. Prakash P. Kulkarni, CA Kuntal P. Shah, CA. Giriraj Soni, CA.
Vitesh Gandhi, CA. Hitesh Pomal, CA. Pankaj Tiwari, CA. Saurabh Peshwe,
and CA. Pankaj Mittal for their dedicated efforts in revising the Guidance
Note despite the demands of their professional and personal lives under the
overall supervision of CA. Nihar Niranjan Jambusaria, Central Council
Member, ICAI. I am thankful to CA. M. P. Vijay Kumar, Central Council
Member, ICAI and his team for their efforts.
My sincere thanks to all the Members of Jaipur Study Group constituted
under my convenorship viz., CA. Bhupendra Mantri (Dy. Convenor), CA.
Vimal Chopra, CA. Prahalad Gupta, CA. Vikas Gupta, CA. Vishnu Dutt
Mantri, CA. Ajay Atolia, CA. Jugal Kishore Agrawal, CA. P. D. Baid, CA.
Mukesh Gupta, CA. Vikas Rajvanshi, CA. Thalendra Sharma, CA. Varun
Bansal, CA. Sandeep Jhanwar, and CA. Keshav Garg for reviewing exposure
draft of the Guidance Note and providing their valuable suggestions thereon.
I wish to express my sincere thanks to CA. Naveen N.D. Gupta, Honourable
President, ICAI and CA. Prafulla P. Chhajed, Honourable Vice-President, ICAI for
their guidance and support to the activities of the Board.
I am also thankful to all my Central Council colleagues for their guidance and
support to the activities of the Board. I also express my gratitude to CA.
Sanjay Vasudeva (Vice-Chairman, AASB) and all the members and special
invitees on AASB for their guidance and support in finalizing this Guidance
Note. I also thank CA. Megha Saxena (Secretary), CA. Rajnish Aggarwal
(Assistant Director), CA. Nitish Kumar (Executive Officer) and other staff of
the Board for their hard work in giving the Guidance Note its final shape.
I am sure that the members would find the Guidance Note useful while
conducting audits of banks/ bank branches.
January 13, 2019 CA. Shyam Lal Agarwal
Jaipur Chairman,
Auditing and Assurance Standards Board
Contents
Part I Knowledge of the Banking Industry .............................. 1-4
Part II Risk Assessment and Internal Control ....................... 5-30
Chapter 1: Initial Considerations........................... .....................................5-9
Chapter 2: Risk Assessment and Internal Control ......................................10-21
Chapter 3: Special Considerations in a CIS Environment ...........................22-30
Part III Audit of Advances and NPAs ................................ 31-258
Chapter 1: Advances - Agriculture .............................................................. 31-54
Chapter 2: Advances - Other than Agriculture ..........................................55-146
Chapter 3: Scrutiny of Advance Accounts presented in
Ind AS by Borrowers ............................................................. 147-160
Chapter 4: Asset Classification, Income Recognition and Provisioning ..161-258
Part IV Items of Bank's Financial Statements and
Auditing Aspects ................................................... 259-336
Chapter 1: Cash, Balances with RBI and Other Banks, and Money at
Call and Short Notice ............................................................ 259-268
Chapter 2: Fixed Assets and Other Assets ............................................269-282
Chapter 3: Borrowings and Deposits ......................................................283-300
Chapter 4: Other Liabilities and Provisions .............................................301-304
Chapter 5: Contingent Liabilities and Bills for Collection .........................305-315
Chapter 6: Profit and Loss Account ........................................................316-336
Part V Long Form Audit Report ....................................... 337-382
Chapter 1: Long Form Audit Report in case of Bank Branches ..............337-382
Part VI Special Aspects .................................................... 383-420
Chapter 1: Basel III .................................................................................383-394
Chapter 2: Special Purpose Reports and Certificates ............................. 395-399
Chapter 3: Compliance with Implementation of Ghosh & Jilani
Committee Recommendations ..............................................400-407
Chapter 4: Other Aspects.............................................................408-420
Contents of Accompanying Pen Drive/CD
Foreword and Preface of Past Years ..........................................................421-464
1. Part I Knowledge of the Banking Industry .....................................465-584
1. Banking in India ................................................................................466-502
2. Accounting and Auditing Framework .................................................503-523
3. Accounting Systems ..........................................................................524-568
4. Legal Framework...............................................................................569-584
2. Appendices ..........................................................................................585-702
I. Text of Section 6 of the Banking Regulation Act, 1949
II. The Third Schedule to the Banking Regulation Act, 1949
III. Illustrative Format of Report of the Branch Auditor of a Nationalised
Bank
IV. Illustrative Format of Report of the Branch Auditor of a Banking
Company
V. Illustrative Format of Engagement Letter to be sent to the
Appointing Authority of the Nationalised Bank by Branch Auditor
VI. Illustrative Format of Written Representation Letter to be
obtained from the Branch Management
VII. Illustrative Checklist on Audit Considerations in CIS Environment
VIII. Overview of Various CBS and Basic Concepts
IX. List of Important Menu Commands of CBS
X. Illustrative Checklist on Audit activity through CBS
XI. Features of the Gold Monetization Scheme
XII. Illustrative Audit Checklist for Capital Adequacy
3. Suggested Abbreviations used in the Banking Industry ........................703-720
4. Illustrative list for Basis of Selection of Advance Accounts in
case of Bank Branch Audit ....................................................................721-722
5. Illustrative Bank Branch Audit Programme for the year ended
March 31, 2019 .....................................................................................723-742
6. Illustrative Flow Charts for Use of Core Banking Solution software
in case of Bank Branch Audit ................................................................ 743-746
7. List of Relevant Master Directions issued by RBI .................................747-749
8. List of Relevant Master Circulars issued by RBI ...................................750-752
9. List of Relevant General Circulars.........................................................753-783
PART I
I
Knowledge of the Banking
Industry
1.01 The banking industry is the backbone of any economy as it is essential
for sustainable socio-economic growth and financial stability in the economy.
There are different types of banking institutions prevailing in India which are as
follows:
(a) Commercial Banks
(b) Regional Rural Banks
(c) Co-operative Banks
(d) Development Banks (more commonly known as `Term-Lending Institutions')
(e) Foreign Banks
(f) Payment Banks
(g) Small Finance Banks
(h) EXIM Bank
1.02 All these banks have their unique features and perform various
functions / activities subject to complying with the RBI guidelines issued from
time to time. Section 6 of the Banking Regulation Act, 1949, lists down the forms
of business in which banking companies may engage. The text of the Section 6
has been reproduced in Appendix I of the Guidance Note (given in Pen
Drive/CD accompanying the Guidance Note).
1.03 Of these banks, commercial banks are the most wide spread banking
institutions in India. Commercial banks provide a number of products and
services to general public and other segments of economy. Two of the main
functions of commercial banks are (1) accepting deposits and (2) granting
advances. In addition to their main banking activities, commercial banks also
undertake certain eligible Para Banking activities which are governed by the RBI
guidelines on Para Banking activities.
Guidance Note on Audit of Banks (Revised 2019)
1.04 The functioning of banking industry in India is regulated by the Reserve
Bank of India (RBI) which acts as the Central Bank of our country. RBI is
responsible for development and supervision of the constituents of the Indian
financial system (which comprises banks and non-banking financial institutions)
as well as for determining, in conjunction with the Central Government, the
monetary and credit policies keeping in with the need of the hour. Important
functions of RBI are issuance of currency; regulation of currency issue; acting as
banker to the central and state governments; and acting as banker to commercial
and other types of banks including term-lending institutions. Besides, RBI has
also been entrusted with the responsibility of regulating the activities of
commercial and other banks. No bank can commence the business of banking or
open new branches without obtaining licence from RBI. The RBI also has the
power to inspect any bank.
1.05 The provisions regarding the financial statements of banks are
governed by the Banking Regulation Act, 1949. The Third schedule to the
aforesaid Act, prescribes the forms of balance sheet and profit and loss account
in case of banks. Readers may refer Appendix II of the Guidance Note (given in
Pen Drive/CD accompanying the Guidance Note) for text of third schedule to the
Banking Regulation Act, 1949. Further, in case of banking companies, the
requirements of the Companies Act, 2013, relating to the balance sheet, profit
and loss account and cash flow statement of a company, in so far as they are not
inconsistent with the Banking Regulation Act, 1949, also apply to the financial
statements, as the case may be, of a banking company. It may be noted that this
provision does not apply to Nationalised Banks, State Bank of India, its
Subsidiaries and Regional Rural Banks (RRBs).
1.06 The provisions regarding audit of Nationalised Banks are governed by
the Banking Regulation Act, 1949 and the RBI Guidelines. The provisions
regarding audit of Banking Companies are governed by the Banking Regulation
Act, 1949, RBI Guidelines and the provisions of the Companies Act, 2013. The
illustrative formats of auditor's report are given in Appendices III to IV of the
Guidance Note (given in Pen Drive/CD accompanying the Guidance Note) as
follows:
2
Knowledge of the Banking Industry
Appendix III - Illustrative Format of Report of the Branch Auditor of a
Nationalised Bank
Appendix IV - Illustrative Format of Report of the Branch Auditor of a Banking
Company
1.07 The auditors (both central statutory auditors and branch auditors)
should also ensure that their audit report complies with the requirements of SA
700(Revised), "Forming an Opinion and Reporting on Financial Statements", SA
705(Revised), "Modifications to the Opinion in the Independent Auditor's Report"
and SA 706 (Revised), "Emphasis of Matter Paragraphs and Other Matter
Paragraphs in the Independent Auditor's Report".
1.08 Besides the main audit report, the terms of appointment of auditors of
public sector banks, private sector banks and foreign banks (as well as their
branches), require the auditors to also furnish a Long Form Audit Report (LFAR).
The matters to be dealt with by auditors in LFAR have been specified by the RBI.
If the auditor intends to issue modified opinion, reasons for such modified opinion
need to be mentioned.
1.09 For the reference and benefit of the members, illustrative Formats for
Engagement Letter to be sent to the appointing authority of the Nationalised
`Bank by Branch Auditor & Written Representation Letter to be obtained from
Branch Management are given in Appendices V & VI of the Guidance Note.
1.10 Further various Illustrative Audit Checklists and Broad features of the
Gold Monetization Scheme are given in Appendices VII to XII of the Guidance
Note (given in Pen Drive/CD accompanying the Guidance Note) as follows:
Appendix VII - Illustrative Checklist on Audit Considerations in CIS
environment
Appendix VIII - Overview of various CBS and Basic Concepts
Appendix IX - List of important Menu Commands of CBS
Appendix X - Illustrative Checklist on Audit activity through CBS
Appendix XI - The Broad features of the Gold Monetization Scheme
Appendix XII - Illustrative Audit Checklist for Capital Adequacy
3
Guidance Note on Audit of Banks (Revised 2019)
Important Note
Readers may refer the Pen Drive/CD accompanying the Guidance Note wherein
the details of the following Chapters of "Part I - Knowledge of the Banking
Industry" have been given:
Chapter 1: Banking in India
Chapter 2: Accounting and Auditing Framework
Chapter 3: Accounting Systems
Chapter 4: Legal Framework
4
PART - II
II-1
Initial Considerations
1.01 This section discusses the matters to be considered by a proposed
statutory branch auditor (SBA) upon receiving intimation of appointment and
before commencing the actual audit engagement. It deals with aspects of
preliminary work to be undertaken by the branch auditor before actually
commencing the audit work. The letter of appointment sent by banks to branch
auditors typically contains the following:
Appointment under the Banking Regulation Act, 1949, and the underlying
duties and responsibilities of the SBA.
Particulars of branch(s) to be audited and of the region/zone to which the
branch reports.
Particulars of statutory central auditors.
Particulars of previous auditors.
Guidelines for conducting audit of Branches, completion of audit, eligible
audit fees and reimbursement of expenses etc.
Procedural requirements to be complied with in accepting the assignment,
e.g., letter of acceptance, declaration of indebtedness, declaration of fidelity
and secrecy, other undertaking by the firm/SBA, specimen signatures, etc.
Scope of work - Besides the statutory audit under the provisions of the
Banking Regulation Act, 1949, SBA is also required to verify certain other
areas and issue various report and certificates like LFAR, Tax Audit Report,
certificates for cash verification on odd dates, Ghosh & Jilani reports etc.
Auditors need to note compliance with relevant and applicable Engagement
and Quality Control Standards issued by the ICAI.
An illustrative format of engagement letter to be sent to the appointing authority
of the Nationalised Bank by Branch Auditor is given in Appendix V of the
Guidance Note.
Co-ordination with Branch Management
1.02 Now a days typically, SBA, are given limited time within which they have
to undertake the audit of branches allotted to them. Co-ordination between the
auditor and the branch management is essential for an effective audit, timely
Guidance Note on Audit of Banks (Revised 2019)
completion with the highest audit quality. NOC from the previous auditor should
be obtained and kept on record by SBA. It is advisable that immediately after
accepting the appointment, the SBA should send a formal communication to the
branch management/HO accepting his appointment and other declarations and
undertakings so required. Further, the SBA should also specify the books,
records, and other information that he would require in the course of his audit.
Such a communication would enable the branch management to keep the
requisite documents, information, etc., ready.
1.03 After the completion of the appointment formalities, the SBA should
immediately visit the concerned branches allotted, so as to get the feel of the
business, nature and competences of the staff and understanding of the flow of
information and authority. Thereafter, the SBA should draw up a detailed plan for
the audit and it is advisable to complete the entire non-financial verification (like
documentation, sanctioning terms, review of the supervision and monitoring
terms, review of the concurrent/internal audit and inspection reports before the
year-end. An illustrative format of written representation letter to be obtained from
the branch management is given in Appendix VI of this Guidance Note.
Standard on Auditing (SA) 600, "Using the Work of Another Auditor"
1.04 The SBA's report on the financial statements examined by him is
forwarded to the SCA with a copy to the management of the bank. The SCA, in
preparing his report on the financial statements of the bank as a whole, deals
with the branch audit reports in such manner as he considers necessary. In such
a reporting arrangement, Standard on Auditing (SA) 600, "Using the Work of
Another Auditor" needs to be emphasized.
1.05 Considering the volume of transactions to be verified and the
organizational structure of bank, particularly in the case of public sector banks,
SCA's reliance on work done by the SBA is of utmost importance.
1.06 The SCA would be the Principal Auditor (PA), who is responsible for the
reporting on the financial information for the bank as a whole and the SBA would
be the other auditor (OA) other than the PA, who is responsible for reporting on
financial information of the branch as a component. As per SA 600, the degree of
reliance, SCA would have on the SBA would depend upon many considerations,
few of which are discussed as follows:
(a) the materiality of the portion of the financial information which the SBA
audits and its effect on the overall financial position;
(b) the technical competence and knowledge of the SBA and the degree of
confidence he provides to the SCA;
6
Initial Considerations
(c) the SCA's assessment of risk of material misstatements in the financial
information of the components audited by the other auditor; and
(d) the performance of additional procedures as set out in SA 600 regarding the
components audited by other auditor resulting in the principal auditor having
significant participation in such audit.
1.07 The SCA should perform procedures to obtain sufficient appropriate
audit evidence, that the work of the SBA is adequate for the SCA's purposes in
the context of the specific assignment. The SCA might discuss with the SBA the
audit procedures applied or review a written summary of the SBA's procedures
and findings which may be in the form of a completed questionnaire or check-list
or an Audit Summary Memorandum. This is usually done via the personal
meeting between the SCA and all the SBA or via the bank's closing instruction
(as discussed before). The nature, timing and extent of procedures will depend
on the circumstances of the engagement and the SCA's knowledge of the
professional competence of the SBA. The SCA may conclude that it is not
necessary to apply procedures such as those described in above paragraph
because sufficient appropriate audit evidence has been previously obtained that
acceptable quality control policies and procedures are complied with in the
conduct of SBA's practice.
1.08 The SCA should consider the significant findings of the SBA. The SCA
may consider it appropriate to discuss with the SBA and the management of the
component, the audit findings or other matters affecting the financial information
of the components. He may also decide that supplemental tests of the records or
the financial statements of the component are necessary. Such tests may,
depending upon the circumstances, be performed by the SCA or the SBA.
1.09 In certain circumstances, the SBA may happen to be a person other
than a professionally qualified auditor. This may happen, for instance, where a
component is situated in a foreign country and the applicable laws permit a
person other than a professionally qualified auditor to audit the financial
statements of such component. In such circumstances, the procedures outlined
above assume added importance.
1.10 The SCAs should document in working papers the extent of reliance
placed upon the work done by other auditors with reasons therefor. The SCA
should also document the procedures performed as prescribed by SA 600 and
conclusions reached. The SCAs should document how they have dealt with a
specified opinion (i.e. qualified, adverse or disclaimer) of the SBAs in framing
their report.
7
Guidance Note on Audit of Banks (Revised 2019)
1.11 Further, it is also the responsibility of the SBAs to inform or bring to the
notice of the SCA any areas of concern that have come to their knowledge in the
context in which his work is to be used by the SCA. For example, by bringing to
the SCA's immediate attention any significant findings requiring to be dealt with
at entity level, adhering to the time-table for audit of the component, etc. SBA
should ensure compliance with the relevant statutory requirements. Similarly, the
SCA should advise the SBA of any matters that come to his attention that he
thinks may have an important bearing on the SBA's work.
1.12 When the SCAs has to base their opinion on the financial information of
the entity as a whole relying upon the statements and reports of the SBAs, their
report should state clearly the division of responsibility for the financial
information of the entity by indicating the extent to which the financial information
of components audited by the SBAs have been included in the financial
information of the entity, e.g., the number of divisions/branches/ subsidiaries or
other components audited by SBAs. The SCA would not be responsible in
respect of the work entrusted to the SBAs, except in circumstances which should
have aroused his suspicion about the reliability of the work performed by the
SBAs.
Engagement and Quality Control Standards
1.13 The auditor/audit firm should establish a system of quality control
designed to provide reasonable assurance that the auditor/firm and its personnel
comply with professional standards and regulatory and legal requirements, and
that reports issued by the firm or engagement partner(s) are appropriate in the
circumstances and will survive the test of any regulatory, legal or other action
that may arise in future. This system of quality control should consist of policies
designed to achieve its objectives and the procedures necessary to implement
and monitor compliance with those policies. The nature of the policies and
procedures developed by individual or firms to comply with SQC will greatly
depend on various factors such as the size, maturity, geographical location, type
of work handled and other operating characteristics.
1.14 The ICAI has issued various Engagement and Quality Control
Standards applicable to an audit of financial statements which are mandatorily to
be followed by all practitioners. Understanding of the concepts in these
Engagement Standards would help the auditor in discharging his duties in a
diligent way.
Special Audit Considerations in Foreign Banks
1.15 Audit of foreign banks operating in India, poses unique challenges
compared to local banks in India. Foreign banks have different operating models
8
Initial Considerations
compared to local banks, and, to a limited extent, they also operate in a different
regulatory environment.
1.16 Foreign banks operate in India through branches and do not have a
separate legal entity existence in India. However, for all practical purposes, the
RBI regulates their functioning in India, with regards to scale and nature of
business they undertake in India.
1.17 Auditors of foreign bank will have to modify their audit procedures so as
to take care of the operational structure and operations of these banks. Some of
the important elements related to foreign banks which may have a bearing on the
audit plan and procedure are listed below:-
Management structure.
More centralised operational functions.
Core banking software used globally.
Requirement for compliance with foreign legal and regulatory requirements.
Cross border flow and processing of data.
Complex treasury operations and cross border forex deals.
Operational processes.
9
II-2
Risk Assessment and Internal
Control
Characteristics of a Bank
2.01 Banks have certain characteristics distinguishing them from most other
commercial enterprises e.g.,
Custody of large volumes of monetary items, including cash and negotiable
instruments, whose physical security has to be ensured. This applies to
storage and the transfer of monetary items making banks vulnerable to
misappropriation and fraud necessitating establishment of formal operating
procedures, well-defined limits for individual discretion and rigorous systems
of internal control.
Significant dependence on third party agencies e.g. Cash Replenishment
Agencies, Telcos, etc. bearing risks of outsourcing of certain important
banking processes.
Engagement in a large volume and variety of transactions in terms of
number and value which necessarily requires complex accounting and
internal control systems and extensive use of Information Technology (IT).
Operation through a wide network of geographically dispersed branches and
offices necessitating a greater decentralization of authority and dispersal of
accounting and control functions, with consequent difficult challenges in
maintaining uniform operating practices and accounting systems, particularly
when the branch network transcends national boundaries.
Assumption of significant commitments including those without actual
outflow of funds. These items, called 'off-balance sheet' items, may at times
not involve accounting entries and the failure to record such items may be
difficult to detect.
Engagement in transactions that are initiated at one location, recorded at a
different location and managed at yet another location.
Direct Initiation and completion of transactions by the customer without any
intervention by the bank's employees. For example, over the Internet or
mobile or through automatic teller machines (ATMs).
Risk Assessment and Internal Control
Integration and linkages of national and international settlement systems
could pose a systemic risk to the countries in which they operate.
Regulatory requirements by governmental authorities often influence
accounting and auditing practices in the banking sector.
Continuing development of new products and services and banking
practices
The auditor should consider the effect of the above factors in designing his audit
approach. It is imperative for SCAs to have detailed knowledge of the products
offered by banks and risks associated with them, and appropriately address them
in their audit plan to the extent they give rise to the risk of material misstatements
in the financial statements.
In today's environment, the banks use different applications to carry out different
transactions which may include data flow from one application to other
application; the auditor while designing his plans should also understand
interface controls between the various applications.
Identifying and Assessing the Risks of Material
Misstatements
2.02 Standard on Auditing (SA) 315, "Identifying and Assessing the Risks of
Material Misstatement Through Understanding the Entity and Its Environment"
requires the auditor to identify and assess the risks of material misstatement at
the financial statement level and the assertion level for classes of transactions,
account balances, and disclosures and paragraph 26 of SA 315 provides a basis
for designing and performing further audit procedures.
SA 315 requires the auditor to put specific emphasis on the risks arising out of
the fraud, changes in regulatory environment, complex transactions, related party
transactions, and abnormal business transactions.
2.03 The risk assessment and internal control assessment differs from the
perspective of Statutory Central Auditor (SCA) and Statutory Branch Auditor
(SBA) and needs to be considered based on the need of the work at respective
levels. The level of work at SCA level would be much more comprehensive as
compared to the work required at SBA level. The level of work required at SBA
level would also differ based on the size of the branch and the nature of business
being carried out at the branch level and would be a matter of professional
judgement. The SCA as well as SBA would need to carry out certain common
risk assessment and internal control assessment apart from specific assessment
required to be carried out at their level. The SBA is required to make assessment
of their work based on the size of the branch, nature of assets and liabilities and
11
Guidance Note on Audit of Banks (Revised 2019)
type of business being done at branch. The SBA can get detailed guidance
based on the risk assessment and control given for SCAs and determine as to
what shall be applicable for them at the branch level and do the needful
accordingly. Some of such key items to be looked upon at the branch level are
discussed below.
Understanding the Bank Branch and Its Environment
including Internal Control
2.04 As per SA 315, the auditor's objective is to identify and assess the risks
of material misstatement, whether due to fraud or error, at the financial statement
and assertion levels, through understanding the entity and its environment,
including the entity's internal control, thereby providing a basis for designing and
implementing responses to the assessed risks of material misstatement.
2.05 The audit engagement partner should appropriately be involved so as to
achieve its basic objective of identifying and assessing the risks of material
misstatement, whether due to fraud or error, at the financial statement and
assertion levels. The use of professional skepticism, and experience acquired
during the course of other audits play a vital role in this process.
2.06 The auditor is also required to:
Obtain an understanding of the bank's branch accounting process relevant
to financial reporting.
Obtain an understanding of the bank's branch internal control relevant to the
audit.
Structure of overall internal control environment of a bank
2.07 The auditor should obtain an understanding of the control environment
sufficient to assess management's attitudes, awareness and actions regarding
internal control and their importance in the entity. Such an understanding would
help to make a preliminary assessment of the adequacy of the accounting and
internal control system as a basis for the preparation of the financial statements,
and of the likely nature, timing and extent of audit procedures.
2.08 The overall control environment of a bank generally includes a mix of
the various controls in place. The SBA should review the same relating to branch
with respect to internal audit being done relating to branch and adequacy of the
same, revenue audit conducted during the year at branch, inspection of the
branch carried out by bank staff as well as RBI inspectors, concurrent audit
prevalent in the branch, systems audit carried out, etc. These reports shall help
12
Risk Assessment and Internal Control
the auditor to understand the controls and risk prevalent at the branch which
shall help the SBA to plan his working accordingly.
Structure of Internal Control Procedures in a Bank
I. Delegation of Powers
2.09 Banks have detailed policy on delegation of powers. The financial and
administrative powers of each committee/each official/each position are fixed and
communicated to all persons concerned. This approved policy on delegation of
powers should be taken by SBA.
II. Authorisation of Transactions
2.10 Authorisation may be general (i.e., it may relate to all transactions that
conform to prescribed conditions referred to as routine transactions) or it may be
specific with reference to a single transaction (non-routine transactions and
accounting estimates). It is necessary to establish procedures which provide
assurance that authorisations are issued by persons acting within the scope of
their authority, and that the transactions conform fully to the terms of the
authorisations. The following procedures are usually established in banks for this
purpose:
All financial decisions at any level are required to be reported to the next
higher level for confirmation/information. For example, in case of a money
market transaction, if the dealer exceeds the pre-defined limits such as a
position limit or counterparty limit, then the transaction has to be vetted and
confirmed by the head dealer.
All transactions entered into the applications require authorization at different
level based on authority to get executed.
Any deviation from the laid down procedures requires confirmation
from/intimation to higher authorities.
Branches have to send periodic confirmation to their controlling authority on
compliance of the laid down systems and procedures.
SBAs should specifically review the delegation of powers to note the
authorization, approval, exception, waiver and ratification powers of each bank
official.
III. Segregation and Rotation of Duties
2.11 A fundamental feature of an effective internal control system is the
segregation and rotation of duties in a manner conducive to prevention and
timely detection of occurrence of frauds and errors. Work of one staff member is
13
Guidance Note on Audit of Banks (Revised 2019)
invariably supervised / checked by another staff member, irrespective of the
nature of work.
Banks have a system of rotation of job amongst staff members, which reduces
the possibility of frauds and is also useful in detection of frauds and errors. Most
banks usually have a process of giving "block" leave to its staff members wherein
the employee stays away from work for at least a continuous period of 2 weeks.
IV. Maintenance of Adequate Records and Documents
2.12 Accounting controls should ensure that the transactions are recorded at
correct amount and in the accounting periods in which they are executed, and
that they are classified in appropriate accounts. The procedures established in
banks to achieve these objectives usually include the following:
All records are maintained in the prescribed books and registers only. This
ensures that all requisite particulars of a transaction are adequately recorded
and also that the work of finalisation of accounts is facilitated.
All Bank branches have a unique code number which is circulated amongst
all offices of the bank and is required to be put on all important instruments.
All books are to be balanced periodically and it is to be confirmed by an
official specifically assigned for the same.
All inter-office transactions are to be reconciled at regular intervals within a
specified time frame.
V. Accountability for and Safeguarding of Assets
2.13 The accountability for assets starts at the time of their acquisition and
continues till their disposal. The accountability for assets is achieved by
maintenance of records of assets and their periodic physical verification. To
safeguard the assets, it is also necessary that access to assets is limited to
authorised personnel and covers direct physical access and also indirect access
through preparation or processing of documents that authorise the use or
disposal of assets. The following are some of the important controls implemented
by banks in this regard:
Particulars of lost security forms which are immediately advised to branches
to exercise caution.
Specimen signatures of all officers are captured and scanned in the system
and available for view/access in all branches which were earlier maintained
in a book. The officials approving the payment of the instruments drawn on
14
Risk Assessment and Internal Control
their branches by other branches are required to confirm the signatures on
the instruments with reference to the specimen signatures. Likewise, the
branches have on record the specimen signatures of the authorised officials
of approved correspondent banks also.
Instruments of fund remittances above a cut-off level are to be signed by
more than one official.
Important financial messages, when transmitted electronically, are generally
encrypted.
Negative lists like stop-payment cheques or stop payment instructions are
kept, which may deal with the particular kind of transaction. There may be a
caution list for advances also.
Sensitive items like currency, valuables, draft forms, term deposit receipts,
traveller's cheques and other such security forms are in the custody of at
least two officials of the branch. (However, in the case of very small
branches having only one official, single custody is also permitted.)
All assets of the bank/charged to the bank are physically verified at specified
intervals.
Engagement Team Discussions
2.14 The engagement team should hold discussions to gain better
understanding of the bank branch and its environment, including internal control,
and also to assess the potential for material misstatements of the financial
statements. All these discussions should be appropriately documented for future
reference.
2.15 The discussion between the members of the engagement team and the
audit engagement partner should be done on the susceptibility of the bank's
branch financial statements to material misstatements. These discussions are
ordinarily done at the planning stage of an audit. Specific emphasis should be
provided to the susceptibility of the bank's financial statements to material
misstatement due to fraud, that enables the engagement team to consider an
appropriate response to fraud risks, including those related to engagement risk,
pervasive risks, and specific risks. It further enables the audit engagement
partner to delegate the work to the experienced engagement team members, and
to determine the procedures to be followed when fraud is identified. Further, audit
engagement partner may review the need to involve specialists to address the
issues relating to fraud.
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Guidance Note on Audit of Banks (Revised 2019)
Establish the Overall Audit Strategy
2.16 Standard on Auditing (SA) 300, "Planning an Audit of Financial
Statements'' states that the objective of the auditor is to plan the audit so that it
will be performed in an effective manner. For this purpose, the audit engagement
partner should:
establish overall audit strategy, prior to the commencement of an audit; and
involve key engagement team members and other appropriate specialists
while establishing the overall audit strategy depending on the characteristics
of the audit engagement.
2.17 The overall audit strategy sets the scope, timing and direction of the
audit as it guides the development of detailed audit plan. The establishment of
the overall audit strategy involves:
Consider the guidance / closing checklist given by Head Office / SCAs.
Consider the various RBI Circulars, Master Circulars and Master Directions
issued from time to time, as applicable.
Consider the requirements of various Accounting Standards, Guidance
Notes and Standards on Auditing, to the extent applicable, to assess the
nature and extent of audit procedures to be performed.
Ascertaining the reporting objectives of the audit engagement to plan the
timing of the audit and the nature of the communications required, such as
deadlines for interim and final reporting, key dates for expected
communications with the management and with those charged with
governance.
Consider the results of preliminary engagement activities and, where
applicable, whether knowledge gained on other engagements performed by
the engagement partner for the bank is relevant.
Audit Planning Memorandum
2.18 The auditor should summarise audit plan by preparing an audit planning
memorandum in order to:
Describe the expected scope and extent of the audit procedures to be
performed.
Highlight all significant issues and risks identified during planning and risk
assessment activities, as well as decisions of reliance on controls.
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Risk Assessment and Internal Control
Provide evidence that they have planned the audit engagement
appropriately and have responded to engagement risk, pervasive risks,
specific risks, and other matters affecting the audit engagement.
Operating Framework for Identifying and Dealing with
Frauds
2.19 All banks have policy and operating framework in place for detection,
reporting and monitoring of frauds as also the surveillance/ oversight process in
operation so as to prevent the perpetration of frauds. The RBI, vide its Circular
No. DBS. CO.FrMC.BC.No.10/23.04.001/2010-11 dated 31st May 2011 had
identified certain areas wherein frauds had shown occurrence or increasing trend
in banks. These areas include:
loans/ advances against hypothecation of stocks.
housing loans cases.
submission of forged documents including letters of credit.
escalation of overall cost of the property to obtain higher loan amount.
over valuation of mortgaged properties at the time of sanction.
grant of loans against forged FDRs.
over-invoicing of export bills resulting in concessional bank finance,
exemptions from various duties, etc.
frauds stemming from housekeeping deficiencies.
2.20 RBI has accordingly prescribed certain guidelines to be incorporated by
the banks in their operating framework for identifying and dealing with frauds.
The operating framework for tracking frauds and dealing with them should be
structured along the following tracks:
i. Detection and reporting of frauds.
ii. Corrective action.
iii. Preventive and punitive action.
iv. Provisioning for Frauds.
RBI has vide its circular RBI/2015-16/376 DBR.No.BP.BC.92/21.04.048/ 2015-16
dated 18th April, 2016, decided to amend the provisioning norms in respect of all
cases of fraud, as under:
a. Banks should normally provide for the entire amount due to the bank or for
which the bank is liable (including in case of deposit accounts), immediately
upon a fraud being detected. While computing the provisioning requirement,
17
Guidance Note on Audit of Banks (Revised 2019)
banks may adjust financial collateral eligible under Basel III Capital
Regulations - Capital Charge for Credit Risk (Standardised Approach), if
any, available with them with regard to the accounts declared as fraud
account;
b. However, to smoothen the effect of such provisioning on quarterly profit and
loss, banks have the option to make the provisions over a period, not
exceeding four quarters, commencing from the quarter in which the fraud
has been detected;
c. Where the bank chooses to provide for the fraud over two to four quarters
and this results in the full provisioning being made in more than one
financial year, banks should debit 'other reserves' [i.e., reserves other than
the one created in terms of Section 17(2) of the Banking Regulation Act
1949] by the amount remaining un-provided at the end of the financial year
by credit to provisions. However, banks should proportionately reverse the
debits to `other reserves' and complete the provisioning by debiting profit
and loss account, in the subsequent quarters of the next financial year;
Assess the Risk of Fraud
2.21 As per SA 240, "The Auditor's Responsibilities Relating to Fraud in an
Audit of Financial Statements", the auditor's objectives are to identify and assess
the risks of material misstatement in the financial statements due to fraud, to
obtain sufficient appropriate audit evidence on those identified misstatements
and to respond appropriately. The attitude of professional skepticism should be
maintained by the auditor so as to recognise the possibility of misstatements due
to fraud. When obtaining an understanding of the bank and its environment, the
auditor should make inquiries of branch management, internal auditors and
others.
2.22 ICAI in February 2016 issued the Revised Guidance Note on Reporting
on Fraud under Section 143(12) of the Companies Act, 2013. Part B of the
Guidance Note paragraph 11 deals with reporting to RBI in case of frauds noted
in audit of banks. Auditors of banking companies may also refer the aforesaid
Guidance Note for further clarity.
2.23 RBI circular dated 7th May 2015 on framework for dealing with loan
frauds has introduced the concept of a Red Flag Account (RFA), i.e., an account
where suspicion of fraudulent activity is thrown up by the presence of one or
more early warning signals (EWS).
2.24 These Early Warning signals are as advised by RBI which should alert
the bank officials about some wrongdoings in the loan accounts which may turn
out to be fraudulent.
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Risk Assessment and Internal Control
Assess the Risk of Money Laundering
2.25 Due to the nature of their business, banks are ready target for those
who are engaged in the money laundering activities by which the proceeds of
illegal acts are converted into proceeds from the legal acts. The RBI has framed
specific guidelines that deal with prevention of money laundering and "Know
Your Customer (KYC)" norms. The RBI has from time to time issued guidelines
("Know Your Customer Guidelines Anti Money Laundering Standards"),
requiring banks to establish policies, procedures and controls to deter and to
recognise and report money laundering activities. The RBI, vide its master
direction no. RBI/DBR/2015-16/18 Master Direction DBR.AML.BC.No.81/
14.01.001/2015-16 dated December 08, 2016, (Updated July 12, 2018) on "Know
Your Customer (KYC) Direction, 2016", have advised the banks to follow certain
customer identification procedure for opening of accounts and monitoring
transactions of a suspicious nature for the purpose of reporting it to appropriate
authority. These policies, procedures and controls commonly extend to the
following:
Customer acceptance policy, i.e., criteria for accepting the customers.
Customer identification procedure, i.e., procedures to be carried out while
establishing a banking relationship; carrying out a financial transaction or
when the bank has a doubt about the authenticity/veracity or the adequacy
of the previously obtained customer identification data. A requirement to
obtain customer identification (know your client).
Monitoring of transactions Banks are advised to set key indicators for risk
sensitive (e.g., high turnover accounts or complex or unusual transactions
accounts) accounts, taking note of the background of the customer, such as
the country of origin, sources of funds, the type of transactions involved and
other risk factors. Banks should also put in place a system of periodical
review of risk categorisation of accounts and the need for applying enhanced
due diligence measures. Such review of risk categorisation of customers
should be carried out at a periodicity of not less than once in six months. In
view of the risks involved in cash intensive businesses, accounts of bullion
dealers (including sub-dealers) and jewellers, the banks are also advised to
categorise these accounts as `high risk' requiring enhanced due diligence.
Further, the banks are also required to subject these 'high risk accounts ' to
intensified transaction monitoring. High risk associated with such accounts
should be taken into account by banks to identify suspicious transactions for
filing Suspicious Transaction Reports (STRs) to Financial Intelligence Unit
India (FIU-IND).
19
Guidance Note on Audit of Banks (Revised 2019)
2.26 Further, banks should closely monitor the transactions in accounts of
marketing firms (MLM Companies). In cases where a large number of cheque
books are sought by the company, there are multiple small deposits (generally in
cash) across the country and where a large number of cheques are issued
bearing similar amounts/dates, the bank should carefully analyse such data and
in case they find such unusual operations in accounts, the matter should be
immediately reported to Reserve Bank and other appropriate authorities such as
Financial Intelligence Unit India (FIU-Ind) under Department of Revenue, Ministry
of Finance.
2.27 Banks were advised to complete the process of risk categorization and
compiling/updating profiles of all of their existing customers in a time-bound
manner latest by end-March 2013.
2.28 Such review of risk categorisation of customers has to be carried out at
a periodicity of not less than once in six months.
2.29 Some methods in which money laundering takes place are as under -
Breaking up of cash into smaller amounts and depositing it in to the bank
below the monitored reporting thresholds.
Physically moving the cash into locations or jurisdictions and depositing it in
off shore banks with lesser stringent enforcement laws and regulations.
Using business typically known to receive revenue in cash to be used to
deposit criminally derived cash.
Trade based laundering Over or Under Invoicing.
Shell companies operating in jurisdictions not requiring reporting of
beneficial owner to earn tax favored profits.
Round Tripping wherein money is deposited in a controlled foreign
corporation offshore preferably a tax haven where minimal records are kept
& then shipped back as FDI to earn tax favored profits through a shell
company.
Use of Casinos Chips are purchased with laundered cash and on winning,
the buyer either gets back the winnings in cheque or gets a receipt for the
winnings.
Real estate Transactions seller agrees to understate the value of the
property and collects the difference in cash.
Bank capture Buying a controlling interest in a Bank in a jurisdiction with
weak money laundering controls and then move money through the bank
without much scrutiny.
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Risk Assessment and Internal Control
At Branch level the Statutory Branch Auditors may review process of
documenting explanations received from customer regarding AML alerts.
Response to the Assessed Risks
2.30 SA 330, "The Auditor's Responses to Assessed Risks" deals with the
auditor's responsibility to design and implement responses to the risks of material
misstatement identified and assessed by the auditor in accordance with SA 315.
Further, it requires the auditor to design and implement overall responses to
address the assessed risks of material misstatement at the financial statement
level. The auditor should design and perform further audit procedures whose
nature, timing and extent are based on and are responsive to the assessed risks
of material misstatement at the assertion level.
2.31 The auditor shall design and perform tests of controls and substantive
procedures to obtain sufficient appropriate audit evidence, as to the operating
effectiveness of relevant controls, and to detect material misstatements at the
assertion level.
21
II-3
Special Considerations in a CIS
Environment
Introduction
3.01 The face of Banking Industry is changing rapidly. What Banking is today
is quite different from what it was in the years gone by. Rapid strides in
technological advancements, payment systems, integration of AADHAR for Card
Less transactions is changing the way of banking. However, in recent times there
have been few instances of manipulating the banking system for unlawful gains
and frauds.
Responsibilities of Branch Auditors
3.02 Generally, the branch auditors do not have access to the overall IT
policy, processes, controls and accounting procedures implemented by the
bank. Moreover, the branch auditors confront following practical issues at fully
computerised branches:
Accounting manual, entries, calculations and framework is built in
computerised accounting systems.
Critical IT and manual controls are centralised at HO level.
Limited access to periodical MIS and exception reports generated by the
system.
Documentation of critical processes performed for accounting and book
keeping (IT and Manual).
Access to primary records and entry level transactions.
Audit sampling.
Hard copies of transactions.
Independent IT Audit at branches, etc.
3.03 The overall review of IT environment and of the computerised
accounting system has to be taken up at central level. The management plays
a more proactive role to ensure that the computerised accounting systems are
working properly and effectively. It is for the central auditor to review whether
Special Considerations in a CIS Environment
the management is performing this role effectively. The roles and
responsibilities of bank, and the branch auditors are enumerated below -.
Role and responsibilities of the Bank
3.04 Considering the importance of IT systems in the preparation and
presentation of financial statement, it is imperative that the bank should share
the detailed information about the following key aspects relating to IT
environment of the bank with the central/branch auditor at regular intervals:
Overall IT Policy, structure and environment of the bank's IT system and
changes/developments, if any, thereto.
Data processing and data interface under various systems.
Data integrity and data security.
Business Continuity Plans and Disaster Recovery Plans.
Accounting manual and critical accounting entries (including month-end
and year-end) and the processes and involvement of IT systems.
Controls over key aspects, such as, account codes and mapping thereof,
use of various account heads including other assets and other liabilities,
asset classification, income recognition, expense booking, overdue
identification, month-end and year-end procedures, valuation and re-
valuation of various items of the financial statements, KYC, ALM, etc.
Controls and recording of various e-banking and internet banking
products & Channels.
Manual processing of key transactions.
MIS reports being generated and the periodicity thereof.
Hard copies being generated and the periodicity thereof.
Process of generating information related to various disclosures in the
financial statements and the involvement of the IT systems.
Major exception reports and the process of generation thereof along with
logic embedded in generation of such reports.
Major IT related issues (including frauds and failures) faced and
resolved/unresolved during the year, such as, data/system corruption,
system break-down, etc., having bearing on the preparation and
presentation of financial statements.
Significant observations of internal auditors, concurrent auditors, system
23
Guidance Note on Audit of Banks (Revised 2019)
auditors, RBI inspection and internal inspection, etc., related to
computerised accounting and overall IT systems.
Customer complaints related to mistakes in transactions (interest
application, balances, etc.).
In order to ensure that the technology deployed to operate the payment
system/s authorised is/are being operated in a safe, secure, sound and
efficient manner and as per the process flow submitted by the bank for
which authorisation has been issued, banks are required to get a System
audit done by a firm of Chartered Accountants / Certified Information
System Auditor. The scope of the System audit would include evaluation
of the hardware structure, operating systems and critical applications,
security and controls in place, including access controls on key
applications, disaster recovery plans, training of personnel managing
systems and applications, documentation, etc. The system auditor is also
required to comment on the deviations, if any, in the processes followed
from the process flow submitted to RBI while seeking authorisation.1
Compliance documentation with RBI IT and Security directives and
guidelines.
Role and responsibilities of branch auditors
3.05 Based on the guidance and information received from the Statutory
Central Auditor / Bank, the branch auditors need to ensure that:
Their roles and responsibilities are clearly understood and implemented.
To the extent possible, data analysis tools are used for better and
effective audit.
Test of controls and substantive checking of sample transactions is
carried out at the branch level and, where considered necessary, the
results are shared with the statutory central auditors.
Data review and analysis through CBS is carried out.
Significant observations having bearing on the true and fair view are
reported to the statutory central auditors.
Any other limitations on audit which are required to be reported to the
central auditors are reported in a timely manner.
1
Refer RBI circular No. DPSS.AD.No./ 1206/02.27.005/2009-2010 dated 7thDecember, 2009
on "System Audit of the Payment Systems operated under the PSS Act, 2007".
24
Special Considerations in a CIS Environment
Audit in a CIS environment
Assessment of Inherent and Control Risks
3.06 The nature of banking operations is such that the auditors may not be
able to reduce audit risk to an acceptably low level by the performance of
substantive procedures alone. This is because of factors such as the following:
The extensive use of IT and EFT systems, which means that much of the
audit evidence is available only in electronic form and is produced by the
bank's own IT systems.
The high volume of transactions processed by banks, which makes
reliance on substantive procedures alone impracticable.
The geographic spread of banks' operations.
Complex trading transactions (Highly inter connected and automated
systems such as card, mobile banking and payment systems).
3.07 In most situations, the auditors' ability to reduce audit risk to an
acceptably low level would be affected by the internal control systems
established by the management that allow the auditors to be able to assess the
level of inherent and control risks as less than high. The auditors obtain sufficient
appropriate audit evidence to assess the level of inherent and control risks.
The auditor's procedures would need to be adapted as the circumstances
warrant and in respect of each account, different procedures may be necessary.
An illustrative checklist on audit considerations in CIS environment is given in
Appendix VII of this Guidance Note.
3.08 The principal objective of the auditor in undertaking an audit in a CIS
environment is to evaluate the effectiveness of controls. In simple words, controls
are those policies and procedures which the organisation implements to minimise
the events and circumstances whose occurrence could result in a loss /
misstatement. There are mainly four types of controls.
A. Deterrent controls - Deterrent Controls are designed to deter people, internal
as well as external, from doing undesirable activities. For example, written
policies including the punitive measures may deter people from doing
undesired activities.
B. Preventive Controls - Preventive Controls prevent the cause of exposure
from occurring or at least minimise the probability of unlawful event taking
place. For example, security controls at various levels like hardware,
25
Guidance Note on Audit of Banks (Revised 2019)
software, application software, database, network, etc.
C. Detective Controls - When a cause of exposure has occurred, detective
controls report its existence in an effort to arrest the damage further or
minimise the extent of the damage. Thus, detective controls limit the losses
if an unlawful event has occurred.
D. Corrective Controls - Corrective Controls are designed to recover from a loss
situation. For example, Business Continuity Planning is a corrective control.
Without corrective controls in place, the bank has risk of loss of business
and other losses due to its inability to recover essential IT based services,
information and other resources after the disaster has taken place.
3.09 The auditor should obtain a preliminary understanding of the IT
environment and various controls put in place by the management, including
entity-level controls and then test and evaluate whether the controls are
operating effectively. The auditor should discuss the methodology adopted by
the bank in implementing controls and their monitoring with the Head of the IT
department and the Head of the audit department. These discussions will
enable the auditor to get a view on the manner in which the bank has
implemented controls. Based on these discussions, the auditor could interact
with the various officials of the bank to determine whether they are sensitised
to the control expectations of the management considering the technology
deployed. If this sensitisation level is low, the auditor may need to perform
more extensive audit procedures.
Security Control Aspects
3.10 The key security control aspects that an auditor needs to address
when undertaking audit in a computerised bank include:
Ensure that authorised, accurate and complete data is made available
for processing.
Ensure that in case of interruption due to power, mechanical or
processing failures, the system restarts without distorting the completion
of the entries and records.
Verify whether "access controls" assigned to the staff-working match with
the responsibilities as per manual. It is important for the auditor to
ensure that access and authorisation rights given to employees are
appropriate.
Verify that segregation of duties is ensured while granting system access
26
Special Considerations in a CIS Environment
to users and that the user activities are monitored by performing an
activities log review.
Verify that changes made in the parameters or user levels are
authenticated.
Verify that charges calculated manually for accounts when function is not
regulated through parameters are properly accounted for and authorised.
Verify that exceptional transaction reports are being authorised and
verified on a daily basis by the concerned officials. It is important for
auditor to understand the nature of exception and its impact on
financials.
Verify that the account master and balance cannot be
modified/amended/altered except by the authorised personnel.
Verify that all the general ledger accounts codes authorised by Head
Office are in existence in the system.
Verify that balance in general ledger tallies with the balance in subsidiary
book.
Credit Risk
3.11 Generally, the bank's credit risk is not increased by the mere fact that
a loan is originated through an e-banking channel. However, the bank should
ensure that additional precautions are in place when originating and approving
loans electronically including assuring management information systems
effectiveness by preparing a track of the performance of portfolios originated
through e-banking channels. The following aspects of on-line loan origination
and approval tend to make risk management of the lending process more
challenging:
Verifying the customer's ID for on-line credit applications and executing
an enforceable contract;
Monitoring and controlling the growth, pricing, and on-going credit quality
of loans originated through e-banking channels;
Monitoring and oversight of third-parties operations doing business as
agents or on behalf of the banks;
Valuing collateral and perfecting liens over a potentially wider geographic
area; and
Collecting loans from individuals over a potentially wider geographic
area.
If not properly managed, these aspects can significantly increase credit risk.
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Guidance Note on Audit of Banks (Revised 2019)
Compliance/ Legal Risk
3.12 Compliance and legal issues arise out of the rapid growth in usage of e-
banking services and the differences between the electronic and paper-based
processes. E-banking is a new delivery channel where the laws and rules
governing the electronic delivery of certain financial products or services may be
ambiguous or still evolving. Specific regulatory and legal challenges include:
Uncertainty over the legal jurisdictions applicable to the transaction
taking place through e-banking;
Delivery of credit and deposit related disclosures/notices as required by
law or regulation;
Retention of required compliance documentation for on-line advertising,
applications, statements, disclosures, notices; and
Establishment of legally binding electronic agreements.
3.13 Banks offering e-banking services, both informational and transactional,
assume a higher level of compliance risk because of the changing nature of the
technology, the speed at which errors can be replicated, and the frequency of
regulatory changes to address e-banking issues. The potential for violations is
further heightened by the need to ensure consistency between paper and
electronic advertisements, disclosures and notices.
Reputational Risk
3.14 The rise of the sophisticated cyber-crime has become one of the fastest
growing security and reputational risks to banks. The cyber-crime landscape
features malware exploits that can routinely evade traditional security controls.
The reactive attack and penetration approaches of the past may no longer be
sufficient to deal effectively with that level of ingenuity of cyber-attacks and are
being replaced with new forms of cyber intelligence capable of enhancing
traditional security programs. Adding a layer of complexity to the issue is the rise
of social networking, online communications, and online financial transactions.
The bank has a significant role to play in identifying and addressing this risk
thereby safeguarding its reputation and instilling the confidence in its customers.
Audit through CBS
3.15 With the adoption of CBS by banks, amendment in the conventional
audit methodology has also become inevitable.
28
Special Considerations in a CIS Environment
What is CBS?
3.16 The core banking system is the set of basic software components that
manage the services provided by a bank to its customers through its branches
(branch network). The bank's customers can make their transactions from any
branch, ATM, Service Outlets, Internet, Phone at their disposal. The CBS is
based on Service Oriented Architecture (SOA). It helps banks to reduce risk that
can result from manual data entry and out-of date information. It also helps banks
to improve Service Delivery quality and time to its customer. The software is
accessed from different branches of bank via communication lines like
telephones, satellite, internet etc.
3.17 Core Banking Solution [CBS] works on a concept of Centralized
Database and Processing. Transactions take place at various geographical
locations which get recorded and processed at a Centralized Server. Updation of
Database is on Real Time Basis. Due to the Centralization of Transaction
Processing, issue of Out of Date Information is eliminated. All the users
connected to CBS will be able to get upto date information. CBS also enhances
quality of Reporting and strengthens Access Control.
3.18 Under CBS data is stored in centralized servers at Data Centre. This
effectively means that all operations at the connected branches, back offices are
carried out through servers at Data Centre including transactions through other
delivery channels like ATMs, Internet Banking, Phone Banking.
3.19 Under CBS, the branches, back offices are defined as SOL (i.e. Service
Outlets) where each SOL functions as a service window. The CBS is capable of
processing any transaction from any branch location connected to CBS. It can be
equated with single window operations at airline counters or railway reservation
counters wherein all the services can be obtained at one place. Hence, under
CBS customer is now a customer of the bank and not merely a customer of a
branch of the Bank. This has facilitated Any-where, Anytime Banking
convenience for the customer.
3.20 From Bank's perspective, control over the application and processes
has been entrusted at Data Center Level. In addition to it CBS also makes
available effective MIS on real-time basis. It enables generation of all periodical
returns centrally.
29
Guidance Note on Audit of Banks (Revised 2019)
3.21 There are various CBS developed by various software companies are
available in the market. Few widely used CBS are a) FINACLE, b) BaNCS and c)
FlexCube.
3.22 Various other Appendices such as Overview of various CBS and basic
concepts, List of important Menu commands in CBS, Illustrative Checklist on
Audit Activity through CBS are given in Appendices VIII to X of the Guidance
Note.
30
PART - III
III-1
Advances-Agriculture
Introduction
1.01 Indian Agriculture has always been the backbone of Indian economy
despite sustained progress in industrial and service(s) sector. It still contributes
around 18% of the GVA (Gross Value Added) and provides employment
opportunities to around 50% of the population. Indian agriculture has been
source of raw materials to many of our leading industries like cotton, jute textile
industries, sugar, flour mills, vanaspati, oil mills etc. Besides, many industries like
handloom weaving, rice-dehusking etc. depend indirectly on the agriculture.
Rapid growth in agriculture is essential not only for self-reliance but also to earn
valuable foreign exchange.
1.02 The agriculture sector in India is pre-dominantly dependent on Monsoon
rains which more often than not tend to be of erratic nature. Hence, agricultural
credit is considered as one of the most basic input for conducting all agricultural
development programmes. In India there is an immense need for proper
agricultural credit as the economic condition of Indian farmers generally is of
subsistence. From the very beginning the prime source of agricultural credit in
India has been money lenders as many of the commercial banks were generally
discouraged by inherent characteristics of Indian agriculture like uncertain
character of Indian agriculture, small amounts of individual loans, inadequate
security for loans, difficulty in recovery of loans from farmers and lack of business
experience of working with rural sector.
1.03 With a view to ensure wider spread of agricultural credit, the
Government adopted the institutional credit approach through various agencies
like co-operatives, commercial banks, regional rural banks etc. to provide
adequate credit to farmers, at a cheaper rate of interest. The long term and short
term credit needs of these institutions are also being met by National Bank for
Agricultural and Rural Development (NABARD). It is the evolution of agricultural
finance. It has the objective of promoting the health and the strength of the credit
institutions which are in the forefront of the delivery system namely, cooperatives,
commercial banks and regional rural bank. It is, in brief, an institution for the
Guidance Note on Audit of Banks (Revised 2019)
purpose of refinance; with the complementary work of directing, inspecting and
supervising the credit- flows for agricultural and rural development.
1.04 The evolution of institutional credit to agriculture could be broadly
classified into four distinct phases
i. 1904-1969 (predominance of co-operatives and setting up of RBI);
ii. 1969-1975 [nationalization of commercial banks and setting up of Regional
Rural Banks (RRBs)];
iii. 1975 - 1990 (setting up of NABARD); and
From 1991 onwards (financial sector reforms): The genesis of institutional
involvement in the sphere of agricultural credit could be traced back to the
enactment of the Cooperative Societies Act in 1904. The establishment of
the RBI in 1935 reinforced the process of institutional development for
agricultural credit.
1.05 Government has increasingly begun to tap institutional finance from
banks and other term lending institutions for financing various developmental
programmes in the State in view of the need to supplement plan financing. Banks
in the State have also played a pivotal role in this regard. However, credit should
be utilized in prudent manner to maximize returns and spread the benefit over
wider sections of the population. Successful implementation of socioeconomic
developmental programmes calls for effective co-ordination between financial
agencies and government departments. It also helps in improvising efficiency of
resource allocation & identifying infrastructural gaps.
1.06 The State Level Bankers' Committee (`SLBC'), constituted by the
Reserve Bank of India under the Lead Bank Scheme periodically takes up the
review performance and monitors progress under special schemes. At the district
level the District Consultative Committee with the Chief Executive Officer of Zilla
Panchayat as chairperson and representatives of financial institutions and Heads
of Government departments at the district level as members' monitors the
implementation of government sponsored schemes & Service Area Credit Plans.
At the block level, Block Level Bankers' Committee chaired by Lead District
Manager with bank managers and departmental heads of government at block
level as members periodically reviews the implementation of government
sponsored schemes & Service Area Credit Plans and sorts out problems
encountered in the implementation of various programmes. In order to select &
prioritise the works for loan assistance from National Bank for Agriculture and
Rural Development (NABARD) under Rural Infrastructure Development Fund
32
Advances-Agriculture
(RIDF) Scheme, launched in 1995-96, a Cabinet Sub-Committee on RIDF has
been constituted under the chairmanship of the Minister for Public Works. There
is also a High Power Committee chaired by the Additional Chief Secretary and
Development Commissioner for reviewing the implementation of RIDF projects.
These policy measures have resulted in the increase in the share of institutional
credit of the rural households.
Role of Commercial Banks (CBs) in providing agricultural
credit
1.07 Commercial banks are guided by priority sector lending policy of
providing credit to various deserving sectors/sections including agriculture and
allied activities.
1.08 Commercial banks entered the field of agricultural credit in a major way
following their nationalisation in 1969. Growth in commercial bank credit to
agriculture, which was lower than the growth in aggregate bank credit during the
1990, picked up sharply in the first half of the 2005 and largely coincided with the
growth in aggregate bank credit. There was a downturn in the growth in
commercial bank credit to agriculture after 2005-06, when growth in aggregate
bank credit also slowed down. Previously Commercial Banks (CBs) were
confined only to urban areas serving mainly to trade, commerce and industry.
Their role in rural credit was abysmally low i.e., 0.9 per cent in 1951-52 and 0.7
per cent in 1961-62. The insignificant participation of CBs in rural lending was
explained by the risky nature of agriculture due to its heavy dependence on
monsoon, unorganized nature and subsistence approach. In the year 1990-91
share of commercial banks increased up to 54 percent. At present, they are the
largest source of institutional credit to agriculture.
Priority Sector Lending (PSL)
1.09 With a view to regulate and encourage the flow of agricultural credit by
all scheduled Commercial Banks, the RBI from time to time, issues a number of
guidelines /instructions/directives to banks on Priority Sector Lending.
1.10 Priority Sector Lending programme has been an integral part of the
banking policy in India. It is a major public policy intervention through which credit
is directed to the sectors of national priorities critical for both employment and
equity. The Priority Sector Lending programme of India is one among the longest
serving direct lending programmes in the world. This scheme is intended to give
loans to the important sectors of the economy (agriculture, small scale industries
etc.) in such a way to ensure maximum credit flow to the last man in the last
village of the country through a strong banking network. The origin of the PSL
33
Guidance Note on Audit of Banks (Revised 2019)
programme can be traced back to the Credit Policy for 1967-68, when public
sector banks were advised to increase their involvement in financing of certain
sectors identified as priority sectors in line with the national economic policy.
Priority sector lending in its present form was introduced in 1980, when it was
also made applicable to private sector banks and a sub-target was stipulated for
lending to the "weaker" sections of the society within the priority sector.
Meaning Priority Sector & Priority sector advances
1.11 Priority sector refers to those sectors of the economy which may not get
timely and adequate credit in the absence of this special dispensation. Priority
sector advances are small value loans to farmers for agriculture and allied
activities, micro and small enterprises, poor people for housing, students for
education and other low income groups and weaker sections.
1.12 In terms of RBI Master Direction- RBI/ FIDD/ 2016-17/ 33 Master
Direction FIDD.CO.Plan.1/04.09.01/2016-17 "Master Direction-Priority Sector
Lending- Targets and Classification" dated July 7, 2016 (updated December 04,
2018) the categories under priority sector are as follows:
(i) Agriculture
(ii) Micro, Small and Medium Enterprises
(iii) Export Credit
(iv) Education
(v) Housing
(vi) Social Infrastructure
(vii) Renewable Energy
(viii) Others
1.13 The targets and sub-targets for agriculture set under priority sector
lending for all scheduled commercial banks operating in India are furnished
below for domestic scheduled commercial banks and foreign banks with 20
branches and above:
Agriculture 18 percent of Adjusted Net Bank Credit (ANBC) or Credit
Equivalent Amount of Off-Balance Sheet Exposure,
whichever is higher.
Within the 18 percent target for agriculture, a target of 8
percent of ANBC or Credit Equivalent Amount of Off-Balance
Sheet Exposure, whichever is higher is prescribed for Small
and Marginal Farmers. Additionally, domestic banks are
directed to ensure that the overall lending to non-corporate
farmers does not fall below the system-wide average of the
34
Advances-Agriculture
last three years achievement. All efforts should be
maintained to reach the level of 13.5 percent direct lending
to the beneficiaries who earlier constituted the direct
agriculture sector. The applicable system wide average
figure for computing achievement under priority sector
lending will be notified every year. For FY 2018-19, the
applicable system wide average figure is 11.99 percent.
Foreign banks with less than 20 branches have to achieve
the Agriculture Target of 40% in phased wise manner by
2019-20 and the target for FY: 2018-19 is 38%.
Guidelines issued by RBI for Priority Sector lendings by
Small Finance Banks are different and these should be
noted separately.
Computation of Adjusted Net Bank Credit (ANBC)
1.14
Bank Credit in India [As prescribed in item No.VI of Form `A' I
under Section 42 (2) of the RBI Act, 1934].
Bills Rediscounted with RBI and other approved Financial II
Institutions
Net Bank Credit (NBC)* III (I - II)
Bonds/debentures in Non-SLR categories under HTM category IV
+ other investments eligible to be treated as priority sector +
Outstanding Deposits under RIDF and other eligible funds with
NABARD, NHB, SIDBI and MUDRA Ltd. on account of priority
sector shortfall + outstanding PSLCs
Eligible amount for exemptions on issuance of long-term bonds V
for infrastructure and affordable housing as per circular
DBOD.BP.BC.No.25/08.12.014/2014-15 dated July 15, 2014.
Eligible advances extended in India against the incremental VI
FCNR (B)/NRE deposits, qualifying for exemption from
CRR/SLR requirements.
ANBC III+IV-V-VI
* For the purpose of priority sector computation only. Banks should not deduct /
net any amount like provisions, accrued interest, etc. from NBC
A. The computation of priority sector targets/sub-targets achievement will be
based on the ANBC or Credit Equivalent Amount of Off-Balance Sheet
35
Guidance Note on Audit of Banks (Revised 2019)
Exposures, whichever is higher, as on the corresponding date of the
preceding year.
B. For the purpose of priority sector lending, ANBC denotes the outstanding
Bank Credit in India [As prescribed in item No.VI of Form `A' under Section
42 (2) of the RBI Act, 1934] minus bills rediscounted with RBI and other
approved Financial Institutions plus permitted non SLR bonds/debentures
under Held to Maturity (HTM) category plus other investments eligible to be
treated as part of priority sector lending (e.g. investments in securitised
assets).
C. The outstanding deposits under RIDF and other funds with NABARD, NHB,
SIDBI and MUDRA Ltd. in lieu of non-achievement of priority sector lending
targets/sub-targets will form part of ANBC.
D. Advances extended in India against the incremental FCNR (B)/NRE
deposits, qualifying for exemption from CRR/SLR requirements, as per the
Reserve Bank's circulars DBOD.No.Ret.BC.36/12.01.001/2013-14 dated
August 14, 2013 read with DBOD.No.Ret.BC.93/12.01.001/2013-14 dated
January 31, 2014 and DBOD mailbox clarification issued on February 6,
2014 will be excluded from the ANBC for computation of priority sector
lending targets, till their repayment.
E. The eligible amount for exemption on account of issuance of long-term
bonds for infrastructure and affordable housing as per Reserve Bank's
circular DBOD.BP.BC.No.25/08.12.014/2014-15 dated July 15, 2014 will
also be excluded from the ANBC for computation of priority sector lending
targets.
F. For the purpose of calculation of Credit Equivalent Amount of Off-Balance
Sheet Exposures, banks may be guided by the Master Circular on Exposure
Norms issued by the Department of Banking Regulation.
G. If a banks opts to subtract prudential write off at Corporate/Head Office level
while reporting Bank Credit as above, bank credit to priority sector and all
other sub-sectors so written off should also be subtracted category wise
from priority sector and sub-target achievement.
Agriculture Credit
1.15 Hitherto the agriculture advances were bifurcated into direct / indirect
agriculture advances, however, in terms of revised guidelines issued by
Reserve Bank of India (RBI-2014-15/573 FIDD.CO.Plan.BC.54/04.09.01/2014-
15 dated April 23, 2015), the present distinction has been dispensed with and
the lending to agriculture sector has been defined to include (i) Farm Credit
36
Advances-Agriculture
(which will include short-term crop loans and medium/long-term credit to
farmers) (ii) Agriculture Infrastructure and (iii) Ancillary Activities.
1.16 A list of eligible activities under the three sub-categories is indicated
below:
(i) Farm Credit
A. Loans to individual farmers [including Self Help Groups (SHGs) or Joint
Liability Groups (JLGs), i.e. groups of individual farmers, provided banks
maintain disaggregated data of such loans] and Proprietorship firms of
farmers, directly engaged in Agriculture and Allied Activities, viz., dairy,
fishery, animal husbandry, poultry, bee-keeping and sericulture. This will
include:
a. Crop loans to farmers, which will include traditional/non-traditional
plantations and horticulture, and, loans for allied activities.
b. Medium and long-term loans to farmers for agriculture and allied
activities. (e.g. purchase of agricultural implements and machinery,
loans for irrigation and other developmental activities undertaken in the
farm, and developmental loans for allied activities.)
c. Loans to farmers for pre and post-harvest activities, viz., spraying,
weeding, harvesting, sorting, grading and transporting of their own farm
produce.
d. Loans to farmers up to Rs. 50 lakh against pledge/hypothecation of
agricultural produce (including warehouse receipts) for a period not
exceeding 12 months.
e. Loans to distressed farmers indebted to non-institutional lenders.
f. Loans to farmers under the Kisan Credit Card Scheme.
g. Loans to small and marginal farmers for purchase of land for agricultural
purposes.
B. Loans to corporate farmers, farmers' producer organizations/companies of
individual farmers, partnership firms and co-operatives of farmers directly
engaged in Agriculture and Allied Activities, viz., dairy, fishery, animal
husbandry, poultry, bee-keeping and sericulture up to an aggregate limit of
Rs. 2 crore per borrower.
This will include:
a. Crop loans to farmers which will include traditional/non-traditional
plantations and horticulture, and, loans for allied activities.
37
Guidance Note on Audit of Banks (Revised 2019)
b. Medium and long-term loans to farmers for agriculture and allied
activities. (e.g. purchase of agricultural implements and machinery,
loans for irrigation and other developmental activities undertaken in the
farm, and developmental loans for allied activities.)
c. Loans to farmers for pre and post-harvest activities, viz., spraying,
weeding, harvesting, sorting, grading and transporting of their own farm
produce.
d. Loans up to Rs. 50 lakh against pledge/hypothecation of agricultural
produce (including warehouse receipts) for a period not exceeding 12
months.
(ii) Agriculture Infrastructure
a. Loans for construction of storage facilities (warehouses, market yards,
godowns and silos) including cold storage units/ cold storage chains
designed to store agriculture produce/products, irrespective of their location.
b. Soil conservation and watershed development.
c. Plant tissue culture and agri-biotechnology, seed production, production of
bio-pesticides, bio-fertilizer, and vermi composting.
For the above loans, an aggregate sanctioned limit of Rs. 100 crore per borrower
from the banking system, will apply.
(iii) Ancillary activities
a. Loans up to Rs. 5 crore to co-operative societies of farmers for disposing of
the produce of members.
b. Loans for setting up of Agriclinics and Agribusiness Centres.
c. Loans for Food and Agro-processing up to an aggregate sanctioned limit of
Rs. 100 crore per borrower from the banking system.
d. Loans to Custom Service Units managed by individuals, institutions or
organizations who maintain a fleet of tractors, bulldozers, well-boring
equipment, threshers, combines, etc., and undertake the farm work for
farmers on contract basis.
e. Bank loans to Primary Agricultural Credit Societies (PACS), Farmers'
Service Societies (FSS) and Large-sized Adivasi Multi-Purpose Societies
(LAMPS) for on-lending to agriculture.
f. Loans sanctioned by banks to MFIs for on-lending to agriculture sector as
per the conditions specified in paragraph IX of the aforesaid Master
Directions.
38
Advances-Agriculture
g. Outstanding deposits under RIDF and other eligible funds with NABARD on
account of priority sector shortfall.
1.17 For the purpose of computation of achievement of the sub-target, Small
& Marginal Farmers will include the following:-
a. Farmers with landholding of up to 1 hectare (Marginal Farmers). Farmers
with a landholding of more than 1 hectare and up to 2 hectares (Small
Farmers).
b. Landless agricultural labourers, tenant farmers, oral lessees and share-
croppers, whose share of landholding is within the limits prescribed for small
and marginal farmers.
c. Loans to Self Help Groups (SHGs) or Joint Liability Groups (JLGs), i.e.
groups of individuals Small and Marginal farmers directly engaged in
Agriculture and Allied Activities, provided banks maintain disaggregated data
of such loans.
d. Loans to farmers' producer companies of individual farmers, and co-
operatives of farmers directly engaged in Agriculture and Allied Activities,
where the membership of Small and Marginal Farmers is not less than 75
percent by number and whose land-holding share is also not less than 75
percent of the total land-holding.
1.18 Kisan Credit Card (KCC)
a. In terms of RBI Cir. No. RPCD:F.S.D. BC No. 77/05/09/2011-12 dated 11th
May, 2012 revised scheme for issue of Kisan Credit card was introduced by
RBI which was subsequently modified vide various circulars. Latest Master
cir. No. RBI/2018-19/10 FIDD.CO.FSD.BC. No. 6/05.05.010/2018-19 dated
July 04, 2018.
b. The scheme was simple and hassle free for both the farmers and bankers.
The scheme was aimed at providing adequate & timely credit support under
single window to the farmers for their cultivation and other needs as
indicated below:
Short term credit limits.
i. To meet the short-term credit requirement for cultivation of crops.
ii. Post-harvest expenses.
iii. Produce marketing loan.
iv. Consumption requirement of farmer household.
39
Guidance Note on Audit of Banks (Revised 2019)
v. Working capital for maintenance of farm assets & activities allied to
agriculture like dairy, inland fishery etc.
Long term Credit Limit:
i. Investment credit requirement for agriculture & allied activities.
c. It may be noted that KCC is not a type of loan, but is a channel for granting
either short term or long term agricultural finance.
1.19 Interest Application
a. Unlike normal loans, the interest on agricultural advances is not charged at
monthly rests but is charged normally at half yearly or annual rests.
b. Compounding of Interest is generally not permitted in respect of an
Agricultural advance, unless it turns out to be a non-performing advance.
c. The RBI vide its circular no.: DBOD No. Dir. BC. 25/13.03.00/2002-03 dated
September 19, 2002 had advised the banks that instructions regarding
charging of interest on monthly rests shall not be applicable to agricultural
advances and banks shall continue to follow the existing practice of
charging/compounding of interest on agricultural advances linked to crop
seasons.
Examples of Interest application according to crop seasons and for other
activities:
Crop Season Kharif Rabi Horticulture
Disbursement Period April 01 to Sept 30 Oct 01 to March
31
Interest Application Annual Annual Annual
Interest Application 31st March 30th June 31st March
date
Compounding Annual Annual Annual
Due Date 31st March 30th June One year after
first
disbursement
every year.
Compounding from After 31st March After 30th June After end of
date year (to be
calculated
from date of
first
disbursement
every year)
40
Advances-Agriculture
Penal Interest If overdue, after If overdue, after If overdue,
31st March 30th June from the due
date
Allied Activities
Dairy, Poultry Goat Rearing, Piggery
Repayment Quarterly Half Yearly / Yearly
Interest Application Quarterly Half Yearly / Yearly
Interest application date Quarter end Half Year end / Year end
Compounding Frequency Quarterly Half Yearly / Yearly
Compounding from date After Quarter end After Half Year end / Year end
Penal Interest If overdue, after If overdue after half year /year
Quarter end end.
Interest Subvention
1.20 Public / Private Sector Scheduled Commercial Banks (in respect of
loans given by the rural and semi urban branches) are eligible under the scheme.
Interest subvention of 2% p.a. is allowed on their own funds used for short term
crop loans upto Rs.3.00 lakh per farmer. Short term credit made available at 7%
p.a. to farmers is considered for interest subvention. This is calculated on the
crop loan amount from the date of its disbursement/ drawal up to the date of
actual repayment of the crop loan by the farmer or up to the due date of the loan
fixed by the banks, whichever is earlier, subject to a maximum period of one
year.
From 2011-12, additional interest subvention of 3% to those farmers, who repay
their short term crop loans promptly and on or before the due date. Farmers, who
promptly repay their crop loans as per the repayment schedule fixed by the
banks, are offered loans at an effective interest rate of 4% p.a.
1.21 The RBI vide its circular no.: RBI/2017-18/190 FIDD.CO.FSD.BC.No.21/
05.04.001/2017-18 dated June 07, 2018 has specified continuation of the interest
subvention scheme for 2018-19 on the terms and conditions approved for the
scheme for 2017-18.
Further, As notified by the Government of India (Subject to inclusion in the
Interest Subvention Scheme on short term crop loans) from time to time, to
provide relief to farmers availing short term crop loans and affected by a natural
calamity, an interest subvention of 2 percent per annum shall be made available
to banks for the first year on the restructured loan amount. Such restructured
loans shall attract normal rate of interest from the second year onwards.
41
Guidance Note on Audit of Banks (Revised 2019)
Interest subvention scheme to post harvest loans
1.22 Scheme extended to small and marginal farmers (having Kisan Credit
Card) for a further period upto six months, post-harvest, against negotiable
warehouse receipt for keeping their produce in warehouses. To discourage
distress sale by farmers and to encourage them to store their produce in
warehouses against warehouse receipts.
1.23 Auditors have to submit certificate of Interest Subvention alongwith
annual accounts of the branch audited by them.
Audit Procedure
1. Obtain written representation from the management about the scheme and
its applicability.
2. Obtain list of eligible borrowers with outstanding balance.
3. Interest on the loan account has been properly charged.
4. The subvention is computed properly for the eligible year and credited in
respective borrower account.
5. Inquire about any rejection made in earlier year claims and reasons thereof.
As per RBI circular, the auditor need to certify the correctness of the claim, so the
substantive testing needs to be carried out for examinations.
Non-achievement of priority sector targets
1.24 Scheduled Commercial Banks having any shortfall in lending to priority
sector shall be allocated amounts for contribution to the Rural Infrastructure
Development Fund (RIDF) established with NABARD and other Funds with
NABARD/NHB/SIDBI/ MUDRA Ltd., as decided by the Reserve Bank from time
to time. The achievement will be arrived at the end of financial year based on the
average of priority sector target /sub-target achievement as at the end of each
quarter.
1.25 While computing priority sector target achievement, shortfall / excess
lending for each quarter will be monitored separately. A simple average of all
quarters will be arrived at and considered for computation of overall shortfall /
excess at the end of the year. The same method will be followed for calculating
the achievement of priority sector sub-targets. An Illustrative example is given in
Annex A of Master Directions Priority Sector lending Target and Classification
issued dated July 07, 2016 (Updated as on December 04, 2018).
1.26 The interest rates on banks' contribution to RIDF or any other Funds,
tenure of deposits, etc. shall be fixed by Reserve Bank of India from time to time.
42
Advances-Agriculture
1.27 The misclassifications reported by the Reserve Bank's Department of
Banking Supervision would be adjusted/ reduced from the achievement of that
year, to which the amount of declassification/ misclassification pertains, for
allocation to various funds in subsequent years.
1.28 Non-achievement of priority sector targets and sub-targets will be taken
into account while granting regulatory clearances/approvals for various purposes.
Term wise Categories of Agriculture Credit
1.29 The credit needs of cultivators fall into three broad categories:
i. Crop Loan or Short Term - mainly for financing current expenditure in
connection with the raising of crops.
ii. Medium Term - for meeting outlay relating to the replacement and
maintenance of assets and for capital investment designed to increase the
output from land. Such loans are generally repayable in 3 to 5 years. They
are sanctioned for purposes such as deepening of wells, sinking of new
wells, installation of pump sets, purchase of agricultural machinery or a pair
of bullocks, etc.
iii. Long Term - for capital investments in agriculture such as sinking of new
wells, construction of tube wells, land levelling, bunding, terracing, purchase
of tractors, power tillers and other costly machinery, electrical motors,
purchase of land, etc. Such loans are generally repayable over a period of 5
to 15 years and in exceptional cases in 20 years.
As per the extant RBI guidelines, "long duration" crops would be crops with crop
season longer than one year and crops, which are not "long duration" crops
would be treated as "short duration" crops. The crop season for each crop, which
means the period up to harvesting of the crops raised, would be as determined
by the State Level Bankers' Committee in each State depending upon the
duration of crops raised by an agriculturist.
State Level Banker's Committee (SLBC)
1.30 The Agriculture finance is supervised and monitor by State Level
Banker's Committee (`SLBC') and its decisions are implemented by all banking
sector having branches in the state. Every state has its own SLBC and guidelines
have been issued to banks to develop agricultural finance.
1.31 The SLBC is an inter-institutional forum for co-ordination and joint
implementation of development programmes and policies by all the financial
43
Guidance Note on Audit of Banks (Revised 2019)
institutions operating in a state. Although SLBC is envisaged as a bankers'
forum, Government officials are also included. The Lead Bank designated as
'Convener Bank'. The State Level Banker's Committee meets once a quarter.
1.32 The SLBC of the respective state decides the crop season for each
crop, which effectively means the period upto harvesting of the crop raised and
the banks of the respective state have to adhere with the crop season as decided
by the SLBC of that respective state. Hence, practically it may occur that same
crop may have different harvesting season in different states as decided by the
respective SLBC of those states. In these cases the auditor needs to verify
whether the Banks have the requisite mechanism to map the crop season(s) vis-
à-vis the crop season(s) as defined by the SLBC of each state as any
discrepancies may have a direct impact on identification of NPAs.
1.33 Auditors are advised to refer to the guidelines issued by SLBC of the
state wherein the branch under the audit is located.
1.34 Few examples of Harvesting Season as defined by SLBC in different
states in various years are as follows:
A. SLBC Rajasthan
As per guidelines2, the SLBC has to determine crop season for each crop so as
to decide the NPA norms to be followed in the State for asset classification under
Agriculture Advance. Based on the sowing, harvesting period prevailing in the
State & looking to the crop pattern, Agro Climatic condition, the Crop season for
Kharif & Rabi season was proposed as under, which was unanimously approved
by the house.
Kharif Crop - April Dec - Due date of repayment may be fixed 31st March
Rabi Crop - Oct April - Due date of repayment may be fixed 30th June
B. SLBC Gujarat
Short duration Mono cropping farmers:
PARTICULARS KHARIF SEASON RABI / SUMMER SEASON
Year of sanction of Loan 2004-05 2004-05
Month of sanction April 04 to June 04 October 04 to November 04
Season start June -July 04 November-December 04
Harvest Time October-November February-March 05
04
2 Excerpts from minutes of 108th meeting of SLBC Rajasthan held on 16.03.2011.
44
Advances-Agriculture
Due date for Repayment 31.03.2005 30.06.2005
1st crop season June 05 to December October 05 to March 06
05
2nd crop season June 06 to October 06 to March 07
December 06
Short duration Double cropping farmers:
PARTICULARS KHARIF SEASON RABI / SUMMER SEASON
Year of sanction of Loan 2004-05 2004-05
Month of sanction April - June 04 October - November 04
Season start June -July 04 November-December 04
October-November February-March 04
04
Due date for Repayment 31.03.2005 30.06.2005
1st crop season October 04 - March June 05 - December 05
05
2nd crop season June 05 - December October 05 - March 06
05
Two Crops seasons is considered as under:
If a farmer is growing Crops only in Kharif season and land remains fallow
during the rest of the year, two crop seasons will spread over two years.
Similar is the case if crops are grown only in Rabi season by a farmer. In this
case, repayment date will be fixed once in a year.
If the farmer is growing Kharif as well as Rabi crops, two crop seasons will
spread over one year period. There will be two repayment dates during one
year period.
(Excerpts from minutes of 119th State Level Bankers' Committee Meeting held on
December 22, 2008 at Dena bank)
Security for Crop Loan
1.35 An essential feature of the crop loan system is that a cultivator's
eligibility for loan and its size are determined not with reference to the value of
the land or any other tangible security that he is in position to offer but on the
basis of the size of the land holding he cultivates and the crops he grows. The
repayment of loans is expected out of the sale proceeds of the crops raised. A
distinction has to be drawn between:
i. loan to a cultivator and loan for agricultural production;
45
Guidance Note on Audit of Banks (Revised 2019)
ii. Loans given without reference to outlays on the crops and repaying capacity
generated thereby will fall in the former category; whereas, crop loans fall in
the latter category, as they are essentially need based and production-
oriented (and not security oriented).
1.36 While the security offered will not be the basis for a crop loan, it does
not mean that the security aspect should be completely done away with. Security
is necessary to provide against the possibility of a loan becoming unrealisable.
Many Cooperative Societies Acts and Banks provide for a charge on the
"standing crops as security" for advances made for agricultural purposes. If the
crops grown are really to constitute the security for advances, it is necessary to
ensure that the repayment of loan is made out of the sale proceeds of crops
grown. However, partly because of the ineffective linking of credit with marketing
and partly because of inadequate and inefficient supervision, the credit agency
has little or no control over the sale of crops. Further, it is also difficult to enforce
the charge on crops in spite of the provision therefor in the Cooperative Societies
Acts.
1.37 Mortgage of land would appear to be a sound security from the point of
view of the lending agency. But insistence on such security is likely to create
difficulties to the borrowers. Firstly, the procedure and formalities which an
execution of mortgage involves are generally time consuming and elaborate.
Secondly, it may handicap a borrower in raising medium or long term loans for
which mortgage of land is normally insisted upon. Thirdly, a large number of
cultivators would be deprived of loans because of their inability to provide
mortgage security e.g., tenants, oral lessees, etc.
NPA Norms for Agriculture Advances
1.38 NPA classification of Agricultural Loans is linked with:
i. Nature of crop.
ii. Duration of crop / crop season.
Applying a single form for NPA & setting up the system parameters in CBS is
difficult. System is required to be configured to capture relevant SLBC guidelines
for crop seasons & classification of crops and also implementation of relaxations
due to natural calamities.
1.39 A loan granted for short duration crops will be treated as NPA, if the
instalment of principal or interest thereon remains overdue for two crop seasons
and, a loan granted for long duration crops will be treated as NPA, if the
instalment of principal or interest thereon remains overdue for one crop season.
Depending upon the duration of crops raised by an agriculturist, the above
46
Advances-Agriculture
NPA norms would also be made applicable to agricultural term loans availed by
him.
1.40 These NPA norms should be made applicable only to Farm Credit
extended to agricultural activities as listed at paragraph 6.1 of the Master
Direction on Priority Sector Lending Targets and Classification RBI/FIDD/2016-
17/33 Master Direction FIDD.CO.Plan.1/04.09.01/2016-17 dated July 07, 2016
(updated December 04, 2018). An extract of the list of these items is furnished in
the Annex 2 of the Master Circular Prudential Norms on Income Recognition,
Asset Classification and Provisioning pertaining to Advances.
1.41 In respect of agricultural loans, other than those specified in the
Annex-2 and term loans given to non-agriculturists, identification of NPAs
would be done on the same basis as non-agricultural advances, which, at
present, is the 90 days delinquency norm.
1.42 It is important to note that the duration of crops / crop season and the
overdue period for NPA's would be determined by the State Level Bankers'
Committee (`SLBC') of each state as per the extant guidelines of RBI. Further,
based on the harvesting period as noted by the SLBC would be taken into
consideration while identification of accounts as NPA's.
Following in an example to elaborate this point further:
C. Maharashtra SLBC
1.43 Based on the resolution and minutes of 71st steering committee
meeting of SLBC held on Sep 6, 2004 following guidelines have been framed
for identification of NPA's in respect of Farm credit (erstwhile Direct Agricultural
Advances) and come into effect from Sep 30, 2004.
It was decided that in Maharashtra State except sugarcane and banana, all
other crops would be reckoned as Short duration crops.
A. Short Duration Crops:
1. Kharif / Rabi crops: A loan granted for Kharif / Rabi crop will be
treated as NPA if the instalment of principal or interest thereon
remains overdue for a period of 21 months from repayment due date.
2. Horticulture Crops: A loan granted for Horticultural crop will be treated
as NPA if the instalment of principal or interest thereon remains
overdue for a period of 24 months from repayment due date.
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Guidance Note on Audit of Banks (Revised 2019)
B. Long Duration Crops:
1. Perennial Crop Sugarcane (Adsali): A loan granted for sugarcane
(Adsali) will be treated as NPA if the instalment of principal or interest
remains overdue for a period of 18 months from repayment due date.
2. Perennial Crop Banana (Mrig Bahar): A loan granted for banana crop
will be treated as NPA if the instalment of principal or interest remains
overdue for a period of 21 months from repayment due date.
3. Repayment due date means the date fixed at the time of sanction of
loan for repayment of crop loan or instalments/interest of term loan.
C. Agricultural term Loan:
Depending upon the duration of crops raised (e.g., short duration, long
duration or both), by an agriculturalist, respective overdue period as
applicable to the crops mentioned above in (A) and (B) will be applicable
for identification of NPAs in agricultural term loans availed by the borrower.
While identifying NPAs following points may be noted:
1.44
a. Term loan/s availed with crop loan/s: Where an agriculturist has availed
loans both for short duration as well as long duration crops along with
Term loan/s, such term loan/s will be classified as NPA if either of the
loans for short duration or long duration crops is classified as NPA.
Example 1: An agriculturist avails following loans
i) Crop loan for kharif crop (a short duration crop) is availed on 1.6.2004
for which repayment due date prescribed is 31.03.2005.
ii) Crop loan for Adsali sugarcane (a long duration crop) is availed on
1.7.2004 for which repayment due date prescribed is 30.06.2006.
iii) A term loan for deepening of well is availed on 01.05.2004 for which
first repayment instalment is due on 30.06.2006.
If crop loan for Kharif crop remains overdue up to 31.12.2006 (i.e. overdue
for 21 months after repayment due date of 31.03.2005) this crop loan
along with the crop loan for sugarcane and term loan for deepening of well,
will be classified as NPA with effect from 31.12.2006.
b. Term loan/s availed without crop loan: where an agriculturist has availed
only Agricultural Term Loan without availing any crop loan, details of crops
grown (i.e. whether kharif / Rabi, horticulture, sugarcane or banana) are
required to be obtained, verified and recorded. Based on the duration of
these crops, overdue period for each crop as stated in (A) or (B) above will
48
Advances-Agriculture
be identified and recorded. If the term loan remains overdue for the period
identified as above, the same will be classified as NPA.
Example 2: In the example 1 referred to above, if only term loan is availed
without availing crop loan for kharif crop & sugarcane, which are actually
grown by the borrower, overdue period will be identified as 21 months for
kharif crop and 18 months for sugarcane crop as mentioned above paras.
The term loan will become NPA if its instalment of principal or interest
remains overdue for 18 months from repayment due date i.e., from
30.06.2006 (overdue period applicable will be the lower of 18 or 21 months
as applicable for crops grown by the borrower). Thus the loan for
deepening of well will become NPA on 31.12.2007.
RBI Clarification received by Maharashtra SLBC
1.45 Loan may be treated as NPA immediately on completion of two crop
seasons / one crop season (as the case may be, depending on the duration of
the crops) after the repayment due date. Two crop seasons after the due date
should refer to only those two consecutive crop seasons in which the farmer
usually undertakes crop production.
1.46 The crop season for each crop, means the period up to harvesting of
the crops raised. The asset classification norms assume that there is normal crop
yield during the season for which credit is extended. Hence, immediately after
consecutive two harvest seasons (as per the cultivation pattern followed by the
farmer borrower) from repayment due date, the account is to be identified as
NPA as per the revised guidelines. In case the yield is affected by natural
calamities as declared by the State Government, the loan accounts should be
restructured / rescheduled.
Example of NPA identification
1.47 Example of NPA identification for various types of Crop loans is given
as follows.
Particulars Rabi Kharif Rabi Sugarcane Banana
Season Season Season
Year of 2014-15 2015 2015-16 October July
Finance
Date of From From From From From
Finance 1/10/2014 1/4/2015 1/10/2015 1/10/2014 1/7/2014
Season Oct. 2014 May/June Oct. 2015 Oct-Nov.14 July-Oct.14
starts 2015
49
Guidance Note on Audit of Banks (Revised 2019)
Harvesting March / Nov. 2015 March/ Oct/Dec.15 Sept.15-
Time April 2015 April 2016 Dec.15
Repayment Up to Up to Up to Up to Up to
Due date 30/9/2015 31/3/2016 30/9/2016 31/12/2015 31/12/2015
First Crop Season after due date: (For Dual Crop Farmer i.e. he is growing
Rabi and Kharif Crop both in a year)
Season May/June Oct., June 16 1/10/2015 1/7/2015
starts 15 2015
Harvesting Nov. 2015 March/ Nov. Oct./Nov.16 Sept.16-
Time April 16 2016 Dec.16
Second Crop Season after due date: (For Dual Crop Farmer i.e. he is growing
Rabi and Kharif Crop both in a year)
Season Oct/Nov 15 May/June Oct./Nov
starts 2016 16
Harvesting March/ Nov. 16 March
Time April 2016 2017
NPA Date 30/6/2016 31/12/16 30/6/2017 31/12/2016 31/12/2016
First Crop Season after due date: (For Mono Crop Farmer i.e. he is growing
only one crop in a year.)
Season Oct/Nov May/June Oct./Nov
starts 15 2016 16
Harvesting March/ Nov. 16 March
Time April 2016 2017
Second Crop Season after due date: (For Mono Crop Farmer i.e. he is growing
only one crop in a year.)
Season Oct/Nov 16 May/June Oct./Nov
starts 2017 17
Harvesting March/ Nov. 17 March
Time April 2017 2018
NPA Date 30/6/2017 31/12/7 30/6/2018
Allied Activity (Instalment)
Dairy Goat Rearing Piggery Poultry
Type (equated (equated half (equated half (equated
quarterly yearly / yearly yearly / quarterly
installment installment yearly installment
with considering installment with
moratorium moratorium considering moratorium
period, first period of six moratorium period, first
50
Advances-Agriculture
installment months first period of six installment
will due on installment is months first will due on
Sept 30, due on June installment is Sept 30,
2013) 30, 2014) due on June 2013)
30, 2014)
Loan Disbursed 1-Jun-13 1-Jul-13 1-Jul-13 1-Jun-13
Due Date 30-Sep-13 30-Jun-14 30-Jun-14 30-Sep-13
Overdue Date 1-Oct-13 1-Jul-14 1-Jul-14 1-Oct-13
Compounding 1-Oct-13 1-Jul-14 1-Jul-14 1-Oct-13
NPA turning date 31-Dec-13 30-Sep-14 30-Sep-14 31-Dec-13
Remark After 90 After 90 days After 90 days After 90
days overdue overdue days
overdue overdue
Investment Credit (Instalment)
Type Investment Credit - Minor Irrigation system to a
farmer cultivating cotton
Loan Disbursed 1-Jun-13
Due Date 31-Mar-14
Overdue Date 1-Apr-14
Compounding 1-Apr-14
NPA turning date 31-Mar-16
Remark After two crop season. First crop season will end
at March 2015 and other will end at March 2016
Some of the Key Points while Auditing Agriculture Advances
1.48 The audit approach for agriculture advances has to be on the similar
lines as that of other advances. The following is a summary of few Key aspects in
the audit of Agricultural Advances:
a. Sanctioned amount of Agriculture Loans should be as per scale of finance
applicable to the land under cultivation and the crop being cultivated. Further,
necessary securities should be obtained as per the guidelines framed by the
bank.
b. Auditors should verify that the agricultural credit is extended only after
obtaining `No dues/ No objection certificates' from the existing credit
agencies in the area of finance.
c. Disbursement of agricultural finance is required to be carried out in various
`stages' based on the requirements of farming activity. This needs to be
ensured strictly. In some cases, the expenditure is incurred by farmer from
51
Guidance Note on Audit of Banks (Revised 2019)
his/her own sources or from non-institutional lenders and subsequently
banks are requested to reimburse the same. In such cases, auditors have to
carefully verify the facts from the documents/evidences available on record.
Under all situations, auditors should verify that the bank holds documents
evidencing the utilisation of loans for agricultural activities.
d. For crop loans, primary security is normally the standing crops under
cultivation, as such pre and post sanction visits by the officers of bank, who
are experts in Agriculture finance and adequate documentation of visit report
is a key control.
e. While verifying the security offered for agricultural loans, it is to be confirmed
that the security is legally enforceable. Standing crops and agricultural
machinery and implements are secured by a hypothecation charge, while
the agricultural land is secured by a mortgage charge. Auditors have to
ensure that amongst others, the following has been duly taken on record by
the banks:
Copy of the land revenue extracts.
Land Tax Assessment and payment receipt.
Copy of record with sub registrar. (wherever applicable)
Original copies of the title deeds.
Search of title deeds and Legal opinion from the advocate on the Bank's
approved panel.
Valuation of land from a valuer on the Bank's approved panel.
f. Loans granted to farmers against the security of NSC, KVP or Fixed
Deposits of Banks, which has been utilised for agricultural purposes, is
allowed to be classified under the category of finance to agriculture.
However, auditors should carefully verify the loan documents and other
supporting documents to ensure that non-agricultural loans are not classified
as Agricultural Finance.
g. Agricultural Advances are required to be serviced through realisation of sale
proceeds to crop. Auditors should be skeptical about the nature and timing
credits coming in to service the agricultural loans and ensure that they are
from genuine sources.
Agricultural Advances Affected by Natural Calamities
1.49 Paragraph 4.2.13 of the Master Circular - Prudential norms on Income
Recognition, Asset Classification and Provisioning pertaining to Advances
dated July 1, 2015 deals elaborately with the classification and income
recognition issues due to impairment caused by natural calamities. Banks may
52
Advances-Agriculture
decide on their own relief measures, viz., conversion of the short term
production loan into a term loan or re-schedulement of the repayment period
and the sanctioning of fresh short-term loan, subject to the guidelines
contained in RBI's latest Master Circular on "Prudential Norms on Income
Recognition, Asset Classification and Provisioning Pertaining to Advances"
dated July 1, 2015 and directions contained in RBI Master Direction
RBI/FIDD/2018-19/64 FIDD.CO.FSD.BC No.9/05.10.001/2018-19 dated October
17, 2018 on "Master Direction - Reserve Bank of India (Relief Measures by
Banks in Areas Affected by Natural Calamities) Directions, 2018". In such
cases the NPA classification would be governed by such rescheduled terms.
Asset classification of remaining amount (if any), not restructured, continue to
be governed by original terms & conditions.
1.50 Additional finance granted due to natural calamities treated as
standard assets, and will be governed by the terms & conditions of its sanction.
Different dues from the borrower (e.g. current dues, dues which are not
restructured etc.) will be classified under different asset classification norms.
This is accepted departure from the basic principle of IRAC norms, i.e. NPA
should be borrower-wise and not facility-wise.
1.51 In such cases of conversion or re-schedulement, the term loan as well
as fresh short-term loan may be treated as current dues and need not be
classified as NPA. The said benefit of restructuring of assets would not be
available for Short-term Crop Loans if the said loan was overdue at the time of
occurrence of natural calamity and for Long-term Credits if the borrower has
wilfully defaulted in repayment of loan in earlier years. The asset classification
of these loans would thereafter be governed by the revised terms & conditions
and would be treated as NPA if interest and/or instalment of principal remain
overdue for two crop seasons for short duration crops and for one crop season
for long duration crops. For the purpose of these guidelines, "long duration"
crops would be crops with crop season longer than one year and crops, which
are not 'long duration" would be treated as "short duration" crops.
1.52 In case of receipt of claim of (crop) insurance, the insurance proceeds
shall ideally compensate the losses. Under the Prime Minister Fasal Bima
Yojana (PMFBY), all Seasonal Agricultural Operations (SAO) loans for notified
crops in notified areas are to be compulsorily provided insurance cover for all
stages of the crop cycle including post-harvest risks in specified instances.
1.53 There are further ancillary measures prescribed by RBI for providing
relief in terms of relaxation on KYC norms, providing access to banking
services, etc.
53
Guidance Note on Audit of Banks (Revised 2019)
Agricultural Debt Relief / Waiver Schemes
1.54 There are various state and central government debt waiver / relief
schemes which are implemented for providing relief to the affected agriculture
borrowers. An auditor is advised to go through the schemes so declared and
implemented by state / central government for providing agricultural debt relief /
waiver as the case may be and consider the same in terms of eligible loans
under the scheme, amount of relief / waiver provided, asset classification
norms and accounting.
Audit Procedure
1.55
1. Obtain the copy of relevant schemes and bank's circular in this regard.
2. Obtain list of eligible borrowers with outstanding balance.
3. Check the claim amount statement submitted to RO/ZO for claiming the
same.
4. Check the accounting entries passed for the credit of eligible amount in the
account of the borrower.
5. Verify the accounting of interest and other charges to be borne by the
landing institution as per the scheme.
6. Ensure reporting requirement as per closing instructions of the bank.
7. Obtain written representation from the management about the scheme and
its applicability including cutoff amount and period of loan disbursed.
54
III-2
Advances-Other than
Agriculture
This Chapter is divided into following parts:
A. Introduction
B. Type of Advances and Nature of Security
C. Bank's Process
D. Regulatory Aspects
E. Accounting and Audit Process
A. Introduction
2.01 Lending constitutes a major activity of a bank besides the investment
function. The core business of banks is accepting deposits for onward lending.
Advances, generally, constitute the largest item on the assets side of the
balance sheet of a bank and are major source of its income.
2.02 Audit of advances is one of the most important areas covered by
auditors in bank audit. It is necessary that auditors should have adequate
knowledge of the banking industry and the regulations governing the banks.
Auditors must be aware of the various functional areas of the bank/branches,
its processes, procedures, systems and prevailing internal controls with regard
to advances.
2.03 Advances generally comprise of:
a) Money lent by bank to its customers including interest accrued & due;
b) Debit balances in the account of the depositors;
c) Inter-Bank Participation Certificates.
2.04 Every bank has its credit policy approved by its board of directors. The
credit policy is generally in line with the applicable RBI guidelines, relevant
laws and regulations. Auditors must acquaint themselves with the credit policy
of the bank and composition of its advances portfolio. Generally, this policy is
updated at regular intervals.
Guidance Note on Audit of Banks (Revised 2019)
B. Type of Advances and Nature of Security
Fund Based and Non-Fund Based Credit Facilities
2.05 Fund based credit facilities are those where, upon sanction, there is
an actual outflow of funds from the bank to the borrower, whereas non-fund
based facilities are those, at the time of sanction which do not involve such
outflow of the bank's funds. Typical examples of fund based facilities are term
loan, cash credit and overdraft and that of non-fund based facilities are letters
of credit, bank guarantees, letter of comfort/undertaking, etc. Non-fund based
facility may turn into a fund based facility on due date, if not paid by the
borrower, for eg. devolvement of bills under LC, invocation of Bank Guarantee,
etc.
Cash Credit
2.06 Cash credit facility is provided usually to entities (borrowers) engaged in
manufacturing and / or trading activities to enable them to meet the gap in their
working capital requirements. This facility is repayable on demand. The cash
credit facility is generally granted against the security of stocks of goods (net of
trade creditors), standing crops, bills / book debts representing genuine sales
(restricted to pre-defined age of such book debts).
2.07 Cheque book is issued to the borrower for withdrawal of money against
the limit sanctioned. The withdrawals are permitted to the extent, lower of
drawing power or sanctioned limit. This is a revolving facility and is, generally,
reviewed and renewed annually or on other intervals as per the policy of the
bank. The Bank based on the credit assessment of the borrower performs
periodical review of the borrower.
2.08 The cash credit advances are generally on `floating' interest rate
basis. The rate is reset periodically, depending upon any changes in the bank's
base rate (MCLR Marginal Cost of fund based Lending Rate) / spread in
relation to the class of borrower / risk perception about the borrower.
Working Capital Demand Loan (WCDL)
2.09 WCDL is granted for a fixed period on the expiry of which it has to be
liquidated, renewed or rolled over. Depending on the terms of sanction the
repayment of WCDL can either be in the form of instalments spread over the
tenure of the facility or bullet payment at the end of the tenure of the loan.
WCDL is generally granted to meet the gap in working capital requirement &
considered as a part of working capital facility at the time of renewal or roll
over.
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Advances-Other than Agriculture
Term Loans
2.10 Term loans are repayable in instalments spread over a period of time
excluding the moratorium period, if granted. The moratorium period is
assessed by the lender based on future cash flows and requirements of
borrower. However, if there is a default in compliance with terms and
conditions by the borrower, the bank has the right to demand repayment of the
entire loan outstanding, before due date. In few cases, there are terms for
increase in interest rate of the borrower as stipulated in sanction terms and
conditions. The amount, periodicity of repayment, last draw down date and
other terms and conditions are fixed at the time of sanction and duly recorded
in the loan documents. The amount and the periodicity may be uniform
throughout the life of the loan, or either or both of them may differ from
instalment to instalment. Besides, repayment schedule may either be drawn
only for the principal amount in which case periodic interest has to be paid by
the borrower separately as and when due, or a schedule may be fixed with
`equated monthly instalments' which also includes the amount of interest likely
to be applied to the account during its entire tenure at the rate of interest
applicable at the time of sanction/documentation/first disbursement. The
disbursal may happen in one tranche or more than one tranche as per the
requirements of the borrower.
2.11 The interest rate for loans may be either on `fixed' terms' in which
event, the rate contracted originally holds good during the entire currency of
the loan, or it may be on `variable' terms; which means that the rate may
undergo changes at unspecified periods on happening of certain events as
outlined in the loan agreement. This aspect is a subject matter of negotiation
between the bank and the borrower. Interest is charged on reducing balance
method.
2.12 The term loans are generally extended for the following purposes:
For setting up of plants, acquisition of fixed assets like land and building,
plant and machinery, furniture, vehicles, implements, houses, consumer
durables, etc.
For meeting expenses on education/medical treatment of
self/dependants.
For meeting other personal expenses.
For meeting deficit in the net working capital requirements as assessed
by the bank.(WCTL)
For Marketing / Launching / Branding etc.
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Guidance Note on Audit of Banks (Revised 2019)
2.13 Banks may give general purpose loans also i.e. without stipulating any
end-use of funds, on the strength of a suitable security, or even without
security based on the credit worthiness of the borrower. The bank policy
provides guidance and documentation to be obtained for end use of funds.
Foreign Currency Loans
2.14 Banks are authorised to lend in foreign currency. These loans are
sanctioned as per the EXIM Policy and guidelines issued by Reserve Bank of
India from time to time. Foreign Currency Loans may be in nature of Term
loans or Working Capital loans. These loans may be issued independently or
through conversion of rupee term/working capital loan to foreign currency loan
for a stipulated period as per the guidelines issued by RBI.
Overdrafts
2.15 The overdraft facility may be either secured or clean (i.e., without
security) and does not generally carry a fix repayment schedule. The most
common form of security for an overdraft arrangement is term deposit receipts. In
such cases, care is taken to ensure that lien marking is done in the system and
also on physical fixed deposit receipt (and not on fixed deposit advice). Fixed
deposits are generally for specific period and need to be renewed on the
maturity. The care should be taken to ensure that interest rate spread between
overdraft and fixed deposit are maintained. Also, the bank has updated lien mark
on new fixed deposit. Overdrafts may also be granted against other securities
like immovable properties, life insurance policies, shares, bonds, NSCs, Kisan
Vikas Patra, Indira Vikas Patra, etc. The bank has to ensure that proper margin
i.e. security value and loan amount has been kept while sanctioning the
overdraft.
Bills
2.16 The finance against bills is meant to finance the actual sale
transactions. The finance against bills can be in any of the below mentioned
form:
Purchase of bills by the bank if these are payable `on demand'.
Discounting of bills by the bank if these are usance (or time) bills.
Advance against bills under collection from the drawees, whether sent for
realisation through the bank or sent directly by the drawer to the drawees.
2.17 A unique kind of facility under this head is advances against bills drawn
on public sector undertakings / government departments which do not accept
bills. In such cases, pre-receipted challans are submitted by the borrower to the
bank as an evidence for availing finance there against (a pre-receipted challan
establishes genuine movement of goods and ensures that the funds of the bank
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Advances-Other than Agriculture
are used for sanctioned purposes only). This facility is commonly known in the
banking sector as `government bills facility' or `supply bills facility'. It may also be
mentioned that the purchase / discounting of bills may be either under a letter of
credit or without a letter of credit. In case of dishonour of bills, banks have the
right to recover the amount from the drawer with penalty, additional interest, etc.
2.18 Bills may be either `documentary', i.e., accompanied by the original
documents of title to the goods, or `clean', i.e., without the original documents
of title to the goods. In the case of documentary bills, the bank releases the
documents of title to the drawee only against payment (in the case of demand
bills purchased) or against acceptance (in the case of usance bills discounted).
On release of documents of title after acceptance of usance bills, these also
assume the nature of clean bills. The bills may be domestic (denominated in
rupee for domestic trade) or foreign (denominated in foreign currency for
import/export).
2.19 The RBI has issued guidelines for regulation of discounting and
rediscounting of bills (Ref. Master Circular No. DBR.No.Dir.BC.10/13.03.00/
2015-16, dated July 01, 2015, "Loans and Advances-Statutory and other
Restrictions".
Export
Export Credit
2.20 Exporters are granted facilities in the form of cash credit and bills only
but, being of a special nature, require a separate mention here. These facilities
extended to exporters are in the form of `pre-shipment credit' and `post-
shipment credit'. All type of advances sanctioned to finance the production
cycle i.e. from procurement of raw materials to bringing them to the port for
despatch fall under `pre-shipment credit' category. It also includes financing of
working capital expenses towards rendering of services. The advance is given
either on the basis of individual order obtained, or the customer is sanctioned
an Export Packing Credit (EPC) limit and the advances are disbursed on
submission of individual orders; in the latter case, EPC becomes a running
account. The exporter usually adjusts the account by drawing bills of exchange
on the foreign buyer, which are discounted by the bank under the letter of
credit and the proceeds collected from the foreign bank. The post-shipment
credit relates to financing of bills raised on the overseas buyer upon shipment
of goods/ services. Another feature of export credit is that the advance may be
granted in Indian Rupees or a designated foreign currency. In the latter case,
the loan is disbursed in a foreign currency. The export credit is granted at
concessional rates of interest. The pre-shipment credit has to be liquidated out
of the export proceeds only and cannot be adjusted out of rupee funds (except
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Guidance Note on Audit of Banks (Revised 2019)
where the raw materials required for processing exceed the FOB value of the
contract, in which the excess advance has to be repaid within a maximum of 30
days from the date of advance). The export proceeds have normally to be
received within 9 months from the date of shipment. The period can be
extended in genuine cases, with the approval of the bank (within the discretion
available to it under the regulations in force at the relevant time) or of the RBI,
as permitted by the Exchange Control Manual and the operating instructions
issued by the Reserve Bank from time to time. The bills representing the export
proceeds can be handled only by branches permitted to act as authorised
foreign exchange dealers as they involve handling transactions in a foreign
currency and reporting to Reserve Bank.
2.21 Pre-shipment credit granted in a foreign currency is called `Packing
Credit in Foreign Currency' (PCFC) advance and has to be repaid out of the
export bills discounted under the Export Bills Rediscounting (EBR) scheme or
out of export proceeds. Each bank designates a few select branches to handle
PCFC and EBR transactions. The Rupee Export credit is also allowed to be
shared between export order holders and manufacturer of the goods to be
exported. Similarly, bank may extend PCFC also to the manufacturer on the
basis of disclaimer from the export order holder through his bank. PCFC
granted to the manufacturer can be repaid by transfer of foreign currency from
the export order holder by availing of PCFC or by discounting of bills. It should
be ensured that no double financing is involved in the transaction and total
period of packing credit is limited to the actual cycle of production of the
exported goods. (Ref. Para 5.12 of the Master Circular No. DBR
No.DIR.BC.14/04.02.002/2015-16 dated July 1, 2015, "Rupee/Foreign
Currency Export Credit & Customer Service to Exporter"). PCFC may be made
available to both the supplier of EOU/EPZ/SEZ unit and the receiver of EOU /
EPZ / SEZ unit and PCFC for supplier EOU / EPZ / SEZ unit will be for supply
of raw material/components of goods which will be further processed and
finally exported by receiver EOU / EPZ / SEZ unit. The PCFC extended to the
supplier EOU/EPZ/SEZ unit will have to be liquidated by receipt of foreign
exchange from the receiver EOU/EPZ/SEZ unit, for which purpose, the receiver
EOU/EPZ/SEZ unit may avail of PCFC. The stipulation regarding liquidation of
PCFC by payment in foreign exchange will be met in such cases not by
negotiation of export documents but by transfer of foreign exchange from the
banker of the receiver EOU/EPZ/SEZ unit to the banker of supplier
EOU/EPZ/SEZ unit. Thus, there will not normally be any post-shipment credit in
the transaction from the supplier EOU/EPZ/ SEZ unit's point of view. In all such
cases, it has to be ensured by banks that there is no double financing for the
same transaction. Needless to add, the PCFC to receiver EOU/EPZ/SEZ unit
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Advances-Other than Agriculture
will be liquidated by discounting of export bills or by receipt of export proceeds
as per Master Circular DBR No.DIR.BC.14/04.02.002/2015-16 dated July 01,
2015, on "Rupee/Foreign Currency Export Credit & Customer Service to
Exporter". In this context, attention of the readers is also invited to RBI's
Circular No. DBOD.Dir.BC.NO.57/04.02.001/2013-14 on "Export Credit in
Foreign Currency" dated September 25, 2013.
Import
Trade Credit Buyer's Credit
2.22 In Indian context, this facility is provided by overseas banks / foreign
branches of Indian banks to the importers of capital goods and raw material
through Indian Banks to its customers (importers) towards payment of imports in
India. The overseas bank either (i) credits the amount of Buyer's credit in the
NOSTRO account of the Indian bank and the Indian bank remits the funds to the
overseas supplier of the importer for payment of import bill or (ii) remits the funds
to the overseas supplier of the importer for payment of import bill of the importer.
The typical flow of transaction of Buyer's Credit (with underlying import through
LC transaction) is as follows:
1) The borrower imports goods from foreign supplier against Foreign Letter of
Credit (FLC) drawn in favour of foreign supplier;
2) The borrower either through its Indian bank or on its own approaches foreign
bank (or overseas / foreign branches / offices of Indian banks) for availing
Buyer's Credit for payment to be made to the foreign supplier;
3) The borrower's bank arranges the credit and provides a quote with details
like the tenure, rate of interest applicable (including margin) and foreign
currency conversion rate to the borrower;
4) The Letter of Comfort is issued by Indian bank to the foreign bank on
approval of terms and conditions through SWIFT message for the proposed
Buyers Credit;
5) The foreign Bank remits funds to the NOSTRO Account of Indian bank which
is handling import transaction, on the strength of the Letter of Comfort (LoC)/
Letter of Undertaking (LoU) which is issued by the Indian bank in its favour;
6) The Indian bank remits the funds to foreign supplier through its NOSTRO
Accounts;
7) The Indian bank subsequently retires and reverses the Letter of Credit in its
book and passes another entry for creation of a non-fund based (contingent)
liability of Letter of Comfort;
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Guidance Note on Audit of Banks (Revised 2019)
8) On the due date of Buyer's Credit, the Indian bank remits the funds
(inclusive of interest) to the overseas bank and recovers the similar amount
from its customer;
9) With respect to liability towards Letter of Comfort, the Indian banks accounts
for the same as a "Contingent Liability".
The entries of the inward and outward remittances (specified in steps 4 and 5)
are to be recorded in the books of accounts (NOSTRO Mirror Account) of the
Indian bank.
Nature of Security
2.23 A brief reference has been made in the preceding section to the types
of securities commonly accepted by banks for granting different kinds of credit
facilities. In this section, the aspect will be examined in greater detail.
Primary and Collateral Securities
2.24 The term `primary security' refers to the security offered by the
borrower for bank finance or the one against which credit has been extended
by the bank. Primary security is the principal security for an advance. A
collateral security is an additional security. Security can be in any form i.e.
tangible or intangible asset, movable or immovable asset.
Mode of Creation of Security
2.25 Depending on the nature of the item concerned, creation of security
may take the form of a mortgage, pledge, hypothecation, assignment, set-off,
or lien.
Mortgage
2.26 Mortgage has been defined under section 58 of the Transfer of
Property Act, 1882, as "the transfer of an interest in specific immovable
property for the purpose of securing the payment of money advanced by way of
loan, an existing or future debt, or the performance of an engagement which
may give raise to a pecuniary liability".
2.27 Mortgages are of several kinds but the most important are the
Registered Mortgage and the Equitable Mortgage. A Registered Mortgage can
be affected by a registered instrument called the `Mortgage Deed' signed by
the mortgagor. It registers the property to the mortgagee as a security.
Equitable mortgage, on the other hand, is effected by a mere delivery of title
deeds or other documents of title with intent to create security thereof. The
government mandate to register all types of mortgages with Central Registry of
Securitisation Asset Reconstruction and Security Interest of India (CERSAI)
should be strictly followed by banks.
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Advances-Other than Agriculture
Pledge
2.28 A pledge is defined under section 172 of the Indian Contract Act,
1872, as "the bailment of goods as security for payment of a debt or
performance of a promise." A pledge thus involves bailment or delivery of
goods by the borrower to the lending bank with the intention of creating a
charge thereon as security for the advance. The legal ownership of the goods
remains with the pledger while the lending banker gets certain defined interests
in the goods. The pledge of goods constitutes a specific (or fixed) charge. In a
pledge, the bank has all the liabilities and responsibilities of a bailee of goods.
The bank may be held responsible for not carrying out their obligations as
bailee.
Hypothecation
2.29 The term `hypothecation' is not defined in law. In commercial parlance,
the term refers to the creation of an equitable charge (i.e., a charge created not
by an express enactment but by equity and reason), which is created in favour
of the lending bank by execution of hypothecation agreement in respect of the
moveable securities belonging to the borrower. Neither ownership nor
possession is transferred to the bank. However, the borrower holds the
physical possession of the goods as an agent/trustee of the bank. The
borrower periodically submits statements regarding quantity and value of
hypothecated assets (stocks, debtors, etc.) to the lending banker on the basis
of which the drawing power of the borrower is fixed.
Assignment
2.30 Assignment represents a transfer of an existing or future debt, right or
property belonging to a person in favour of another person. Only actionable
claims (i.e., claim to any debt other than a debt secured by a mortgage of
immovable property or by hypothecation or pledge of moveable property) such
as book debts and life insurance policies are accepted by banks as security by
way of assignment. An assignment gives the assignee absolute right over the
moneys/debts assigned to him. The transfer of debt, right or property is subject
to all the liabilities and equity to which the transferor was subject on the date of
transfer. In other words, the assignee cannot get a better title than that of the
assignor.
Set-off
2.31 Set-off is a statutory right of a creditor to adjust, wholly or partly, the
debit balance in the debtor's account against any credit balance lying in
another account of the debtor. A lending bank has the right of set-off in the
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Guidance Note on Audit of Banks (Revised 2019)
absence of an agreement, express or implied, to the contrary with the
borrower. The right of set-off enables a bank to combine two accounts (a
deposit account and a loan account) of the same person provided both the
accounts are in the same name and in the same right (i.e., the capacity of the
account holder in both the accounts should be the same). For the purpose of
set-off, all the branches of a bank are treated as one single entity. The right of
set-off can be exercised in respect of time-barred debts also.
Lien
2.32 Lien is creation of a legal charge with the consent of the owner, which
gives lender a legal right to seize and dispose / liquidate the asset under lien.
Types of Securities
2.33 The characteristics of a good security from the view point of the
lending bank are marketability; easy ascertainability of value, stability of value,
clean title, realisability and transferability/transportability. The most common
types of securities accepted by banks are the following.
Personal Security of Guarantor
2.34 The personal security of guarantor comprises a guarantee by a third
party for payment of loan outstanding, in the event of default by the borrower.
No charge is created on the guarantor's movable or immovable assets.
Fixed and Floating Charges
2.35 A fixed charge (also called `specific charge') is a charge on some
specific and ascertained assets. The creator of the charge (i.e., the borrower)
cannot deal with the asset without the specific consent of the holder of the
charge (i.e., the lender). A floating charge, on the other hand, is an equitable
charge on the assets, present as well as future. A floating charge attaches to
assets whose condition varies from time to time in the ordinary course of
business (e.g., work-in-process). A floating charge crystallises (i.e., becomes a
fixed charge) when money becomes repayable and the holder of the charge
(i.e., lender) takes necessary steps for the enforcement of the security.
Margin
2.36 Margin on Loans is upfront payment by the borrower towards the
purpose of the loan sanctioned. Banks provide finance after keeping suitable
margin, depending upon the risk perception of the bank. Margin is deducted
from the value of the assets to take care of any downward fluctuations in the
market value of the assets. Generally, margin is prescribed in every sanction
letter in terms of percentage of security value, as per credit policy of bank. For
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Advances-Other than Agriculture
certain types of loans such as advances against gold ornaments and jewellery,
RBI has defined limits on the loan to value.
Stock Exchange Securities and Other Instruments
2.37 Stock exchange securities include shares, debentures and bonds
which are traded on stock exchanges. These securities are easily marketable;
their market value is readily ascertainable; it is easy to ascertain the title of the
depositor; and they are easy to pledge. The banks have policy for shares
against which they provide the loan and periodically re-assess the eligible
share as security for lending against the same. In addition to stock exchange
securities, banks also make advances against such instruments as gilt-edged
securities, National Savings Certificates, Kisan Vikas Patras, Indira Vikas
Patras, Gold Bonds, etc. It may be noted that the banks are not allowed to
provide loans to companies for buy back of shares / securities. Further, the
banks are not allowed to provide loans against security of its own shares.
2.38 These securities are usually in the possession of the bank. Wherever
the shares are held as security by a bank (whether as primary or as collateral
security), banks are required to have them transferred in their own names if the
loan amount exceeds the ceiling prescribed by RBI. The ceiling is different for
shares in dematerialised form and those in physical form. In other cases, (i.e.,
where the loan amount does not exceed the prescribed ceiling), banks accept
the aforesaid securities subject to the following conditions:
(a) in the case of physical shares, if they are accompanied by blank transfer
deeds duly signed by the person in whose name they are registered; in
case of shares held in dematerialised form, authorisation slips should be
obtained from the borrower and should be passed on to relevant
depository participant who immediately marks those shares as pledged;
or
(b) if the bank holds a general power of attorney from the person in whose
name they are registered.
2.39 If the person in whose name the securities are registered is other than
the borrower, the bank has to particularly satisfy itself that the person has a
good title to the security. The bank also obtains a letter of renunciation from the
person in whose name the securities are registered.
2.40 In the case of advances against bearer securities (Kisan Vikas Patras/
Indira Vikas Patras), banks obtain independent/direct confirmation of the
genuineness of the certificates from issuing authorities. After obtaining such
confirmation, in the case of bearer securities, only possession by the bank is
sufficient.
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Guidance Note on Audit of Banks (Revised 2019)
2.41 In the case of government paper and inscribed stock, the banks
should get them registered in their own name while accepting them as security.
2.42 Before accepting shares as security, the lending bank has to ensure
that the provisions of section 19 of the Banking Regulation Act, 1949 are not
contravened except otherwise specifically permitted by RBI regulations. This
section prohibits a banking company from holding shares in any company,
whether as pledge, mortgagee or absolute owner, of an amount exceeding
thirty per cent of the paid up share capital of that company or thirty per cent of
its own paid-up share capital and reserves, whichever is less.
Goods
2.43 Goods constitute a significant proportion of the securities taken by
banks. They are either the stock-in-trade of its trading customers or the
finished products of manufacturers. Raw materials, work-in-process, etc., are
also accepted as security. Banks should have a system in place to ensure that
the security in terms of stock offered by borrower is as per the Policy of Bank.
2.44 Goods may be either hypothecated to, or pledged with, the bank. As
mentioned earlier, in case of hypothecation of goods, banks obtain periodic
statements from the borrowers (monthly/quarterly), declaring the quantity and
value of the goods on the basis of which the drawing power of the borrowers is
fixed. The officers of the lending bank pay regular visits to godowns or factories
of the borrowers to inspect them and to check the correctness of records
maintained by the borrowers on the basis of which, the periodic statements are
prepared by them. They also check the value of the goods in stock with
reference to sale bills, market quotations, etc. In case of large advances, the
inventory is subject to inspection and verification (stock audit) by external
agency at stipulated intervals. The auditor may go through the same for
determining existence and adequacy of security and also to determine the
irregularity in the account, if any.
2.45 Stock registers are maintained by the godown keepers of the lending
bank in respect of goods pledged with the bank. The godown are regularly
inspected by the inspectors and other officers of the bank. When goods are
brought into the godown, the godown keeper has to satisfy himself, by
appropriate test checks, regarding the quantity and quality of goods. Banks
have to exercise care to ensure that frauds are not perpetrated against them by
pledging packages not containing the specified goods and later on holding
them responsible for the goods supposed to have been pledged according to
the documents.
2.46 The goods are insured against fire and other risks involved and the
insurance policies are either in the name of, or endorsed in favour of, the bank.
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Advances-Other than Agriculture
2.47 In case the borrower is a company, the bank has to ensure that
charge on the goods hypothecated is registered with the Registrar of
Companies.
Documents of Title to Goods
2.48 A document of title to goods is a negotiable or quasi-negotiable
instrument. According to section 2(4) of the Sale of Goods Act, 1930, a
document of title is any document used in the ordinary course of business as
proof of the possession or control of goods, or authorising or purporting to
authorise, either by endorsement or by delivery, the possessor of the document
to transfer or receive the goods represented thereby. Documents of title
include:
Bill of lading
Railway receipt
Transporter's receipt
Dock warrant
Warehouse-keeper's certificate
Wharfinger's receipt
Warrant or order for delivery of goods
Before being pledged with the bank, these documents have to be appropriately
endorsed in favour of the bank.
Gold Ornaments and Bullion
2.49 Gold ornaments are accepted by banks as security on the basis of
assessor's certificate regarding the content, purity and weight of gold and the
value thereof. Valuation, however, keeps on changing as a result of market
fluctuations. Loans are given only on the basis of gold content of ornaments,
no regard being had to labour charges. RBI has, vide its Master Circular No.
DBR.No.Dir.BC.10/13.03.00/2015-16 on Loans and Advances-Statutory and
Other Restrictions dated July 1, 2015, directed banks to give preference to
hallmarked jewellery for granting advances. RBI has, vide its Circular No.
DBOD.BP.BC.No.86/21.01.023/2013-14 on "Lending against Gold Jewellery"
dated January 20, 2014, issued guidance in respect of Advances against Gold
Ornaments and Jewellery for the purpose of Medical Expenses and Meeting
Unforeseen Liabilities". In this context, attention of the readers is also invited to
RBI's Circular No. DBOD.No.BP.79/21.04.048/2013-14 on "Non-Agriculture
Loans against Gold Ornaments and Jewellery" dated December 30, 2013
containing guidelines on bullet repayment of loans extended against pledge of
gold ornaments and jewellery for other than agricultural purposes.
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Guidance Note on Audit of Banks (Revised 2019)
Life Insurance Policies
2.50 Life insurance policies have to be assigned in favour of the bank and
such assignment has to be registered with the insurer. The surrender value of
the policies is taken as the basis of valuation.
Plantations
2.51 Advances are made to agriculturists such as tea gardeners to finance
their growing crops. When the produce is harvested, processed and sold, the
money is repaid to the bank.
2.52 The basis of calculating the amount of the advance is the estimated
crop of the season. This depends upon the area under cultivation, expected
yield, etc. Separate advances are made for each season's crop. Please refer
chapter on Agricultural advances for detail.
2.53 The crop to be produced is hypothecated to the bank. Generally, the
fixed assets of the plantation are also mortgaged with the bank as collateral
security. Finance is taken from the bank to incur expenditure on the crop. As
such, the amount of the advance increases as the crop grows.
Immovable Property
2.54 Before advancing money on mortgage of immovable property, the
lending bank has to satisfy itself that the borrower has a clear and
unencumbered title to the property, and that the property is marketable and
adequately insured. For this purpose, banks also ascertain whether the
property in question has already been mortgaged to any other financial
institution and if so, the details of the charges already created on the property.
In respect of advances to public companies against the mortgage of a block of
assets, it is essential that the provisions of section 180(1)(a) of the Companies
Act, 2013 need to be kept in view.
Third Party Guarantees
2.55 Advances covered only by the personal guarantee of third parties
(except banks and government) in addition to the personal security of the
borrower are not classified as `secured' advances and would be classified as
`unsecured' advances in the financial statements.
2.56 The guarantee bond executed by the guarantor in favour of the bank
may be in bank's own prescribed form or otherwise. Such bonds are generally
executed by holding companies, overseas customers, overseas principals,
insurance companies, etc. A letter of continuity is also obtained from the
guarantor.
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Advances-Other than Agriculture
Banker's General Lien
2.57 Besides the above securities, which are created by an agreement
between the borrower and the bank, a lending bank also has a general lien
under the law. A lien represents the right of retaining the goods/securities
unless a debt due by a debtor is paid to the creditor (retainer), provided there is
no agreement, express or implied, to the contrary. A lien is a statutory right,
which does not require any separate agreement. Under section 171 of the
Indian Contract Act, 1872, a banker may, in the absence of an agreement to
the contrary, retain as security for a general balance of account, any goods and
securities bailed to him. This is called banker's general lien. Two conditions
necessary for creating such lien are:
(a) the securities must have been placed in his hands as a banker by his
customers; and
(b) they are not specifically appropriated.
2.58 Examples of securities over which a banker has general lien are credit
balance in any other account, bonds and coupons deposited for collection,
securities allowed to remain in the banker's hands after repayment of a secured
advance, etc. Examples of securities on which a banker does not have a general
lien are securities deposited for safe custody, money deposited or earmarked for a
specific purpose, documents executed for a special purpose, etc. Lien is applicable
even in respect of the borrower's obligations as a surety. The banker's right of
general lien over the security is not barred by the law of limitation and can be
exercised in the case of unenforceable or time-barred debts also.
2.59 The term `negative lien' is commonly used to refer to an undertaking
given by the borrower to the bank that borrower will not create any charge such
as lien, pledge, hypothecation, or mortgage, over his immovable and moveable
properties and assets including uncalled capital without the prior permission of
the bank. A negative lien relates to goods, securities, etc., which are not in the
possession of the bank. Negative lien does not require registration with the
Registrar of Companies or similar other authorities.
C. Bank's Process
Procedure for Sanction, Documentation, Disbursement, Supervision
and Renewal of Advances
2.60 Each bank has its own procedures for sanctioning, disbursal,
supervision and renewal of advances. Following is the common process across
banks w.r.t. advances.
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Guidance Note on Audit of Banks (Revised 2019)
Sanction
Loan Application
2.61 Initiation of process of sanction of advance is receipt of a formal
request from the applicant. The request may be in the form of a standard
format (Loan Application Form) of the bank or in the form of a letter in which
case the bank requests the intending borrower to furnish the standard format
duly filled in. All applications are entered in a Loan Applications Received
Register (the exact nomenclature may vary from bank to bank). The required
supporting documents are to be furnished along with the application. The Bank
should ensure that the documents are obtained from respective borrowers as
per the Loan policy of the Bank.
Credit Appraisal
2.62 The proposal is evaluated in the context of the directions of the RBI
including prudential exposure limits and the bank's own credit policy and risk
management guidelines. Besides, the proposal is appraised on the following
parameters to ensure technical feasibility, economic viability and commercial
acceptability (the degree of scrutiny depends largely on the amount of the
advance):
Performance of the unit vis-a-vis other similar units.
Conduct of its accounts with the lenders.
Experience, competence and profile of the management of the unit.
Guarantees and collateral securities offered.
Trend and ratio analysis to see that the unit's growth is healthy, financials
are sound, liquidity is comfortable and the promoters have a reasonable
stake in the unit.
Availability of inputs for production.
Market condition.
Technology in use.
Unit's capability to achieve the projected operating and performance levels
and to service the debt.
Applicability of norms/benchmarks relating to scale of finance, e.g., Nayak
Committee recommendations for SSI units, scale of finance fixed by the
bank for agricultural finance to be extended in the local area, etc.
CIBIL, RBI List of defaulter, Credit and confidential reports from other
banks. These are to be checked from respective websites.
Various disclosure/notices issued by the government/government authority
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Advances-Other than Agriculture
such as with regard to shell companies, defunct companies, directors of
these types of companies, etc.
Latest Government. policy about particular industry / Locational restriction,
etc.
Sanctioning Authority
2.63 If the official concerned finds the proposal acceptable, a detailed
appraisal note is submitted along with necessary supporting documents with
recommendations to the authority having powers to sanction it. Each official
who has been vested with powers to sanction advances has a monetary ceiling
upto which he/she can sanction advances to the specified kind of borrowers
(like individuals, partnerships, companies, etc.) and/or for the specified
activities (like agriculture, industry, professional education, business, etc.) and /
or for the type of facility (term loan, overdraft, cash credit, etc.). Such powers
are properly documented and circulated by the bank to all its offices as
Delegation of Powers. The officials at the branch can sanction only those
advances, which fall within their delegated powers. For advances, which
require to be sanctioned by higher authorities, the branch has to carry out the
appraisal and send the proposal along with its recommendations to its
controlling office for necessary sanction. As and when the advance is
sanctioned by the competent authority (which could be an official, a committee
of officials or the board of directors of the bank, depending on the amount
involved), the fact of sanction along with detailed terms and conditions of the
sanction are communicated by the controlling office to the branch.
Documentation and Disbursement
2.64 After the sanction of the advance, the branch communicates the terms
and conditions of the sanction to the applicant and obtains its consent for the
arrangement. Thereafter, the documents as prescribed by the bank are
obtained, charges created and, the bank's charge over the unit's assets noted
with the authorities concerned, e.g., Registrar of Companies, Road Transport
Authority, Insurance Company, Land Records Authority, CERSAI, etc. In the
case of an advance to a partnership firm, while the account is opened in the
trade name of the firm, the security documents are got executed from the
partners in both their individual capacity (i.e., without mentioning the name of
the firm or affixing the stamp of the firm) and in their capacity as partners of the
firm. This is to ensure that the advance may be recovered from the assets of
the firm as well as from the individual assets of the partners. The bank
generally records the sanction details and stipulation in the system. In many
cases, the system is updated for pre-sanction, pre-disbursement documents for
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Guidance Note on Audit of Banks (Revised 2019)
each loan. The document discrepancy report then acts as a check for
documents received and pending for monitoring purposes.
2.65 After the above formalities have been completed, the advance is
released in the following manner:
Term loans (granted generally for acquisition of fixed assets, etc.) are
disbursed on the basis of quotations/ proforma invoices obtained by the
borrower from the vendors and submitted to the bank either along with the
application or later. In case of large projects, the schedule and status of
completion of projects have also to be seen. Banks generally stipulate a
stated percentage of the cost to be met by the borrower from his own
funds. Once the borrower provides his contribution to the bank, the branch
debits the Term Loan account with the balance amount and pays the
amount to the vendor directly along with a letter stating the purpose of the
funds. The term loan may be released in one or more instalments. As and
when the asset is received by the borrower, the bank officials inspect it,
record the particulars in their books, and obtain copies of the final invoices
for their record from the borrower.
There may be instances where, on business considerations, the borrower
has already acquired the asset. In such a case, he submits the
documentary evidence to the branch and seeks reimbursement to the
extent permissible. The branch officials inspect the asset and verify books
of account of the borrower and, if satisfied, credit the eligible amount to the
borrower's account (current / cash credit, as desired by the borrower) by
debiting his term loan account.
Cash credit advances are released on the basis of drawing power
calculated as per the stock statements submitted by the borrower as per
the periodicity laid down in the terms of sanction. The branch officials
verify the stock statements and calculate the `drawing power' based on the
security held by the borrower and the margin prescribed in the sanction. In
case of consortium accounts, the drawing power calculation and allocation
is made by the Lead Bank and is binding on the Member Banks (Circular
No. C&I/Circular/2014-15/689 dated 29 September 2014 issued by the
Indian Banks Association). This `drawing power' is noted in the system in
respect of Cash Credit accounts and is a guide to the official concerned
while authorising debits to the account.
The procedures of many banks require the branch manager to periodically
submit a certificate to the controlling authority (i.e., regional or zonal office)
that all disbursements during the relevant period have been made only
after completion of the necessary formalities.
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Central Registry of Securitisation Asset Reconstruction and Security
Interest of India (CERSAI) - The auditor needs to keep abreast the
mandatory requirements related to registration of mortgages and
compliance thereof by the lender bank, as applicable to the various forms
of securities offered as security for the advances.
Monitoring and Supervision
2.66 The following are the procedures usually adopted by banks for
monitoring and supervision of advances after disbursement:
Regular inspection of the borrower's assets and books. The main purposes
of inspection are as follows:
o To ensure that the amounts disbursed have been utilised for purposes
for which the advance was sought.
o To check that the borrower has not acquired / disposed of any asset
without the consent / knowledge of the bank, depending upon the
terms of the advance. Acquisition of fixed assets from working capital
funds may amount to diversion of short-term funds which, from the
viewpoint of the bankers, is not a sign of financial prudence.
o To cross-check the figures declared in the stock statements with the
books maintained by the borrower (including excise and other
statutory records, as applicable) as well as to physically verify the
stock items, to the extent possible.
o To check that the unit has been working on projected levels
particularly in the areas of sales and production and the general
working of the unit is satisfactory.
o To ensure that the borrower has not availed of finance against stocks
for which it has itself not made the payment.
o To ensure that the borrower has not availed of unauthorised finance
from any other lender.
o To ensure that the borrower has not made any investment in, or
advances to, its associates without the bank's approval, if such
approval is required as per the terms of the loan or otherwise diverted
the funds.
o To check that there is a regular turnover of stocks and the unit does
not carry any obsolete, unusable stocks. Generally, banks place a limit
on the age of stocks which are eligible for bank finance; the items
older than such limit are not financed. Similarly, in the case of book
debts, debts outstanding beyond a specified period are also not
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Guidance Note on Audit of Banks (Revised 2019)
eligible for bank finance. Also to check Sundry creditors for goods.
o To ensure that the borrower continues to be engaged in the activity for
which the loan has been granted.
Periodic review of the progress in implementation of the project (to note
whether project timelines given at the time of processing loan are being
adhered to. If there are delays, it may hamper the project completion and
may affect servicing of loan). Generally, in large and complex projects,
banks appoint lead engineer agency who provides the status of the project
on periodically basis.
Review of the conduct of the account.
Obtaining and scrutinising stock statements.
Obtaining other relevant financial data periodically and analysis of the
data. Banks obtain information at monthly / quarterly / half yearly / yearly
intervals about on the levels of sales, production, profit, cash accruals,
break up of assets and liabilities, cash flows etc. The analysis covers the
following points:
o Comparison of the data with the projections contained in the appraisal
note to find out the deviations, the reasons thereof, and the corrective
action to be taken, wherever necessary.
o Comparison of the unit's performance, on an on-going basis, with
other similar units.
o Ratio analysis based on the provisional data submitted by the unit to
find out the liquidity and solvency position and any diversion of short-
term resources towards long term uses.
o Observing the credits to the account.
Whenever the above analysis indicates weaknesses in operations, or the
need for additional documentation or security, a dialogue is held with the
borrower, with consequent follow-up.
2.67 RBI, vide its circular no. DBS.CO.PPD.BC.No. 5 /11.01.005/2010-11
dated January 14, 2011 on "End Use of Funds - Monitoring", has advised to
evaluate and strengthen the efficacy of the existing machinery in the banks for
post-sanction inspection by the bank officers, supervision and follow-up of
advances. There needs to be a proper process of stock audit of the borrowers.
Effective monitoring of the end use of funds lent is of critical importance in
safeguarding a bank's interest. Further, this would also act as a deterrent for
borrowers to misuse the credit facilities sanctioned, and in the process, help
build a healthy credit culture in the Indian banking system.
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Advances-Other than Agriculture
Early Recognition of Financial Distress, Prompt Steps for Resolution and Fair
recovery of lenders Framework for revitalisation of distressed assets
2.68 The RBI has issued guidelines for classification of standard assets
into three sub-categories, viz., SMA-0, SMA-1 and SMA2 in order to recognise
the financial distress in any performing asset at an early stage, besides
regulatory compliances like forming of Joint Lender's Forum, reporting to
CRILC, etc. for specified categories of Special Mention Accounts (SMA). In
case if the bank does not follow the said regulatory compliances, such
accounts are subjected to accelerated provisions. These provisions are
elaborately given in Paragraphs 4.111 to 4.114 of Part III of the Guidance Note.
Renewal of Advances
2.69 Working capital advances are generally granted for one year at a time
and require renewal if the borrower wants to continue the facility beyond that
period at the same level, reduced level or increased level, depending upon the
borrower's needs, its financial ratios, the bank's perception of risk and so on.
Loans repayable over a period of time in instalments are not renewed.
However, some banks have a system of reviewing these loans from time to
time primarily with the objective of risk evaluation and interest rate resetting.
The procedure described above for sanction of advances is also followed, to
the extent applicable, for renewal of advances already granted to an applicant.
2.70 The RBI guidelines require banks to renew the advances within 6
months of the expiry of the limit. Hence no working capital limit can remain
without reviewed for more than 18 months. It should be ensured that the latest
audited balance sheet, various compliance proofs should be on bank's record.
Further the various monitoring reports such as inspections, stock audit and
operations in the account should be taken cognisance of during renewal.
2.71 Non-renewal sometimes may appear to be administrative delay but it
may not be so. Hence stricter compliances should be ensured.
Nature of Borrowing Arrangements
2.72 The following paragraphs explain the different ways in which a
banking arrangement can be tied up by a borrower.
Sole Banking
2.73 In this arrangement, the borrower obtains credit from a single bank. This
is the simplest form of tie-up and is operationally convenient for both the lender
and the borrower. Most of the banking tie-ups in India are of this type because
the quantum of bank finance in an individual case is usually small. Depending on
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Guidance Note on Audit of Banks (Revised 2019)
the nature and extent of credit facility offered, the lending bank itself may
stipulate that the borrower will not avail of finance from another bank.
Consortium Arrangement
2.74 In this type of arrangement, the number of lending banks is more than
one. The lending banks form a formal consortium. Salient features of the
arrangement are:
The consortium has a formal leader, called the `lead bank' (normally
though not necessarily, the bank with the largest exposure).
The consortium frames and adopts its rules within the RBI framework for
conducting its business with the borrower.
There is a common set of loan documents, which is obtained by the lead
bank on behalf of other participating banks also.
The lead bank is responsible for overall monitoring.
The member banks of the consortium have rights over the security in an
agreed proportion.
The borrower maintains direct business relationship with all member
banks of the consortium.
Minutes of the consortium meetings are circulated amongst the members.
Banks should exchange information about the conduct of the borrowers'
accounts with other banks at least at quarterly intervals.
Multiple Banking
2.75 In this type of arrangement, there is no formal arrangement amongst
the lending banks. Each of them has its set of loan documents, securities and
mode of lending, independent of other lending banks. The borrower has to deal
with each of the banks separately.
2.76 The RBI, vide its Circular No. DBOD No. BP. BC.46/ 08.12.001/2008-
09 dated September 19, 2008 on "Lending under Consortium
Arrangement/Multiple Banking Arrangements", encourages the banks to
strengthen their information back-up about the borrowers enjoying credit facilities
from multiple banks as under:
(i) At the time of granting fresh facilities, banks may obtain declaration from
the borrowers about the credit facilities already enjoyed by them from other
banks, as prescribed in the RBI Circular No. DBOD.No.BP.BC.94
/08.12.001/2008-09 dated December 08, 2008 on "Lending under
Consortium Arrangement/Multiple Banking Arrangements". In the case of
existing lenders, all the banks may seek a declaration from their existing
borrowers availing sanctioned limits of Rs.5.00 crores and above or
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Advances-Other than Agriculture
wherever, it is in their knowledge that their borrowers are availing credit
facilities from other banks, and introduce a system of exchange of
information with other banks as indicated above.
(ii) Subsequently, banks should exchange information about the conduct of the
borrowers' accounts with other banks at least at quarterly intervals.
(iii) Obtain Diligence Report by a professional at regular intervals, regarding
compliance of various statutory prescriptions that are in vogue, as per
specimen given in the RBI Circular.
D. Regulatory Aspects
Guidelines of the RBI on Income Recognition, Asset Classification,
Provisioning and Other Related Matters
2.77 Detailed guidelines w.r.t. Income Recognition, Asset Classification and
provisioning requirements have been given in Chapter 4 of Part III of the
Guidance Note.
Restrictions on Advances
2.78 The Master Circular no. RBI/2015-16/95 DBR.No.Dir.BC.10
/13.03.00/2015-16 dated July 1, 2015, on "Loans and Advances - Statutory and
other Restrictions" issued by the RBI contains detailed requirements and
guidelines in respect of statutory and other restrictions on loans and advances
by banks.
Statutory Restrictions
Advances against Bank's own Shares
2.79 In terms of Section 20(1) of the Banking Regulation Act 1949, a bank
cannot grant any loan or advance against the security of its own shares.
Advances to Bank's Directors
2.80 Section 20(1) of the Banking Regulation Act, 1949 also lays down the
restrictions on loans and advances to the directors and the firms in which they
hold substantial interest.
2.81 Banks are prohibited from entering into any commitment for granting
any loans or advances to or on behalf of any of its directors, or any firm in which
any of its directors is interested as partner, manager, employee or guarantor, or
any company (not being a subsidiary of the banking company or a company
registered under Section 8 of the Companies Act, 2013 or a Government
company) of which, or the subsidiary or the holding company of which any of the
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Guidance Note on Audit of Banks (Revised 2019)
directors of the bank is a director, managing agent, manager, employee or
guarantor or in which he holds substantial interest, or any individual in respect of
whom any of its directors is a partner or guarantor. There are certain exemptions
given in the aforesaid Master Circular in this regard.
2.82 For the above purpose, the term 'loans and advances' shall not include
the following:
(a) loans or advances against Government securities, life insurance policies or
fixed deposit;
(b) loans or advances to the Agricultural Finance Corporation Ltd;
(c) such loans or advances as can be made by a banking company to any of its
directors (who immediately prior to becoming a director, was an employee
of the banking company) in his capacity as an employee of that banking
company and on the same terms and conditions as would have been
applicable to him as an employee of that banking company, if he had not
become a director of the banking company. The banking company includes
every bank to which the provisions of Section 20 of the Banking Regulation
Act, 1949 apply;
(d) such loans or advances as are granted by the banking company to its
Chairman and Chief Executive Officer, who was not an employee of the
banking company immediately prior to his appointment as
Chairman/Managing Director/CEO, for the purpose of purchasing a car,
personal computer, furniture or constructing/ acquiring a house for his
personal use and festival advance, with the prior approval of the RBI and on
such terms and conditions as may be stipulated by it;
(e) such loans or advances as are granted by a banking company to its whole
time director for the purpose of purchasing furniture, car, Personal
Computer or constructing/acquiring house for personal use, festival
advance with the prior approval of RBI and on such terms & conditions as
may be stipulated by it;
(f) call loans made by banking companies to one another;
(g) facilities like bills purchased/discounted (whether documentary or clean
and sight or usance and whether on D/A basis or D/P basis), purchase of
cheques, other non-fund based facilities like acceptance/co-acceptance of
bills, opening of L/Cs and issue of guarantees, purchase of debentures from
third parties, etc.;
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Advances-Other than Agriculture
(h) line of credit/overdraft facility extended by settlement bankers to National
Securities Clearing Corporation Ltd.(NSCCL) / Clearing Corporation of India
Ltd. (CCIL) to facilitate smooth settlement; and
(i) a credit limit granted under credit card facility provided by a bank to its
directors to the extent the credit limit so granted is determined by the bank
by applying the same criteria as applied by it in the normal conduct of the
credit card business.
2.83 Purchase of or discount of bills from directors and their concerns, which
is in the nature of clean accommodation, is reckoned as `loans and advances' for
the purpose of Section 20 of the Banking Regulation Act, 1949.
Restrictions on Power to Remit Debts
2.84 Section 20A of the Banking Regulation Act, 1949 stipulates that
notwithstanding anything to the contrary contained in Section 180 of the
Companies Act, 2013, a banking company shall not, except with the prior
approval of the Reserve Bank, remit in whole or in part any debt due to it by -
any of its directors, or
any firm or company in which any of its directors is interested as director,
partner, managing agent or guarantor, or
any individual, if any of its directors is his partner or guarantor.
Any remission made in contravention of the provisions stated above shall be void
and have no effect.
Restriction on Holding Shares in Companies
2.85 In terms of Section 19(2) of the Banking Regulation Act, 1949, banks
should not hold shares in any company except as provided in sub-section (1)
whether as pledgee, mortgagee or absolute owner, of an amount exceeding 30
percent of the paid-up share capital of that company or 30 percent of its own
paid-up share capital and reserves, whichever is less, except otherwise
specifically permitted by RBI regulations.
2.86 Further, in terms of Section 19(3) of the Banking Regulation Act, 1949,
the banks should not hold shares whether as pledgee, mortgagee or absolute
owner, in any company in the management of which any managing director or
manager of the bank is in any manner concerned or interested.
2.87 Accordingly, while granting loans and advances against shares,
statutory provisions contained in Sections 19(2) and 19(3) should be strictly
observed, except otherwise specifically permitted by RBI regulations.
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Guidance Note on Audit of Banks (Revised 2019)
Restrictions on Credit to Companies for Buy-back of their Securities
2.88 In terms of Section 68 of the Companies Act, 2013, companies are
permitted to purchase their own shares or other specified securities out of their:
Free reserves;
Securities premium account; or
Proceeds of any shares or other specified securities.
subject to compliance of various conditions specified in sub-section (2) of
section 68 of Companies Act, 2013. Therefore, banks should not provide loans
to companies for buy-back of shares/securities.
Regulatory Restrictions
Granting Loans and Advances to relatives of Directors
2.89 Without prior approval of the Board or without the knowledge of the
Board, no loans and advances should be granted to relatives of bank's
Chairman/Managing Director or other Directors, Directors (including
Chairman/Managing Director) of other banks and their relatives, Directors of
Scheduled Co-operative Banks and their relatives, Directors of
Subsidiaries/Trustees of Mutual Funds/Venture Capital Funds set up by the
financing banks or other banks. However, banks may grant loan or advance to
or on behalf of spouses of their Directors in cases where the spouse has
his/her own independent source of income arising out of his/her employment or
profession and the facility so granted is based on standard procedures and
norms for assessing the creditworthiness of the borrower. Such facility should
be extended on commercial terms. Accordingly, the Banks should not grant
loans and advances without the approval of Board of Directors/Management
Committee aggregating Rupees twenty five lakhs and above to
a. directors (including the Chairman/Managing Director) of other banks;
b. any firm in which any of the directors of other banks is interested as a
partner or guarantor;
c. any company in which any of the directors of other banks holds substantial
interest or is interested as a director or as a guarantor;
d. any relative other than spouse and minor/dependent children of their own
Chairmen/Managing Directors or other Directors;
e. any relative other than spouse and minor/dependent children of the
Chairman/Managing Director or other directors of other banks;
f. any firm in which any of the relatives other than spouse and minor/
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Advances-Other than Agriculture
dependent children as mentioned in (d) & (e) above is interested as a
partner or guarantor;
g. any company in which any of the relatives other than spouse and minor /
dependent children as mentioned in (d) & (e) above hold substantial interest
or is interested as a director or as a guarantor.
Restrictions on Grant of Loans and Advances to Officers and the Relatives
of Senior Officers of Banks
2.90 Loans and advances to officers of the bank - No officer or any
Committee comprising, inter alia, an officer as member, shall, while exercising
powers of sanction of any credit facility, sanction any credit facility to his/her
relative. Such a facility shall ordinarily be sanctioned only by the next higher
sanctioning authority. Credit facilities sanctioned to senior officers of the
financing bank should be reported to the Board. Loans and advances and award
of contracts to relatives of senior officers of the bank or proposals for credit
facilities to the relatives of senior officers of the bank sanctioned by the
appropriate authority should be reported to the Board. Further, when a credit
facility is sanctioned by an authority, other than the Board, to -
any firm in which any of the relatives of any senior officer of the financing
bank holds substantial interest, or is interested as a partner or guarantor;
or
any company in which any of the relatives of any senior officer of the
financing bank holds substantial interest, or is interested as a director or
as a guarantor, such transaction should also be reported to the Board.
Credit facility will not include loans and advances such as housing loans, car
advances, consumption loans, etc., granted to an officer of the bank under any
scheme applicable generally to bank employees.
Restrictions on Grant of Financial Assistance to Industries Producing /
Consuming Ozone Depleting Substances (ODS)
2.91 Banks should not extend finance for setting up of new units
consuming/producing the Ozone Depleting Substances (ODS). No financial
assistance should be extended to small/medium scale units engaged in the
manufacture of the aerosol units using chlorofluorocarbons (CFC) and no
refinance would be extended to any project assisted in this sector.
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Guidance Note on Audit of Banks (Revised 2019)
Restriction on Advances against Sensitive Commodities under Selective
Credit Control (SCC)
2.92 With a view to prevent speculative holding of essential commodities with
the help of bank credit and the resultant rise in their prices, in exercise of powers
conferred by Section 21 & 35A of the Banking Regulation Act, 1949, the Reserve
Bank of India, issues, from time to time, directives to all commercial banks,
stipulating specific restrictions on bank advances against specified sensitive
commodities.
2.93 Commodities presently under the Selective Credit Control include:
a) food grains i.e. cereals and pulses;
b) selected major oil seeds indigenously grown, viz. groundnut, rapeseed /
mustard, cottonseed, linseed and castor seed, oils thereof, vanaspati and
all imported oils and vegetable oils;
c) raw cotton and kapas;
d) sugar/ gur / khandsari;
e) Cotton textiles which include cotton yarn, man-made fibres and yarn and
fabrics made out of man-made fibres and partly out of cotton yarn and
partly out of man-made fibres.
Restriction on payment of commission to staff members including
officers
2.94 Section 10(1)(b)(ii) of Banking Regulation Act, 1934, stipulates that a
banking company shall not employ or continue the employment of any person
whose remuneration or part of whose remuneration takes the form of
commission or a share in the profits of the company. Further, clause (b) of
Section 10(1)(b)(ii) permits payment of commission to any person who is
employed only otherwise than as a regular staff. Therefore, banks should not
pay commission to staff members and officers for recovery of loans.
Restrictions on offering incentives on any banking products
2.95 Banks are also not permitted to offer any banking products, including
online remittance schemes etc., with prizes /lottery/free trips (in India and/or
abroad), etc. or any other incentives having an element of chance, except
inexpensive gifts costing not more than Rs. 250/-, as such products involve non-
transparency in the pricing mechanism. Such products, if offered, by banks are
considered as violation of the extant guidelines and the banks concerned are
liable for penal action.
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Advances-Other than Agriculture
Restrictions on Other Loans and Advances
Loans and Advances Against Shares, Debentures and Bonds
2.96 Banks are required to strictly observe regulatory restrictions on grant
of loans and advances against shares, debentures and bonds which are
detailed in the July, 2015 Master Circular on Exposure Norms'. The restrictions,
inter alia, on Loans and Advances Statutory and Other Restrictions loans and
advances against shares and debentures, are:
(a) No loans to be granted against partly paid shares.
(b) No loans to be granted to partnership/proprietorship concerns against
the primary security of shares and debentures.
2.97 RBI's Master Circular on "Loans and Advances - Statutory and Other
Restrictions" contains guidelines for granting Loan and Advances against
Shares, Debentures and Bonds as follows:
Advances to individuals
2.98 Banks may grant advances against the security of shares, debentures
or bonds to individuals subject to the following conditions:
(i) Amount of advance: Loans against the security of shares, debentures and
bonds should not exceed the limit of Rs. 10 lakhs per individual if the
securities are held in physical form and Rs. 20 lakhs per individual if the
securities are held in dematerialised form.
(ii) Margin: Banks should maintain a minimum margin of 50 percent of the
market value of equity shares / convertible debentures held in physical
form. In the case of shares / convertible debentures held in dematerialised
form, a minimum margin of 25 percent should be maintained. These are
minimum margin stipulations and banks may stipulate higher margins for
shares whether held in physical form or dematerialized form. The margin
requirements for advances against preference shares / nonconvertible
debentures and bonds may be determined by the banks themselves.
(iii) Lending policy: Each bank should formulate with the approval of their
Board of Directors, a Loan Policy for grant of advances to individuals
against shares / debentures / bonds keeping in view the RBI guidelines.
Banks should obtain a declaration from the borrower indicating the extent of
loans availed of by him from other banks as input for credit evaluation. It
would also be necessary to ensure that such accommodation from different
banks is not obtained against shares of a single company or a group of
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Guidance Note on Audit of Banks (Revised 2019)
companies. As a prudential measure, each bank may also consider laying
down appropriate aggregate sub-limits of such advances.
Advances to Share and Stock Brokers/ Commodity Brokers
2.99
(i) Banks and their subsidiaries are not permitted to undertake financing of
'Badla' transactions. Banks can grant advances only to share and stock
brokers registered with SEBI and who comply with capital adequacy norms
prescribed by SEBI / Stock Exchanges. This could be towards their need
based overdraft facilities / line of credit against shares and debentures held
by them as stock in trade. A careful assessment of need based
requirements for such finance should be made taking into account the
financial position of the borrower, operations on his own account and on
behalf of clients, income earned, the average turnover period of stocks and
shares and the extent to which the broker's funds are required to be
involved in his business operations. Banks may also grant working capital
facilities to such stock brokers to meet the cash flow gap between delivery
and payment for DVP transactions undertaken on behalf of institutional
clients viz. FIs, Flls, mutual funds and banks, the duration of such a facility
will be short and would be based on an assessment of the financing
requirements keeping in view the cash flow gaps, the broker's funds
required to be deployed for the transaction and the overall financial position
of the broker. The utilization to be monitored on the basis of individual
transactions. Further, Banks may institute adequate safeguards and
monitoring mechanisms. A uniform margin of 50 per cent is required to be
applied on all advances/ financing of IPOs/ issue of guarantees on behalf of
share and stockbrokers. A minimum cash margin of 25 per cent (within the
margin of 50%) shall be maintained in respect of guarantees issued by
banks for capital market operations. The above minimum margin will also
apply to guarantees issued by banks on behalf of commodity brokers in
favour of commodity exchanges viz. National Commodity & Derivatives
Exchange (NCDEX), Multi Commodity Exchange of India Ltd. (MCX) and
National Multi Commodity Exchange of India Ltd. (NMCEIL), in lieu of
margin requirements as per the commodity exchange regulations. These
margin requirements will also be applicable in respect of bank finance to
stock brokers by way of temporary overdrafts for DVP transactions. Banks
may issue guarantees on behalf of share and stock brokers/commodity
brokers in favour of stock exchanges in lieu of security deposit to the extent
it is acceptable in the form of bank guarantee as laid down by stock
exchanges. Banks may also issue guarantees in lieu of margin
requirements as per stock exchange regulations.
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Advances-Other than Agriculture
(ii) The requirement relating to transfer of shares in bank's name in respect of
shares held in physical form mentioned at Sl. No. (ix) of paragraph 2.3.1.14
of Master Circular on Loans and Advances would not apply in respect of
advances granted to share and stock brokers provided such shares are
held as security for a period not exceeding nine months. In the case of
dematerialised shares, the depository system provides a facility for pledging
and banks may avail themselves of this facility and in such cases, there will
not be need to transfer the shares in the name of the bank irrespective of
the period of holding. The share and stock brokers are free to substitute the
shares pledged by them as and when necessary. In case of a default in the
account, the bank should exercise the option to get the shares transferred
in its name.
Bank Finance for Market Makers
2.100 Banks may provide need based finance to meet the genuine credit
requirements of approved Market Makers. For this purpose, they should lay down
appropriate norms for financing them including exposure limits, method of
valuation, etc. They should also follow the guidelines given below:
a) Market Makers approved by stock exchange would only be eligible for grant
of advances by scheduled commercial banks.
b) Market Making may be for equity as well as for debt securities including
State and Central Government securities.
c) A uniform margin of 50 per cent shall be applied on all advances / financing
of IPOs / issue of guarantees on behalf of market makers. A minimum cash
margin of 25 per cent (within the margin of 50%) shall be maintained in
respect of guarantees issued by banks for capital market operations.
d) Banks may accept, as collateral for the advances to the Market Makers,
scrips other than the scrips in which the market making operations are
undertaken.
e) Banks should ensure that advances provided for Market Making are not
diverted for investment in shares other than the scrip earmarked for Market
Making purpose. For this purpose, a suitable follow-up and monitoring
mechanism must be evolved.
f) The ceiling of Rupees ten lakhs / Rupees twenty lakhs for advances against
shares/debentures to individuals will not be applicable in the case of Market
Makers.
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Guidance Note on Audit of Banks (Revised 2019)
2.101 Each bank should lay down a detailed loan policy for granting advances
to Stock Brokers and Market Makers and also a policy for grant of guarantees on
behalf of brokers which should include, inter alia, the following:
Purpose and use of such advances / guarantees.
Pricing of such advances.
Control features that specifically recognise the unique characteristics and
risks of such financing.
Method of valuation of collateral.
Frequency of valuation of shares and other securities taken as collateral.
Guidelines for transfer of shares in bank's name.
Maximum exposure for individual credits (within the RBI prescribed
prudential Single Borrower Limit). The Board may also consider laying
down a limit on the aggregate exposure of the bank to this sector.
Approval process for identification of eligible securities against which loan
can be provided.
Periodic re-assessment of eligible security so that they continued to be
allowed as eligible security.
The aggregate portfolio, its quality and performance should be reviewed and put
up at least on a half-yearly basis to the Board.
Advances to Individuals against shares to joint holders or third party beneficiaries
2.102 While granting advances against Shares held in joint names to joint
holders or third party beneficiaries, banks should ensure that no advances to
other joint holders or third party beneficiaries is granted to circumvent the above
limits placed on loans/advances against shares and other securities.
Financing of Initial Public Offerings (IPOs)
2.103 Banks should ensure that no advances exceed the limit of Rs. 10 lakhs
to any individual against security of shares, convertible bonds, convertible
debentures, units of equity oriented mutual funds and PSU bonds for subscribing
to IPOs. Further, the Bank should not extend any credit or financing to
Corporates for investment in other companies' IPOs and to NBFCs for further
lending to individuals for IPOs.
Bank Finance to assist employees to buy shares of their own companies
2.104
(i) Banks may extend finance to employees for purchasing shares of their own
companies under Employees Stock Option Plan (ESOP)/ reserved by way
of employees' quota under IPO to the extent of 90% of the purchase price
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Advances-Other than Agriculture
of the shares or Rs. 20.00 lakh, whichever is lower. Banks are not allowed
to extend advances including advances to their employees/ Employees'
Trusts set up by them for the purpose of purchasing their own banks' share
under ESOPs/IPOs or from the secondary market irrespective of whether
the advances are secured or unsecured. Follow on Public Offers (FPOs)
will also be included under IPO.
(ii) Banks should obtain declaration from the borrower indicating the details of
the loan/advances availed against shares and other securities specified
above, from any other bank/s in order to ensure compliance with the
ceilings prescribed for the purpose.
Advances to other borrowers against shares / debentures / bonds
2.105
(i) The question of granting advances against Primary Security of shares and
debenture including promoters' shares to industrial, corporate or other
borrowers should not normally arise except for secured loans granted
towards working capital or for other productive purposes other than NBFCs.
In such cases, Banks should accept shares only in dematerialised form.
Banks may accept shares of promoters only in dematerialized form
wherever demat facility is available. The question of granting advances
against Primary Security of shares and debenture including promoters'
shares to industrial, corporate or other borrowers should not normally arise
except for secured loans granted towards working capital or for other
productive purposes other than NBFCs. In such cases, Banks should
accept shares only in dematerialised form. Banks may accept shares of
promoters only in dematerialised form wherever demat facility is available.
(ii) Banks may obtain collateral security of shares and debentures by way of
margin for a temporary period of one year from borrowers other than
NBFCs who are in the course of setting up of new projects or expansion of
existing business or for the purpose of raising additional working capital
required by units Banks have to satisfy themselves regarding the capacity
of the borrower to raise the required funds and to repay the advance within
the stipulated period.
Bank Loans for Financing Promoters Contribution
2.106 The promoters' contribution towards the equity capital of a company
should come from their own resources and the bank should not normally grant
advances to take up shares of other companies. However, banks are permitted
to extend loans to corporate against the security of shares (as far as possible in
dematerialised form) held by them to meet the promoters' contribution to the
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Guidance Note on Audit of Banks (Revised 2019)
equity of new companies in anticipation of raising resources subject to the
following terms and conditions and as detailed in the loan policy of the bank, in
addition to the general guidelines given in para 2.3.1.14 of the Master Circular on
Loans and Advances Statutory and Other restrictions dated July 1, 2015.
i) The margin and period of repayment of the loans may be determined by the
banks.
ii) Loans sanctioned to corporates against the security of shares (as far as
possible, demat shares) for meeting promoters' contribution to the equity of
new companies in anticipation of raising resources, should be treated as a
bank's investments in shares which would thus come under the ceiling of 40
percent of the bank's net worth as on March 31 of the previous year
prescribed for the bank's total exposure including both fund based and non-
fund based to capital market in all forms. These loans will also be subject to
individual/group of borrowers exposure norms as well as the statutory limit
on shareholding in companies, as detailed in the Master Circular RBI/2015-
16/70 DBR.No.Dir.BC.12/13.03.00/2015-16 dated July 1, 2015 on
Exposure Norms.
iii) Banks may extend financial assistance to Indian companies for acquisition
of equity in overseas joint ventures / wholly owned subsidiaries or in other
overseas companies, new or existing, as strategic investment, in terms of a
Board approved policy, duly incorporated in the loan policy of the banks.
Such policy should include overall limit on such financing, terms and
conditions of eligibility of borrowers, security, margin, etc. The finance
would be subject to compliance with the statutory requirements under
Section 19(2) of the Banking Regulation Act, 1949.
iv) The restriction on grant of bank advances for financing promoters'
contribution towards equity capital would also extend to bank finance to
activities related to such acquisitions like payment of non-compete fee, etc.
Further, these restrictions would also be applicable to bank finance to such
activities by overseas branches / subsidiaries of Indian banks.
v) With the approval of the Board of Directors, the banks should formulate
internal guidelines with appropriate safeguards for this purpose.
vi) Under the refinance scheme of Export-Import Bank of India, the banks may
sanction term loans on merits to eligible Indian promoters for acquisition of
equity in overseas joint ventures / wholly owned subsidiaries, provided the
term loans have been approved by the EXIM Bank for refinance.
Advances against Units of Mutual Funds
2.107 While granting advances against Units of mutual funds, the banks
should adhere to the following guidelines:
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Advances-Other than Agriculture
i) The Units should be listed in the Stock Exchanges or repurchase facility for
the Units of mutual fund should be available at the time of lending.
ii) The Units should have completed the minimum lock-in-period stipulated in
the relevant scheme.
iii) The amount of advances should be linked to the Net Asset Value (NAV) /
repurchase price or the market value, whichever is less and not to the face
value.
iv) Advance against units of mutual funds (except units of exclusively debt
oriented funds) would attract the quantum and margin requirements as
applicable to advance against shares and debentures. However, the
quantum and margin requirement for loans/ advances to individuals against
units of exclusively debt-oriented mutual funds may be decided by
individual banks themselves in accordance with their loan policy.
v) The advances should be purpose oriented, taking into account the credit
requirement of the investor. Advances should not be granted for subscribing
to or boosting up the sales of another scheme of the mutual funds or for the
purchase of shares/ debentures/ bonds etc.
For exposure norms w.r.t. Advances against Mutual Funds, please refer to para
4.6 of the Master Circular on Exposure Norms dated July 1, 2015.
Margin Trading
2.108 Banks may extend finance to stockbrokers for margin trading. The
Board of each bank should formulate detailed guidelines for lending for margin
trading, subject to the following parameters:
(a) The finance extended for margin trading should be within the overall ceiling
of 40% of net worth prescribed for exposure to capital market.
(b) A minimum margin of 50 per cent should be maintained on the funds lent
for margin trading.
(c) The shares purchased with margin trading should be in dematerialised
mode under pledge to the lending bank. The bank should put in place an
appropriate system for monitoring and maintaining the margin of 50% on an
ongoing basis.
(d) The Bank's Board should prescribe necessary safeguards to ensure that no
"nexus" develops between inter-connected stock broking entities/
stockbrokers and the bank in respect of margin trading. Margin trading
should be spread out by the bank among a reasonable number of
stockbrokers and stock broking entities.
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Guidance Note on Audit of Banks (Revised 2019)
2.109 The Audit Committee of the Board should monitor periodically the
bank's exposure by way of financing for margin trading and ensure that the
guidelines formulated by the bank's Board, subject to the above parameters, are
complied with. Banks should disclose the total finance extended for margin
trading in the "Notes on Account" to their Balance Sheet.
Financing for Acquisition of Equity in Overseas Companies
2.110 Banks may extend financial assistance to Indian companies for
acquisition of equity in overseas joint ventures / wholly owned subsidiaries or in
other overseas companies, new or existing, as strategic investment, in terms of a
Board approved policy, duly incorporated in the loan policy of the banks. Such
policy should include overall limit on such financing, terms and conditions of
eligibility of borrowers, security, margin, etc. While the Board may frame its own
guidelines and safeguards for such lending, such acquisition(s) should be
beneficial to the company and the country. The finance would be subject to
compliance with the statutory requirements under Section 19(2) of the Banking
Regulation Act, 1949.
Refinance Scheme of Export Import Bank of India
2.111 Under the refinance scheme of Export Import Bank of India (EXIM
Bank), the banks may sanction term loans on merits to eligible Indian promoters
for acquisition of equity in overseas joint ventures / wholly owned subsidiaries,
provided that the term loans have been approved by the EXIM Bank for
refinance.
Arbitrage Operations
2.112 Banks should not undertake arbitrage operations themselves or extend
credit facilities directly or indirectly to stockbrokers for arbitrage operations in
Stock Exchanges. While banks are permitted to acquire shares from the
secondary market, they should ensure that no sale transaction is undertaken
without actually holding the shares in their investment accounts.
General guidelines applicable to advances against shares / debentures / bonds
2.113 Statutory provisions regarding the grant of advances against shares
contained in Sections 19(2) and (3) and 20(1) (a) of the Banking Regulation Act
1949 should be strictly observed. Shares held in dematerialised form should also
be included for the purpose of determining the limits under Section 19(2) and
19(3) ibid.
2.114 While considering grant of advances against shares / debentures banks
must follow the normal procedures for the sanction, appraisal and post sanction
follow-up.
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Advances-Other than Agriculture
2.115 Advances against the primary security of shares / debentures / bonds
should be kept distinct and separate and not combined with any other advance.
2.116 Banks should satisfy themselves about the marketability/realisability of
the shares / debentures and the net worth and working of the company whose
shares / debentures / bonds are offered as security.
2.117 Shares/ debentures/ bonds should be valued at prevailing market prices
when they are lodged as security for advances.
2.118 Banks should exercise particular care when advances are sought
against large blocks of shares by a borrower or a group of borrowers. It should
be ensured that advances against shares are not used to enable the borrower to
acquire or retain a controlling interest in the company/ companies or to facilitate
or retain inter-corporate investments.
2.119 No advance against partly paid shares shall be granted.
2.120 No loans to be granted to partnership/ proprietorship concerns against
the primary security of shares and debentures.
2.121 Whenever the limit/limits of advances granted to a borrower exceed
Rupees ten lakhs, it should be ensured that the said shares / debentures / bonds
are transferred in the bank's name and that the bank has exclusive and
unconditional voting rights in respect of such shares. For this purpose the
aggregate of limits against shares/ debentures/ bonds granted by a bank at all its
offices to a single borrower should be taken into account. Where securities are
held in dematerialised form, the requirement relating to transfer of shares in
bank's name will not apply and banks may take their own decision in this regard.
2.122 Whenever the limit/limits of advances granted to a borrower exceed
Rupees ten lakhs, it should be ensured that the said shares / debentures / bonds
are transferred in the bank's name and that the bank has exclusive and
unconditional voting rights in respect of such shares. For this purpose the
aggregate of limits against shares / debentures / bonds granted by a bank at all
its offices to a single borrower should be taken into account. Where securities are
held in dematerialised form, the requirement relating to transfer of shares in
bank's name will not apply and banks may take their own decision in this regard.
Banks should, however, avail of the facility provided in the depository system for
pledging securities held in dematerialised form under which the securities
pledged by the borrower get blocked in favour of the lending bank. In case of
default by the borrower and on the bank exercising the option of invocation of
pledge, the shares and debentures get transferred in the bank's name
immediately.
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Guidance Note on Audit of Banks (Revised 2019)
2.123 Banks may take their own decision in regard to exercise of voting rights
and may prescribe procedures for this purpose.
2.124 Banks should ensure that the scrip lodged with them as security are not
stolen / duplicate / fake / benami. Any irregularities coming to their notice should
be immediately reported to RBI.
2.125 Banks operating in India should not be a party to transactions such as
making advances or issuing back-up guarantees favouring other banks for
extending credit to clients of Indian nationality / origin by some of their overseas
branches, to enable the borrowers to make investments in shares and
debentures / bonds of Indian companies.
2.126 A uniform margin of 50% shall be applied on all advances against
shares/financing of IPOs/issue of Guarantees. A minimum cash margin of 25%
(within margin of 50%) shall be maintained in respect of guarantees issued by
banks for capital market operations. These margin requirements will also be
applicable in respect of bank finance to stock brokers by way of temporary
overdrafts for DVP transactions.
Advances against Fixed Deposit Receipts issued by Other Banks
2.127 There have been instances where fake term deposit receipts, purported
to have been issued by some banks, were used for obtaining advances from
other banks. In the light of these happenings, RBI has advised the banks to
desist from sanctioning advances against FDRs, or other term deposits of other
banks.
Advances to Agents/Intermediaries Based on Consideration of Deposit
Mobilisation
2.128 Banks should desist from being party to unethical practices of raising
of resources through agents/intermediaries to meet the credit needs of the
existing/prospective borrowers or from granting loans to the intermediaries,
based on the consideration of deposit mobilisation, who may not require the
funds for their genuine business requirements.
Loans Against Certificate of Deposits (CDs)
2.129 Banks cannot grant loans against CDs. Furthermore, they are also not
permitted to buy-back their own CDs before maturity. However, these
restrictions on lending and buy back in respect of CDs held by mutual funds
are relaxed. While granting such loans to the mutual funds, banks should keep
in view the provisions of paragraph 44(2) of the SEBI (Mutual Funds)
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Advances-Other than Agriculture
Regulations, 1996. Further, such finance if extended to equity-oriented mutual
funds, will form part of banks' capital market exposure, as hitherto.
Finance for and Loans/Advances against Indian Depository Receipts (IDRs)
2.130 Banks are not permitted to grant any loan / advance for subscription to
Indian Depository Receipts (IDRs). Further, no loans/ advances can be granted
against security / collateral of IDRs issued in India.
Bank Finance to Non-Banking Financial Companies (NBFCs)
2.131 The RBI, vide its Master Circular No. DBR.BP.BC.No.5/21.04.172/
2015-16 on Bank Finance to Non-Banking Financial Companies (NBFCs) dated
July 1, 2015 provides as follows:
2.132 The ceiling on bank credit linked to Net Owned Fund (NOF) of NBFCs
has been withdrawn in respect of all NBFCs which are statutorily registered
with RBI and are engaged in principal business of asset financing, loan,
factoring and investment activities. Accordingly, banks may extend need based
working capital facilities as well as term loans to all NBFCs registered with RBI
and engaged in infrastructure financing, equipment leasing, hire-purchase,
loan, factoring and investment activities.
2.133 In the light of the experience gained by NBFCs in financing second
hand assets, banks may also extend finance to NBFCs against second hand
assets financed by them.
2.134 Banks may formulate suitable loan policy with the approval of their
Boards of Directors within the prudential guidelines and exposure norms
prescribed by the Reserve Bank to extend various kinds of credit facilities to
NBFCs subject to the condition that the activities indicated in the Master
Circular are not financed by them.
2.135 In respect of NBFCs which do not require to be registered with RBI,
viz.:
i) Insurance Companies registered under Section 3 of the Insurance Act,
1938;
ii) Nidhi Companies notified under Section 406 of the Companies Act, 2013;
iii) Chit Fund Companies carrying on Chit Fund business as their principal
business as per Explanation to Clause (vii) of Section 45-I(bb) of the
Reserve Bank of India Act, 1934;
iv) Stock Broking Companies / Merchant Banking Companies registered
under Section 12 of the Securities & Exchange Board of India Act; and
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Guidance Note on Audit of Banks (Revised 2019)
v) Housing Finance Companies being regulated by the National Housing
Bank (NHB) which have been exempted from the requirement of
registration by RBI], banks may take their credit decisions on the basis of
usual factors like the purpose of credit, nature and quality of underlying
assets, repayment capacity of borrowers as also risk perception, etc.
2.136 Banks are prohibited from providing credit for the following activities of
NBFCs:
(i) Bills discounted/rediscounted by NBFCs, except for rediscounting of bills
discounted by NBFCs arising from the sale of
(a) commercial vehicles (including light commercial vehicles), and
(b) two-wheeler and three-wheeler vehicles, subject to the following
conditions:
the bills should have been drawn by the manufacturers on dealers
only.
the bills should represent genuine sale transactions as may be
ascertained from the chassis/engine numbers.
before rediscounting the bills, banks should satisfy themselves
about the bona fides and track record of NBFCs which have
discounted the bills.
(ii) Investments of NBFCs both of current and long term nature, in any
company/entity by way of shares, debentures, etc. However, Stock Broking
Companies may be provided need-based credit against shares and
debentures held by them as stock-in-trade.
(iii) Unsecured loans/inter-corporate deposits by NBFCs to/in any company.
(iv) All types of loans/advances by NBFCs to their subsidiaries, group
companies/entities.
(v) Finance to NBFCs for further lending to individuals for subscribing to Initial
Public Offerings (IPOs) and for purchase of shares from secondary market.
Bank Finance to Residuary Non-Banking Companies (RNBCs)
2.137 Residuary Non-Banking Companies (RNBCs) are also required to be
mandatorily registered with RBI. In respect of such companies registered with
RBI, bank finance would be restricted to the extent of their Net Owned Fund
(NOF). The computation of NOF will be as per definition of NOF as given in the
explanation to Section 45-IA of the Reserve Bank of India Act, 1934.
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Advances-Other than Agriculture
Bridge loans / interim finance to NBFCs
2.138 Banks should not grant bridge loans of any nature, or interim finance
against capital / debenture issues and / or in the form of loans of a bridging
nature pending raising of long-term funds from the market by way of capital,
deposits, etc. to all categories of Non-Banking Financial Companies, i.e.,
equipment leasing and hire-purchase finance companies, loan and investment
companies and also Residuary Non-Banking Companies (RNBCs).
2.139 Banks should strictly follow these instructions and ensure that these
are not circumvented in any manner whatsoever by purport and / or intent by
sanction of credit under a different nomenclature like unsecured negotiable
notes, floating rate interest bonds, etc., as also short-term loans, the
repayment of which is proposed / expected to be made out of funds to be or
likely to be mobilised from external / other sources and not out of the surplus
generated by the use of the asset(s).
Advances against collateral security of shares to NBFCs
2.140 Shares and debentures cannot be accepted as collateral securities for
secured loans granted to NBFCs borrowers for any purpose.
Restriction on Guarantees for placement of funds with NBFCs
2.141 Banks should not execute guarantees covering inter-company
deposits / loans thereby guaranteeing refund of deposits / loans accepted by
NBFCs / firms from other NBFCs / firms. The restriction would cover all types
of deposits / loans irrespective of their source, including deposits / loans
received by NBFCs from trusts and other institutions. Guarantees should not
be issued for the purpose of indirectly enabling the placement of deposits with
NBFCs.
Bank Finance to Equipment Leasing Companies
2.142 Banks should not enter into lease agreements departmentally with
equipment leasing companies as well as other Non-Banking Financial
Companies engaged in equipment leasing.
Bank Finance to Factoring Companies
2.143 Banks are permitted to extend financial assistance to support the
factoring business of Factoring Companies which comply with the following
criteria:
(a) The companies qualify as factoring companies and carry out their business
under the provisions of the Factoring Regulation Act, 2011 and Notifications
issued by the Reserve Bank in this regard from time to time.
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Guidance Note on Audit of Banks (Revised 2019)
(b) They derive at least 75 per cent of their income from factoring activity.
(c) The receivables purchased / financed, irrespective of whether on 'with
recourse' or 'without recourse' basis, form at least 75 per cent of the assets
of the Factoring Company.
(d) The assets / income referred to above would not include the assets / income
relating to any bill discounting facility extended by the Factoring Company.
(e) The financial assistance extended by the Factoring Companies is secured
by hypothecation or assignment of receivables in their favour.
(f) Banks offering factoring services may decide percentage of the invoice to be
paid upfront based on their own assessment of the credit worthiness of the
assignor / buyer, due diligence carried out by them and other commercial
considerations.
(g) Factoring transactions on `with recourse' basis shall be eligible for priority
sector classification by banks, which are carrying out the business of
factoring departmentally. The factoring transactions taking place through
TReDS shall also be eligible for classification under priority sector upon
operationalization of the platform. For detailed guidelines, refer RBI circular
FIDD.CO.Plan.BC.10/04.09.01/2016-17 on "Priority Sector Lending status
for Factoring Transactions"
Restrictions regarding investments made by banks in securities/ instruments
issued by NBFCs
2.144 Banks should not invest in Zero Coupon Bonds (ZCBs) issued by
NBFCs unless the issuer NBFC builds up sinking fund for all accrued interest and
keeps it invested in liquid investments / securities (Government bonds).
2.145 Banks are permitted to invest in Non-Convertible Debentures (NCDs)
with original or initial maturity up to one year issued by NBFCs. However, while
investing in such instruments banks should be guided by the extant prudential
guidelines in force, ensure that the issuer has disclosed the purpose for which
the NCDs are being issued in the disclosure document and such purposes are
eligible for bank finance in terms of instructions given in the preceding
paragraphs.
Advances Against NR(E) and FCNR(B) Deposits
2.146 Grant of advance against NR(E) and FCNR(B) deposits would be
subject to the guidelines issued under Foreign Exchange Management Act,
1999.
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Advances-Other than Agriculture
Advances Against Bullion/Primary Gold
2.147 Banks are prohibited from granting any advance against bullion/
primary gold. However, specially minted gold coins sold by banks are not
treated as "bullion" or "primary gold" and hence the same is acceptable as
security upto 50 gms per customer. Such loans to be granted by the bank, may
be covered under the policy framed by the bank's Board, in terms of RBI
circular DBOD.No. BC. 138/21.01.023/94 dated November 22, 1994. Further,
for cases wherein advances have been granted against the gold coins it should
be ensured that the end use of funds is for approved, non- speculative
purposes. Banks are also required to desist from granting advances to silver
bullion dealers which are likely to be utilised for speculative purposes.
Loans for Acquisition of KVPs
2.148 The grant of loans for acquiring/investing in KVPs does not promote
fresh savings and, rather, channelises the existing savings in the form of bank
deposits to small savings instruments and thereby defeats the very purpose of
such schemes. Banks should therefore ensure that no loans are sanctioned for
acquisition of/investing in Small Savings Instruments including Kisan Vikas
Patras.
Advances against Gold Ornaments & Jewellery
2.149 The RBI vide its Master Circular No. RBI/2015-16/95
DBR.No.Dir.BC.10/ 13.03.00/2015-16 dated July 1, 2015 provides that
hallmarking of gold jewellery ensures the quality of gold used in the jewellery as
to carat fineness and purity. Hence, banks find granting of advances against the
security of such hallmarked jewellery safer and easier. Preferential treatment is
given to loans against hallmarked jewellery which will also be in the long-term
interest of consumer, lenders and the industry. Based on gold purity and content
the bank decides on the margin and rates of interest.
Loan to Value Ratio for Loan against Gold Ornaments & Jewellery
2.150 The RBI vide its Master Circular No. RBI/2015-16/95 DBR.No.Dir.BC.
10/13.03.00/2015-16 dated July 1, 2015 provides that loans (including bullet
repayment loans) sanctioned by banks against pledge of gold ornaments and
jewellery for non-agricultural purposes should not exceed 75 per cent of the
value of gold ornaments and jewellery.
2.151 In order to standardize the valuation and make it more transparent to
the borrower, gold ornaments and jewellery accepted as security / collateral will
have to be valued at the average of the closing price of 22 carat gold for the
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Guidance Note on Audit of Banks (Revised 2019)
preceding 30 days as quoted by the India Bullion and Jewellers Association Ltd.
[Formerly known as the Bombay Bullion Association Ltd. (BBA)]. If the gold is of
purity less than 22 carats, the bank should translate the collateral into 22 carat
and value the exact grams of the collateral. In other words, jewellery of lower
purity of gold shall be valued proportionately.
2.152 Loans extended against pledge of gold ornaments and jewellery for
other than agricultural purposes, where both interest and principal are due for
payment at maturity of the loan will be subject to the following conditions:
(i) Banks, as per their Board approved policy, may decide upon the ceiling with
regard to the quantum of loan that may be granted against the pledge of
gold jewellery and ornaments for non-agricultural end uses.
(ii) The period of the loan shall not exceed 12 months from the date of
sanction.
(iii) Interest will be charged to the account at monthly rests and may be
recognized on accrual basis provided the account is classified as `standard'
account. This will also apply to existing loans.
(iv) Such loans shall also be governed by other extant norms pertaining to
income recognition, asset classification and provisioning which shall be
applicable once the principal and interest become overdue.
Gold (Metal) Loans
2.153 Presently, nominated banks can extend Gold (Metal) Loans to exporters
of jewellery who are customers of other scheduled commercial banks, by
accepting stand-by letter of credit or bank guarantee issued by their bankers in
favour of the nominated banks subject to authorised banks' own norms for
lending and other conditions stipulated by RBI. Banks may also extend the facility
to domestic jewellery manufacturers, subject to the conditions as specified by
RBI's Master Circular RBI/2015-16/95 DBR.No.Dir.BC.10/13.03.00/2015-16
dated July 1, 2015 on Loans and Advances- Statutory and Other restrictions.
2.154 The nominated banks may continue to extend Gold (Metal) Loans to
jewellery exporters subject to the following conditions:
The exposure assumed by the nominated bank extending the Gold (Metal)
Loan against the stand-by LC / BG of another bank will be deemed as an
exposure on the guaranteeing bank and attract appropriate risk weight as
per the extant guidelines.
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Advances-Other than Agriculture
The transaction should be purely on back-to-back basis i.e. the nominated
banks should extend Gold (Metal) Loan directly to the customer of a non-
nominated bank, against the stand-by LC / BG issued by the latter.
Gold (Metal) Loans should not involve any direct or indirect liability of the
borrowing entity towards foreign suppliers of gold.
The banks may calculate their exposure and compliance with prudential
norms daily by converting into Rupee the gold quantity by crossing London
AM fixing for Gold / US Dollar rate with the rupee-dollar reference rate
announced by RBI.
2.155 Banks should recognise the overall risks in extending Gold (Metal)
Loans as also in extending SBLC / BG. Banks should lay down an appropriate
risk management / lending policy in this regard and comply with the
recommendations of the Ghosh Committee and other internal requirements
relating to acceptance of guarantees of other banks to obviate the possibility of
frauds in this area.
2.156 Nominated banks are not permitted to enter into any tie up
arrangements for retailing of gold / gold coins with any other entity including non-
banking financial companies / co-operative banks / non-nominated banks.
Loans and advances to Micro and Small Enterprises (MSEs)
2.157 The Reserve Bank of India has issued Master Directions on Lending
to Micro, Small & Medium Enterprises (MSME) sector vide Master Directions
no.FIDD. MSME & NFS.12/ 06.02.31/2017-18 dated July 24, 2017 (Updated
April 25, 2018), in which definition of MSME and common
guidelines/instructions for lending to MSME section have been given.
Working Capital Finance to Information Technology and Software Industry
2.158 Following the recommendations of the "National Taskforce on
Information Technology and Software Development", Reserve Bank has
framed guidelines for extending working capital to the said industry. Banks are,
however, free to modify the guidelines based on their own experience without
reference to the Reserve Bank of India to achieve the purpose of the guidelines
in letter and spirit. The salient features of these guidelines are set forth below:
(i) Banks may consider sanction of working capital limits based on the track
record of the promoter's group affiliation, composition of the management
team and their work experience as well as the infrastructure.
(ii) In the case of the borrowers with working capital limits of up to Rs 2 crore,
assessment may be made at 20 percent of the projected turnover.
However, in other cases, the banks may consider assessment of MPBF on
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Guidance Note on Audit of Banks (Revised 2019)
the basis of the monthly cash budget system. For the borrowers enjoying
working capital limits of Rs 10 crore and above from the banking system,
the guidelines regarding the loan system would be applicable.
(iii) Banks may obtain collateral security wherever available. First/ second
charge on current assets, if available, may be obtained.
(iv) The rate of interest as prescribed for general category of borrowers may
be levied. Concessional rate of interest as applicable to pre-shipment/post-
shipment credit may be levied.
(v) Banks may evolve tailor-made follow up system for such advances. The
banks could obtain quarterly statements of cash flows to monitor the
operations. In case the sanction was not made on the basis of the cash
budgets, they can devise a reporting system, as they deem fit.
Guidelines for bank finance for PSU disinvestments of Government of India
2.159 In terms of RBI circular DBOD No. Dir.BC.90/13.07.05/98 dated August
28, 1998, banks have been advised that the promoters' contribution towards the
equity capital of a company should come from their own resources and the bank
should not normally grant advances to take up shares of other companies. Banks
were also advised to ensure that advances against shares were not used to
enable the borrower to acquire or retain a controlling interest in the
company/companies or to facilitate or retain inter-corporate investment. It is
clarified that the aforesaid instructions of the 1998 circular would not apply in the
case of bank finance to the successful bidders under the PSU disinvestment
programme of the Government, subject to the following:
Banks' proposals for financing the successful bidders in the PSU
disinvestment programme should be approved by their Board of Directors.
Bank finance should be for acquisition of shares of PSU under a
disinvestment programme approved by Government of India, including the
secondary stage mandatory open offer, wherever applicable and not for
subsequent acquisition of the PSU shares. Bank finance should be made
available only for prospective disinvestments by Government of India.
The companies, including the promoters, to which bank finance is to be
extended, should have adequate net worth and an excellent track record of
servicing loans availed from the banking system.
The amount of bank finance thus provided should be reasonable with
reference to the banks' size, its net worth and business and risk profile.
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2.160 In case the advances against the PSU disinvestment is secured by the
shares of the disinvested PSUs or any other shares, banks should follow RBI's
extant guidelines on capital market exposures on margin, ceiling on overall
exposure to the capital market, risk management and internal control systems,
surveillance and monitoring by the Audit Committee of the Board, valuation and
disclosure, etc. In this regard, banks may be guided by the Master Circular on
Exposure Norms dated July 1, 2015.
Stipulation of lock-in period for shares
2.161 Banks may extend finance to the successful bidders even though the
shares of the disinvested company acquired/ to be acquired by the successful
bidder are subjected to a lock-in period/ other such restrictions which affect their
liquidity, subject to fulfillment of following conditions:
(a) The documentation between the Government of India and the successful
bidder should contain a specific provision permitting the pledgee to liquidate
the shares even during lock-in period that may be prescribed in respect of
such disinvestments, in case of shortfall in margin requirements or default by
the borrower.
(b) If the documentation does not contain such a specific provision, the borrower
(successful bidder) should obtain waiver from the Government for disposal
of shares acquired under PSU disinvestment programme during the lock-in
period.
2.162 As per the terms and conditions of the PSU disinvestments by the
Government of India, the pledgee bank will not be allowed to invoke the pledge
during the first year of the lock-in period. During the second and third year of the
lock-in period, in case of inability of the borrower to restore the margin prescribed
for the purpose by way of additional security or non-performance of the payment
obligations as per the repayment schedule agreed upon between the bank and
the borrower, the bank would have the right to invoke the pledge. The pledgee
bank's right to invoke the pledge during the second and third years of the lock-in
period, would be subject to the terms and conditions of the documentation
between Government and the successful bidder, which might also cast certain
responsibilities on the pledge banks.
2.163 RBI has also clarified that the concerned bank must make a proper
appraisal and exercise due caution about creditworthiness of the borrower and
the financial viability of the proposal. The bank must also satisfy itself that the
proposed documentation, relating to the disposal of shares pledged with the
bank, are fully acceptable to the bank and do not involve unacceptable risks on
the part of the bank.
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2.164 Further, in terms of IECD Circular No. 10/ 08.12.01/ 2000- 2001 dated 8
January 2001, banks are precluded from financing investments of NBFCs in
other companies and inter-corporate loans / deposits to/ in other companies.
However, the Special Purpose Vehicles (SPVs) which comply with the following
conditions would not be treated as investment companies and therefore would
not be considered as NBFCs:
a) They function as holding companies, special purpose vehicles, etc., with not
less than 90 per cent of their total assets as investment in securities held for
the purpose of holding ownership stake;
b) They do not trade in these securities except for block sale;
c) They do not undertake any other financial activities; and
d) They do not hold/accept public deposits.
Financing Housing Projects
2.165 During the recent period, housing sector has emerged as one of the
biggest loan portfolios of banks. The focus of the RBI, therefore, is to ensure
orderly growth of this portfolio. The Master Circular No.DBR.No.DIR.BC.13/
08.12.001/2015-16 dated July 1, 2015 on Housing Finance provides guidance
in respect of the housing finance provided by the banks. Banks could deploy
their funds under the housing finance allocation in any of the three categories
as per the norms provided in the Master Circular, i.e.
Direct Finance.
Indirect Finance.
Investment in Bonds of NHB/HUDCO, or combination thereof.
2.166 The Master Circular also contains a number of guidelines for this
purpose, including conditions wherein a bank cannot extend credit for housing
purposes. These conditions are as follows:
(i) In case of lending to housing intermediary agencies, the banks are
required to ensure that the former have complied with the guidelines of the
National Housing Board (NHB). In terms of the NHB guidelines, a housing
finance companies' total borrowings, whether by way of deposits, issue of
debentures/ bonds, loans and advances from banks or from financial
institutions including any loans obtained from NHB, should not exceed 16
times of their net owned funds. (i.e., paid up capital and free reserves less
accumulated balance of loss, deferred revenue expenditure and intangible
assets.)
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(ii) Banks are also not permitted to extend fund based or non-fund based
facilities to private builders for acquisition of land even as part of a housing
project.
(iii) Banks cannot grant finance for construction of buildings meant purely for
Government/Semi-Government offices, including Municipal and Panchayat
offices. However, banks may grant loans for activities, which will be
refinanced by institutions like NABARD.
(iv) Projects undertaken by public sector entities which are not corporate bodies
(i.e., public sector undertakings which are not registered under Companies
Act or which are not Corporations established under the relevant statute)
also cannot be financed by banks.
(v) In terms of the orders of the Delhi High Court, banks also cannot grant loans
in respect of:
Properties which fall in the category of unauthorised colonies unless
and until they have been regularised and development and other
charges paid.
Properties which are meant for residential use but which the applicant
intends to use for commercial purposes and declares so while applying
for the loan.
Loan to Value (LTV) ratio
2.167 In order to prevent excessive leveraging, the LTV ratio and risk weight
and standard as set provisioning in respect of individual housing loans have
been prescribed. Vide RBI circular dated June 7, 2017 revised LTV ratio is
applicable for all loan sanctioned post June 7, 2017 is as under.
Category of loan LTV ratio (%) Risk Weight (%)
Upto 30 lakh 80 35
> 80 and 90 50
Above 30 lakh and upto 75 80 35
lakh
Above 75 lakh 75 50
2.168 The LTV ratios, Risk Weights and Standard Asset Provision set out in
the circular DBR.BP.BC.No.44/08.12.015/ 2015-16 dated October 8, 2015, on
the captioned subject, shall continue to apply to loans sanctioned up to June 6,
2017.
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Category of loan LTV ratio (%) Risk Weight (%)
Upto 30 lakh 80 35
> 80 and 90 50
Above 30 lakh and upto 75 lakh 75 35
> 75 and 80 50
Above 75 lakh 75 75
2.169 The LTV ratio should not exceed the prescribed ceiling in all fresh
cases of sanction. In case the LTV ratio is currently above the ceiling
prescribed for any reasons, efforts should be made to bring it within limits.
Waiver of EMI in case of regular payment of home loans
2.170 It has been observed that some banks have introduced certain
incentive to home loans from regular payment of EMI/dues. As per the feature,
the borrower gets waiver of some EMI amount either at the end of the loan or
on some periodical basis. The auditor needs to ensure that the bank has made
sufficient provision for future waiver of EMI in the books in the books.
Innovative Housing Loan Products Upfront Disbursal of Housing Loans
2.171 It has been observed that some banks have introduced certain
innovative Housing Loan Schemes in association with developers / builders, e.g.
upfront disbursal of sanctioned individual housing loans to the builders without
linking the disbursals to various stages of construction of housing project, interest
/ EMI on the housing loan availed of by the individual borrower being serviced by
the builders during the construction period / specified period, etc. This might
include signing of tripartite agreements between the bank, the builder and the
buyer of the housing unit.
2.172 These loan products are popularly known by various names like 80:20,
75:25 Schemes. Such housing loan products are likely to expose the banks as
well as their home loan borrowers to additional risks e.g. in case of disputes
between individual borrowers and developers / builders, default / delayed
payment of interest / EMI by the developer / builder during the agreed period on
behalf of the borrower, non-completion of the project on time, etc. Further, any
delayed payments by developers / builders on behalf of individual borrowers to
banks may lead to lower credit rating / scoring of such borrowers by credit
information companies (CICs) as information about servicing of loans gets
passed on to the CICs on a regular basis. In cases where bank loans are also
disbursed upfront on behalf of their individual borrowers in a lump-sum to
builders / developers without any linkage to stages of construction, banks run
disproportionately higher exposures with concomitant risks of diversion of funds.
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2.173 In view of the higher risks associated with such lump-sum disbursal of
sanctioned housing loans and customer suitability issues, banks are advised that
disbursal of housing loans sanctioned to individuals should be closely linked to
the stages of construction of the housing project / houses and upfront disbursal
should not be made in cases of incomplete / under-construction / green field
housing projects.
2.174 It is emphasized that banks while introducing any kind of product should
take into account the customer suitability and appropriateness issues and also
ensure that the borrowers / customers are made fully aware of the risks and
liabilities under such products.
Retail loans
2.175 The banks generally provide other various retail advances namely:
Home loans and loans against property.
Vehicle loans.
Personal loan.
Consumer durable loans.
Credit cards.
2.176 Generally, loans are either sourced through direct selling agents or
through bank's own branches. The bank has a credit policy which defines
process to be followed for sanction and disbursement of loan and the various
documents required.
2.177 Generally, the credit assessment process is not as detailed as followed
in the corporate loans. The bank generally collects following documents:
Completely filled Loan Application Form with customers' signature.
Income proof like Salary slip, financial statement, Income tax returns, Bank
statement.
Photograph.
Business continuity proof. (e.g. Form D of Maharastra Shops and
Establishment Act, Any other govt. certificate for doing business)
Residence proof.
Identification proof.
Contact Point Mobile No of applicants is mandatory.
Age proof.
PAN Card.
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Guidance Note on Audit of Banks (Revised 2019)
2.178 The banks generally have a system in which various information
collected are inputted. The system generally automatically runs a credit filter
report. The credit Filter report is based on pre-defined criteria as per the credit
policy like minimum income criteria, employment details, age, telephone etc. and
the score are generated from the system.
2.179 As a part of sanction process of the loan, the bank also runs CIBIL
score and if CIBIL score is above specific score than the bank considers for
further sanction.
2.180 The bank also conducts field investigations on the proposed customer
which generally involve residential and office visits. Few banks also have the
process of Fraud Containment Unit (FCU) screening of selected sample of file. At
the FCU, the FCU officer screens through the genuineness and authenticity of
the documents from the perspective of any traces of a fraud.
2.181 Post the above verification by FCU, the bank also initiates the Positive
De dupe check for positive database, wherein if the customer is existing
customer of the bank, the system gets the popup of such links on his screen.
2.182 The credit officer initiates the negative de dupe check on the negative
database through system, Negative De dupe check against the RBI defaulter list,
Terrorist list and declined applications. Such list is uploaded in the system by
Central team of the bank. If the customer is traced under such negative listing
then loan application is rejected by the credit officer in the system. Once, all the
processes are completed and based on the results, the bank sanctions the loan.
Financing of Infrastructure Projects
2.183 The RBI has revised the definition of Infrastructure Lending vide Master
Circular on Loans and Advances Statutory and Other Restrictions dated July 1,
2015 read with Circular No. RBI/2012 13/297/DBOD.BP.BC.No 58/08.12.014/
2012-13 dated 20/11/2012 on "Second Quarter Review of Monetary Policy 2012-
13 - Definition of `Infrastructure Lending". RBI has periodically added certain
sectors as infrastructure lending from time to time.
2.184 The revised definition of `infrastructure lending' will be effective from the
date of this circular. The exposure of banks to projects under sub-sectors which
were included under the previous definition of infrastructure, but not included
under the revised definition, will continue to get the benefits under `infrastructure
lending' for such exposures till the completion of the projects. However, any fresh
lending to those sub-sectors from the date of this circular will not qualify as
`infrastructure lending'.
2.185 The definition of Infrastructure Lending would include credit facility
extended by Lenders (i.e., Banks & Selected AIFIs) to a borrower for exposure in
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the various infrastructure sub-sectors as per paragraph 2.3.7.2 of Master Circular
on Loans and Advances- Statutory and Other Restrictions dated July 1, 2015,
read with Circular No. DBOD.BP.BC.No.66/08.12.2014/2013-14 on "Financing of
Infrastructure Definition of `Infrastructure Lending'" dated November 25, 2013.
2.186 In view of the critical importance of the infrastructure sector and high
priority being accorded for development of various infrastructure services,
Banks/FIs are free to finance technically feasible, financially viable and bankable
projects undertaken by both public sector and private sector undertakings subject
to the following conditions:
i. The amount sanctioned should be within the overall ceiling of the prudential
exposure norms prescribed by RBI for infrastructure financing.
ii. Banks/ FIs should have the requisite expertise for appraising technical
feasibility, financial viability and bankability of projects, with particular
reference to the risk analysis and sensitivity analysis.
iii. In respect of projects undertaken by public sector units, such term loans
should not be in lieu of or to substitute budgetary resources envisaged for
the project. The term loan could supplement the budgetary resources if such
supplementing was contemplated in the project design. Banks/FIs are,
advised to follow the above instructions scrupulously, even while making
investment in bonds of sick State PSUs as part of the rehabilitation effort.
iv. Banks may also lend to SPVs in the private sector, registered under the
Companies Act for directly undertaking infrastructure projects which are
financially viable and not for acting as mere financial intermediaries. Banks
may ensure that the bankruptcy or financial difficulties of the parent/ sponsor
should not affect the financial health of the SPV.
v. In few cases where the completion of the project gets delayed, the RBI vide
its Master Circular No. RBI/2015-16/95 DBR.No.Dir.BC. 2/21.04.048/2015-
16 dated July 1, 2015 provides detailed guideline on the classification and
provision for project loans. The RBI its Circular No. RBI/2016-17/122
DBR.No.BP.BC.34 /21.04.132/2016-17 provides guideline for project
companies where change of ownership are happen/happening and date of
commencement of commercial operation (`DCCO'). Detailed guidelines in
this regard are given in Chapter 4 of Part III of this Guidance Note.
vi. The auditor should obtain the list of all outstanding project loans of the bank.
The details should also include information about original DCCO and
revision of DCCO, if any. The auditor should verify that the revision of the
project DCCO is based on the technical and financial study and is approved
by competent authority. The auditor should also verify the revision in DCCO,
and check whether the same is permissible under the extent RBI guidelines.
Auditor should apply professional judgement and skepticism while
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Guidance Note on Audit of Banks (Revised 2019)
evaluating/ accessing and concluding on compliance of the said guidelines
for deferment of DCCO and retaining standard/standard restructured
classification. To verify compliance of the same, auditor shall obtain
documentary evidences for e.g.: legal documents for Court cases, Lead
engineers report/ Review note/ consortium meeting minutes specifying the
event that is beyond promoter's control etc., as the case may be.
vii. RBI has issued clarification on their mail box on the assessment of project
cost and revision in the project cost. RBI mail box clarification also provides
guidance on classification of loan in case revision of project cost is above
certain percentage of original project cost. The auditor should also ensure
compliance with those clarification.
Types of Financing by Banks
2.187
(i) In order to meet financial requirements of infrastructure projects, banks may
extend credit facility by way of working capital finance, term loan, project
loan, subscription to bonds and debentures/ preference shares/ equity
shares acquired as a part of the project finance package which is treated as
"deemed advance" and any other form of funded or non-funded facility.
(ii) Take-out Financing Banks may enter into take-out financing arrangement
with IDFC/ other financial institutions or avail of liquidity support from IDFC/
other FIs. Banks may also be guided by the instructions regarding take-out
finance contained in Circular No.DBOD.BP.BC.144/21.04.048/2000 dated
February 29, 2000.
(iii) Inter-institutional Guarantees: Banks are permitted to issue guarantees
favouring other lending institutions in respect of infrastructure projects,
provided the bank issuing the guarantee takes a funded share in the project
at least to the extent of 5 per cent of the project cost and undertakes normal
credit appraisal, monitoring and follow-up of the project.
(iv) Financing promoter's equity: In terms of Circular No.DBOD.Dir.BC.90/
13.07.05/98 dated August 28, 1998, Banks were advised that the
promoters' contribution towards the equity capital of a company should
come from their own resources and the bank should not normally grant
advances to take up shares of other companies. In view of the importance
attached to the infrastructure sector, it has been decided that, under certain
circumstances, an exception may be made to this policy for financing the
acquisition of the promoters' shares in an existing company, which is
engaged in implementing or operating an infrastructure project in India. The
conditions, subject to which an exception may be made, are as follows:
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Advances-Other than Agriculture
The bank finance would be only for acquisition of shares of existing
companies providing infrastructure facilities. Further, acquisition of such
shares should be in respect of companies where the existing foreign
promoters (and/ or domestic joint promoters) voluntarily propose to
disinvest their majority shares in compliance with SEBI guidelines,
where applicable.
The companies to which loans are extended should, inter alia, have a
satisfactory net worth.
The company financed and the promoters/ directors of such companies
should not be a defaulter to banks/ FIs.
In order to ensure that the borrower has a substantial stake in the
infrastructure company, bank finance should be restricted to 50% of the
finance required for acquiring the promoter's stake in the company
being acquired.
Finance extended should be against the security of the assets of the
borrowing company or the assets of the company acquired and not
against the shares of that company or the company being acquired. The
shares of the Borrower Company / Company being acquired may be
accepted as additional security and not as primary security. The security
charged to the banks should be marketable.
Banks should ensure maintenance of stipulated margins at all times.
The tenor of the bank loans may not be longer than seven years.
However, the Boards of banks can make an exception in specific cases,
where necessary, for financial viability of the project.
This financing would be subject to compliance with the statutory
requirements under Section 19(2) of the Banking Regulation Act, 1949.
The banks financing acquisition of equity shares by promoters should
be within the regulatory ceiling of 40 per cent of their net worth as on
March 31 of the previous year for the aggregate exposure of the banks
to the capital markets in all forms. (both fund based and non-fund
based)
The proposal for bank finance should have the approval of the Board.
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Guidance Note on Audit of Banks (Revised 2019)
Prudential Exposure Limits
Single and Group Borrower Limits3
2.188 With a view to achieve a better risk management and avoidance of
concentration of credit risk, the RBI from time to time, prescribes, limits on
exposure of a bank to individual borrowers and groups of borrowers in India.
The Master Circular No. RBI/2015-16/70 DBR.No.Dir.BC.12/13.03.00/ 2015-16
dated July 1, 2015 on "Exposure Norms", lays down the ceiling on credit
exposure to individual/group borrowers in relation to bank's capital fund as
defined under capital adequacy standards (Tier-I and Tier-II Capital). The
ceiling on exposure to individual borrowers is 15 per cent of capital funds and
40 per cent in the case of a borrower group. However, exposure to borrowers
belonging to a group may exceed the exposure norms of the 40 per cent of the
bank's capital funds by an additional 10 per cent, provided the additional credit
exposure is on account of extension of credit for infrastructure projects.
Exposure to single borrower may also exceed by 5 per cent, provided the
additional exposure is on account of infrastructure projects. Derivative Products
such as Forward Rate Agreements and Interest Rate Swaps are also captured
for computing exposure by applying the conversion factors to notional principal
amounts. Banks should also include forward contracts in foreign exchange and
other derivative products like currency swaps, options, etc., at their
replacement cost value in determining individual/ group borrower exposure.
The Master Circular on Exposure Norms contains guidelines on calculation of
the credit exposure in derivative products.
2.189 In addition to the exposure limit as permitted above, banks may, in
exceptional circumstances, with the approval of their Boards, consider
enhancement of the exposure to a borrower (single as well as group) upto a
further 5 per cent of capital funds.
2.190 With effect from May 29, 2008, the exposure limit in respect of single
borrower has been raised to twenty five per cent of the capital funds, only in
respect of Oil Companies who have been issued Oil Bonds (which do not have
SLR status) by Government of India. In addition to this, banks may in exceptional
circumstances, consider enhancement of the exposure to the Oil Companies up
to a further 5 per cent of capital funds.
3 RBI vide its circular No. DBOD.No.BP.BC.96/21.06.102/2013-14 on Guidelines on Management
of Intra-Group Transactions and Exposures providing guidelines on Intra-Group Transactions and
Exposures (ITEs) for banks. The guidelines contain quantitative limits on financial ITEs and
prudential measures for the non-financial ITEs to ensure that banks engage in ITEs in safe and
sound manner in order to contain concentration and contagion risks arising out of ITEs. These
guidelines l become effective from October 1, 2014.
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Advances-Other than Agriculture
2.191 Such exposures where the bank has exceeded the prudential
exposure limit should be appropriately disclosed in the "Notes to Accounts" to
the Balance Sheet.
Disinvestment Programme of the Government of India
2.192 On account of banks' financing of acquisition of PSU shares under the
Government of India disinvestment programmes, if any bank, is likely to
exceed the regulatory ceiling of single / group borrower limit, RBI will consider
relaxation on specific requests from banks in the single/group credit exposure
norms on a case by case basis, provided that the bank's total exposure to the
borrower, net of its exposure due to acquisition of PSU shares under the
Government of India disinvestment programme, should be within the prudential
single/group borrower exposure ceiling prescribed by RBI.
Sector Specific Limit
2.193 Apart from limiting the exposures to an individual or a borrower group
as indicated above, banks may also consider fixing internal limits for aggregate
commitments to specific sectors, e.g. textiles, jute, tea, etc., so that the
exposures are evenly spread over various sectors. These limits could be fixed
by the banks having regard to the performance of different sectors and the
risks perceived. The limits so fixed may be reviewed periodically and revised,
as necessary.
Lending to NBFCs
2.194 The exposure (both lending and investment, including off balance
sheet exposures) of a bank to a single NBFC / NBFC-AFC (Asset Financing
Companies) should not exceed 10% / 15% respectively, of the bank's capital
funds as per its last audited balance sheet. Banks may, however, assume
exposures on a single NBFC / NBFC-AFC up to 15%/20% respectively, of their
capital funds provided the exposure in excess of 10%/15% respectively, is on
account of funds on-lent by the NBFC / NBFC-AFC to the infrastructure sector.
Exposure of a bank to Infrastructure Finance Companies (IFCs) should not
exceed 15% of its capital funds as per its last audited balance sheet, with a
provision to increase it to 20% if the same is on account of funds on-lent by the
IFCs to the infrastructure sector. Further, banks may also consider fixing
internal limits for their aggregate exposure to all NBFCs put together. Infusion
of capital funds after the published balance sheet date may also be taken into
account for the purpose of computing exposure ceiling. Banks should obtain an
external auditor's certificate on completion of the augmentation of capital and
submit the same to the Reserve Bank of India (Department of Banking
Supervision) before reckoning the additions to capital funds.
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Bills Purchased/Discounted under Letter of Credit
2.195 In cases where the bills discounting/purchasing/negotiating bank and
LC issuing bank are different entities, bills purchased/ discounted/ negotiated
under L/C (where payment to the beneficiary is not "under reserve") is to be
treated as an exposure on L/C issuing bank and not on borrower. In the case of
negotiations "under reserve", the exposure will be treated as an exposure on
the borrower. However, in cases where the bills discounting/purchasing/
negotiating bank and LC issuing bank are part of the same bank, i.e. where LC
is issued by the Head Office or branch of the same bank, then the exposure
should be taken on the third party/borrower and not on the LC issuing bank.
Unhedged Foreign Currency Exposure of Corporates
2.196 To ensure that each bank has a policy that explicitly recognises and
takes account of risks arising out of foreign exchange exposure of their clients,
foreign currency loans above US$ 10 million, or such lower limits as may be
deemed appropriate vis-à-vis the banks' portfolios of such exposures, should be
extended by banks only on the basis of a well laid out policy of their Boards with
regard to hedging of such foreign currency loans. Further, the policy for hedging,
to be framed by their Boards, may consider, as appropriate for convenience,
excluding the following:
Where forex loans are extended to finance exports, banks may not insist
on hedging but assure themselves that such customers have uncovered
receivables to cover the loan amount.
Where the forex loans are extended for meeting forex expenditure.
2.197 Banks may also consider stipulating a limit on unhedged position of
corporates on the basis of bank's Board approved policy. In this context,
attention of the readers is also invited to RBI's Circular No.
DBOD.No.BP.BC.85/21.06.200/2013-14 on "Capital and Provisioning
Requirements for Exposures to entities with Unhedged Foreign Currency
Exposure" dated January 15, 2014 and clarification DBOD.No.BP.BC.116/
21.06.200/2013-14 dated June 3, 2014 providing requirements for exposures to
entities with unhedged foreign currency exposure.
2.198 The auditor while carrying out the audit of the Unhedged Foreign
Currency Exposure (UFCE), should ensure that the Bank has:-
Obtained the UFCE information from all its branches (including foreign
branches) in respect of large borrowers.
Obtained a certificate in respect of UFCE from entities on a quarterly
basis on self-certification basis, and which has preferably been internally
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Advances-Other than Agriculture
audited by the entity concerned. However, at least on an annual basis,
UFCE information should be audited and certified by the statutory
auditors of the entity for its authenticity.
Computed "Capital and Provisioning Requirements for Exposures to
entities with UFCE" at least on a quarterly basis, as per the applicable
RBI guidelines.
Lending for Real Estate
2.199 Banks are required to frame comprehensive prudential norms relating to
the ceiling on the total amount of real estate loans, single/group exposure limits
for such loans, margins, security, repayment schedule and availability of
supplementary finance and the policy should be approved by the banks' Boards.
The disbursements in case of these loans should be made only after the
borrower has obtained requisite clearances from the government authorities.
2.200 RBI has also required that the banks' Boards may also consider
incorporation of aspects relating to adherence to National Building Code (NBC) in
their policies on exposure to real estate. The information regarding the NBC can
be accessed from the website of Bureau of Indian Standards (www.bis.org.in).
Banks should also adopt the National Disaster Management Authority (NDMA)
guidelines and suitably incorporate them as part of their loan policies, procedures
and documentation.
Financing of Joint Ventures
2.201 Banks are allowed to extend credit/non-credit facilities (viz. letters of
credit and guarantees) to Indian Joint Ventures/Wholly-owned Subsidiaries
abroad and step-down subsidiaries which are wholly owned by the overseas
subsidiaries of Indian Corporates. Banks are also permitted to provide at their
discretion, buyer's credit/acceptance finance to overseas parties for facilitating
export of goods and services from India. The above exposure will, however, be
subject to a limit of 20 percent of banks' unimpaired capital funds (Tier I and Tier
II capital) and would be subject to the conditions laid down in this regard in the
Master Circular on `Loans and Advances Statutory and Other Restrictions'
dated July 1, 2015.
Limits on Banks' Exposure to Capital Markets
Statutory limit on shareholding in companies
2.202 No banking company is permitted to hold shares in any company,
whether as pledgee, mortgagee or absolute owner, of an amount exceeding 30
percent of the paid-up share capital of that company or 30 percent of its own
paid-up share capital and reserves, whichever is less, except as provided in sub-
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section (1) of Section 19 of the Banking Regulation Act, 1949. Shares held in
demat form should also be included for the purpose of determining the exposure
limit. This is an aggregate holding limit for each company.
Regulatory Limit
A. Solo Basis
2.203 The aggregate exposure of a bank to the capital markets in all forms
(both fund based and non-fund based) should not exceed 40 per cent of its net
worth as on March 31 of the previous year. Within this overall ceiling, the bank's
direct investment in shares, convertible bonds / debentures, units of equity-
oriented mutual funds and all exposures to Venture Capital Funds (VCFs) [both
registered and unregistered] should not exceed 20 per cent of its net worth.
B. Consolidated Basis
2.204 The aggregate exposure of a consolidated bank to capital markets (both
fund based and non-fund based) should not exceed 40 per cent of its
consolidated net worth as on March 31 of the previous year. Within this overall
ceiling, the aggregate direct exposure by way of the consolidated bank's
investment in shares, convertible bonds/debentures, units of equity-oriented
mutual funds and all exposures to Venture Capital Funds (VCFs) [both registered
and unregistered] should not exceed 20 per cent of its consolidated net worth4.
Sectoral Distribution
2.205 Advances are required to be classified, inter alia, into those in India
and those outside India, with further sub-classification under each category.
One such sub-classification that merits discussion from an auditor's
perspective is advances in India to priority sectors.
2.206 Priority sector advances include:
Advances for agriculture and other allied activities However, RBI, vide
its circular no. RPCD.CO.Plan.BC. 51 /04.09.01/2010-11 dated February
2, 2011 on "Classification of loans against gold jewellery" clarifies that
loans sanctioned to NBFCs for on-lending to individuals or other entities
against gold jewellery, are not eligible for classification under agriculture
sector. Similarly, investments made by banks in securitised assets
originated by NBFCs, where the underlying assets are loans against gold
jewellery, and purchase/assignment of gold loan portfolio from NBFCs are
also not eligible for classification under agriculture sector.
4Attention of the readers is drawn to Master Circular of RBI, DBR.No.Dir.BC.12/13.03.00/2015-16
dated 1 July 2015, for components of capital exposure, exclusions, method of computation of
capital exposure for the purpose and Intra-day limits.
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Advances-Other than Agriculture
RBI vide its master circular no RBI/2018-19/07
FIDD.FID.BC.No.04/12.01.033/2018-19 dated July 02, 2018 has provided
details on SHG- Bank linkage Programme. In order to enable the banks to
report their SHG lending without difficulty, it was decided that the banks
should report their lending to SHGs and/or to NGOs for on-lending to
SHGs/members of SHGs under the new segment, viz. 'Advances to SHGs'
irrespective of the purposes for which the members of SHGs have been
disbursed loans. Lending to SHGs should be included by the banks as part
of their lending to the weaker sections (under priority section).
Advances to minority communities.
Advances to micro/small/medium scale enterprises5.
Advances to small road transport operators.
Advances to retail traders and small business enterprises.
Advances to professionals and self-employed.
Advances sanctioned to State sponsored organisations for scheduled
castes/scheduled tribes.
Educational loans upto the prescribed limit RBI, vide its circular no.
RPCD.SME & NFS.BC.No. 69/06.12.05 /2009-10 dated April 12, 2010 on
"Collateral Free Loans - Educational Loan Scheme", clarified that banks
must not, mandatorily, obtain collateral security in the case of educational
loans upto Rs. 4 lakh.
Housing loans upto prescribed limits6.
Funds provided to RRBs.
Micro credit7.
Any other priority sector advances, such as SEPUP (Self-Employment
Programme for Urban Poor), PMRY (Prime Minister's Rozgar Yojana),
5 The RBI has issued a master Direction no. RBI/FIDD/2017-18/56 FIDD.MSME & NFS.
12/06.02.31/2017-18 on "Lending to Micro, Small and Medium Enterprises (MSME) Sector" dated
July 24, 2017. Also refer to the circular no. RPCD.SME & NFS.BC.No.79/06.02.31/2009-10 dated
May 6, 2010 on "Working Group to Review the Credit Guarantee Scheme for Micro and Small
Enterprises (MSEs) Collateral free loans to MSEs".
6 Attention is also invited to circular no. DBOD.No.BP.BC. 69 /08.12.001/2010-11 dated December
23, 2010 on "Housing Loans by Commercial Banks LTV Ratio, Risk Weight and Provisioning",
circular no. RPCD.MSME & NFS.BC.No. 30 /06.11.01/ 2012-13 dated September 18, 2012 on
"Scheme of 1% interest subvention on housing loans up to Rs. 15 lakh" and Master circular no.
DBR. No.DIR.BC.13/08.12.001/2015-16 dated July 1, 2015 on "Housing Finance".
7 The RBI has issued a master circular no. RPCD.MFFI.BC.No. 05/12.01.001/2010-11 dated July 1,
2010 on "Micro Credit".
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SEEUY (Self-Employment Scheme for Educated Unemployed Youth)
SGSY (Swarna jayanti Gram swaraj Swarojgar Yojana)8, SJSRY (Swarna
jayanti Sahakari Rozgar Yojana).
2.207 Priority sector advances generally carry an interest rate, which is
lower than the normal rate of interest on lending to other sectors. These
advances are also known as DRI advances, i.e., advances on which differential
rate of interest is applicable. Under the Reserve Bank of India's guidelines, a
specified proportion of the total advances of banks are to be made to priority
sectors necessarily. Depending upon the nature and type of facilities extended,
the bank may get subsidy from the Government to fully or partly offset the
shortfall in interest rate and/or get indemnified for bad debts for the whole or a
portion of such advances.
2.208 RBI has issued guidelines for the targets and sub-targets set under
priority sector lending for all scheduled commercial banks operating in India.
For detailed information on the guidelines, refer RBI circular
FIDD.CO.Plan.BC.54/04.09.01/2014-15 on "Priority Sector Lending Targets
and Classification".
2.209 Government of India vide Notification dated February 04, 2016 has
specified "Dealing in Priority Sector Lending Certificates (PSLCs) in
accordance with the Guidelines issued by Reserve Bank of India" as a form of
business under Section 6 (1)(o) of the Banking Regulation Act, 1949. The
purpose of PSLCs is to enable banks to achieve the priority sector lending
target and sub-targets by purchase of these instruments in the event of
shortfall and at the same time incentivize the surplus banks; thereby enhancing
lending to the categories under priority sector. Refer RBI circular
FIDD.CO.Plan.BC.23/04.09.01/2015-16 for detailed guidelines on PSLCs.
System of Base Rate and Interest Rate/ Marginal Cost of Funds
based Lending Rate (MCLR)
2.210 The RBI vide its Circular No. DBR.No.Dir.BC.9/ 13.03.00/2015-16
dated April 1, 2015 and DBR.No.Dir.BC.67/13.03.00/2015-16 dated December
17, 2015 on "Interest Rates on Advances" required the banks to freely
determine the lending rates on the advances as per their Board approved
policy subject to the guidelines contained in the circular. The Base Rate system
8 Attention is the readers is drawn to master circular No. FIDD.CO.Plan.BC.04/04.09.01/2015-16dated
July 1, 2015 on "Priority Sector Lending - Special Programmes Swarna jayanti Gram Swarozgar
Yojana (SGSY)" and Circular No. RPCD.GSSD.BC.No.30 /09.01.01/2010 -11 dated December 15,
2010 on "Swarna jayanti Gram Swarozgar Yojana (SGSY) - Group Life Insurance Scheme". (Add
circular related to NRLM as well)
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Advances-Other than Agriculture
is aimed at enhancing transparency in lending rates of banks and enabling
better assessment of transmission of monetary policy. Accordingly, the
following is the summary guidelines were issued by RBI for implementation by
banks. For detailed guidelines, refer above mentioned RBI circulars:
Banks were required to obtain the approval of their respective Boards for
the Prime Lending Rate which was the minimum rate charged by them for
the credit limits of over Rs 2 lakhs. In case of loans up to Rupees two
lakh, it was decided to continue to protect these borrowers by prescribing
the lending rates. With effect from April 29, 1998, it was decided that
interest on Credit limit of Rs. 2 lakh and below shall not exceed PLR
which was available to the best customer of the concerned bank. In order
to enhance transparency in bank's pricing of their loan products as also to
ensure that the PLR truly reflects the actual cost, in year 2003, it was
decided to abolish the prescription of minimum lending rate for credit
limits of over Rupees two lakh and banks were given the freedom to fix
the lending rates for such credit limits subject to Benchmark Prime
Lending Rate (BPLR) and spread guidelines. Banks were required to
obtain the approval of their respective Boards for the BPLR, which would
be the reference rate for credit Iimits of over Rs. 2 lakh. Each bank's
BPLR had to be declared and be made uniformly applicable at all
branches. BPLR continued to be the ceiling rate of interest for advances
upto Rs. 2 lakh.
Base Rate shall include all those elements of the lending rates that are
common across all categories of borrowers. There can be only one Base
Rate for each bank. Banks may choose any benchmark to arrive at the
Base Rate that may be disclosed transparently.Banks are free to use any
other methodology, as considered appropriate, provided it is consistent
and is made available for supervisory review/scrutiny, as and when
required.
Banks are required to review the Base Rate at least once in a quarter with
the approval of the Board or the Asset Liability Management Committees
(ALCOs) as per the bank's practice. Banks are allowed to review Base
Rate methodology after three years from date of its finalizationwith the
approval of their Board of Directors/ ALCO.
All rupee loans sanctioned and credit limits renewed w.e.f. April 1, 2016
will be priced with reference to the Marginal Cost of Funds based Lending
Rate (MCLR) which will be the internal benchmark for such purposes.
Audit teams should verify whether new loans sanctioned and credit limits
renewed post April 1, 2016 is under the new MCLR regime.
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Guidance Note on Audit of Banks (Revised 2019)
The MCLR will comprise of Marginal cost of funds, Negative carry on
account of CRR, Operating costs and Tenor premium.
Spread
2.211
(i) Banks should have a Board approved policy delineating the components
of spread charged to a customer. It should be ensured that any price
differentiation is consistent with bank's credit pricing policy.
(ii) Bank's internal pricing policy must spell out the rationale for, and range
of, the spread in the case of a given category of borrower, as also, the
delegation of powers in respect of loan pricing. The rationale of the policy
should be available for supervisory review.
(iii) The spread charged to an existing borrower should not be increased
except on account of deterioration in the credit risk profile of the customer
or change in the tenor premium. Any such decision regarding change in
spread on account of change in credit risk profile should be supported by
a full-fledged risk profile review of the customer. The change in tenor
premium should not be borrower specific or loan class specific. In other
words, the change in tenor premium will be uniform for all types of loans
for a given residual tenor.
(iv) The guidelines contained in sub-paragraph (iii) above are, however, not
applicable to loans under consortium/ multiple banking arrangements.
Securitisation and Reconstruction of Financial Assets and
Enforcement of Security Interest (SRFAESI) Act, 2002
Securitisation of Standard Assets
2.212 After the enactment of the Securitization and Reconstruction of
Financial Asset and Enforcement of Security Interest Act, 2002, banks have
got significant power to possess the securities of defaulting borrower. Banks
can now take possession of the assets from borrower and convert the same in
Security Receipts. In the process of securitisation, assets are sold to a
bankruptcy remote special purpose vehicle (SPV) in return for an immediate
cash payment. The cash flow from the underlying pool of assets is used to
service the securities issued by the SPV. Securitisation thus follows a two-
stage process. In the first stage, there is sale of single asset or pooling and
sale of pool of assets to a 'bankruptcy remote' special purpose vehicle (SPV) in
return for an immediate cash payment and in the second stage repackaging
and selling the security interests representing claims on incoming cash flows
from the asset or pool of assets to third party investors by issuance of tradable
debt securities. Thus, the non-performing asset of the banker is taken out of
the balance sheet of the bank and converted into Security Receipts.
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Advances-Other than Agriculture
2.213 In order to further strengthen banks' ability to resolve their stressed
assets effectively, RBI has issued revised guideline to improved framework
governing sale of such assets by banks to SCs/RCs/other banks/Non-Banking
Financial Companies /Financial Institutions etc. In order to enhance
transparency in the entire process of sale of stressed assets, banks are
required to do following:
Identification of stressed assets beyond a specified value, as may be
determined by bank's policy, for sale shall be top-down i.e., the head
office/corporate office of the bank shall be actively involved in
identification of stressed assets, including assets which are classified as
Special Mention. Account, to be put on sale. Early identification will help
in low vintage and better price realisation for banks;
At least once in a year, preferably at the beginning of the year, banks
shall, with the approval of their Board, identify and list internally the
specific financial assets identified for sale to other institutions, including
SCs/RCs;
At a minimum, all assets classified as `doubtful asset' above a threshold
amount should be reviewed by the board/board committee on periodic
basis and a view, with documented rationale, is to be taken on exit or
otherwise. The assets identified for exit shall be listed for the purpose of
sale as indicated above;
Prospective buyers need not be restricted to SCs/RCs. Banks may also
offer the assets to other banks/NBFCs/FIs, etc. who have the necessary
capital and expertise in resolving stressed assets. Participation of more
buyers will result in better price discovery;
In order to attract a wide variety of buyers, the invitation for bids should
preferably be publicly solicited so as to enable participation of as many
prospective buyers as possible. In such cases, it would be desirable to
use e-auction platforms. An open auction process, apart from attracting a
larger set of borrowers, is expected to result in better price discovery.
Banks should lay down a Board approved policy in this regard;
Banks must provide adequate time for due diligence by prospective
buyers which may vary as per the size of the assets, with a floor of two
weeks;
Banks should have clear policies with regard to valuation of assets
proposed to be sold. In particular it must be clearly specified as to in
which cases internal valuation would be accepted and where external
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Guidance Note on Audit of Banks (Revised 2019)
valuation would be needed. However, in case of exposures beyond Rs.50
crore, banks shall obtain two external valuation reports;
The cost of valuation exercise shall be borne by the bank, to ensure that
the bank's interests are protected;
The discount rate used by banks in the valuation exercise shall be spelt
out in the policy. This may be either cost of equity or average cost of
funds or opportunity cost or some other relevant rate, subject to a floor of
the contracted interest rate and penalty, if any.
2.214 In order to make sure that sale of stressed assets by banks actually
result in `true sale' of assets and to create a vibrant stressed assets market, it
has been decided to progressively restrict banks' investment in SRs backed by
their own stressed assets.
i) With effect from April 1, 2017, where the investment by a bank in SRs
backed by stressed assets sold by it, under an asset securitisation, is more
than 50 percent of SRs backed by its sold assets and issued under that
securitisation, the provisions held in respect of these SRs will be subject to
a floor; this floor shall be progressive provisioning as per extant asset
classification and provisioning norms, notionally treating book value of
these SRs as the corresponding stressed loans, assuming these had
remained, without recovery of principal, on the bank's books. In effect,
provisioning requirement on SRs will be higher of the:
a. provisioning rate required in terms of net asset value declared by the
SCs/RCs; and
b. provisioning rate as applicable to the underlying loans, assuming that
the loans notionally continued in the books of the bank;
ii) With effect from April 1, 2018, the above threshold of 50 percent will stand
reduced to 10 percent.
2.215 These Security Receipts are treated as non-SLR security (Investment)
in the books of subscribing bank as per RBI guidelines. In the absence of ready
market for the Security Receipts, the subscribing bank needs to value Security
Receipts on the basis of Net Asset Value to be declared by Securitising
Company on a quarterly basis. Further, when a bank sells the non-performing
assets to securitising company, if the sale value of assets is less than the Net
book Value, i.e., books value of advances less provisions, the shortfall needs
to be debited to Profit & Loss Account. However, in case the sale value being
higher, excess provision cannot be reversed and is kept to meet the shortfall/
loss on account of other non-performing assets.
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Advances-Other than Agriculture
E. Accounting and Auditing Aspects
Balance Sheet Disclosure
2.216 The Third Schedule to the Act requires classification of advances
made by a bank from three different angles, viz., nature of advance, nature and
extent of security, and place of making advance (i.e. whether in India or outside
India). Accordingly, the advances are to be classified in Schedule 9 to the
balance sheet as follows.
A. (i) Bills purchased and discounted
(ii) Cash Credits, Overdrafts and Loans repayable on demand
(iii)Term loans
B. (i) Secured by tangible assets
(ii) Covered by bank/government guarantees
(iii)Unsecured
C. I. Advances in India
(i) Priority sectors
(ii) Public sector
(iii) Banks
(iv) Others
II. Advances outside India
(i) Due from banks
(ii) Due from others
(iii) Bills purchased and discounted
(iv) Syndicated loans
(v) Others
Classification Based on Nature of Advance (Section A)
2.217 Different classifications under section A will be as follows:
(a) In classification under section `A', all outstandings in India as well as
outside India less provisions made, will be classified under three heads.
(b) Outstandings in credit card operations should be shown as part of
advances under the head `cash credits, overdrafts and loans repayable
on demand'.
(c) Term loans will be loans not repayable on demand and would include
overdue instalments.
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Guidance Note on Audit of Banks (Revised 2019)
(d) All interest bearing loans and advances granted by the bank to its
employees should be shown as part of advances.
Classification Based on Nature and Extent of Security (Section B)
2.218 Different classifications under section B will be as follows:
(a) All advances or part of advances, which are secured9 by tangible assets,
whether in India or outside India, should be shown under the heading
`secured by tangible assets'. Advances against book debts may be
included under the head `Secured by Tangible Assets', and presented in
Schedule 9 (Advances) as follows:
"B Secured by Tangible Assets" (includes advances against book debt)
(b) Advances in India and outside India to the extent they are covered by
guarantees of Indian and foreign governments and Indian and foreign
banks and DICGC and ECGC are to be included under the head
`advances covered by bank/government guarantees'.
(c) Unsecured advances will include advances not classified under (i) & (ii) of
section B.
Classification based on Place of Making Advances (Section C)
2.219
a) Advances to sectors, which are classified as priority sectors according to
the instructions of the RBI, are to be classified under the head `priority
sectors'. Such advances should be excluded from, `Advances to Public
Sector'.
b) Advances to Central and State Governments and other government
undertakings including government companies and corporations which
are, according to the statutes, to be treated as public sector companies,
are to be included in the category `Public Sector'.
c) All advances to the banking sector including co-operative banks will come
under the head `Banks'.
d) All the remaining advances will be included under the residual head
`Others'; typically this category will include non-priority advances to the
private, joint and co-operative sectors.
9A `secured advance', according to section 5(n) of the Banking Regulation Act, 1949 means an
advance made on the security of assets the market value of which is not at any time less than the
amount of such advance.
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Advances-Other than Agriculture
Audit Approach and Procedures
2.220 Advances generally constitute the major part of the assets of the bank.
There are large number of borrowers to whom variety of advances are granted.
The audit of advances requires the major attention from the auditors. In carrying
out audit of advances, the auditor is primarily concerned with obtaining evidence
about the following:
a) Amounts included in balance sheet in respect of advances are outstanding
at the date of the balance sheet.
b) Advances represent amount due to the bank.
c) Amounts due to the bank are appropriately supported by Loan documents
and other documents as applicable to the nature of advances.
d) There are no unrecorded advances.
e) The stated basis of valuation of advances is appropriate and properly applied,
and that the recoverability of advances is recognised in their valuation.
f) The advances are disclosed, classified and described in accordance with
recognised accounting policies and practices and relevant statutory and
regulatory requirements.
g) Appropriate provisions towards advances have been made as per the RBI
norms, Accounting Standards and Generally Accepted Accounting
Practices.
2.221 The auditor can obtain sufficient appropriate audit evidence about
advances by study and evaluation of internal controls relating to advances, and by:
examining the validity of the recorded amounts;
examining loan documentation;
reviewing the operation of the accounts;
examining the existence, enforceability and valuation of the security;
checking compliance with RBI norms including appropriate classification
and provisioning; and
carrying out appropriate analytical procedures.
2.222 In carrying out substantive procedures, the auditor should examine all
large advances while other advances may be examined on a sampling basis.
The accounts identified to be problem accounts however need to be examined in
detail unless the amount involved is insignificant. The auditor can obtain the list
of SMA 1 and SMA 2 borrowers from the bank and the same should also be
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Guidance Note on Audit of Banks (Revised 2019)
considered for selection of problematic accounts. The extent of sample checking
would also depend on the auditor's assessment of efficacy of internal controls.
What constitutes a `large advance' would need to be determined in the context of
volume of operations of the branch. As a general rule, however, an advance may
be considered to be a large advance if the year-end balance is in excess of Rs.2
crore or 5% of the aggregate year-end advances of the branch, whichever is
less.
2.223 Advances which are sanctioned during the year or which are adversely
commented by RBI inspection team, concurrent auditors, bank's internal
inspection, etc., should, generally, be included in audit sample. Besides this new
advances sanctioned during the year should be included on selective basis in
the sample.
2.224 In nutshell, auditor at branch may keep following in mind to plan
comprehensive coverage of advances and for selection of sample.
1. Obtain top 10 exposure accounts: It may be advisable for a branch
auditor to visit the branch and ask the list of top 10 accounts/ exposures
along with all the details such as status and security etc. before starting of
the audit.
2. Obtain the list of stressed accounts: Stressed Accounts includes
accounts classified as SMA 1 or SMA 2 of projects where implementation is
delayed. The banks monitor stressed accounts on daily basis. The account
that generally has overdue beyond 60 days or likely to slip to NPA at the
quarter end is termed as stressed account (some banks may use different
terminology). It is advisable to obtain such list of stressed accounts at least
15 days ahead of the closing date i.e. say stressed account list as on 15th
March. This will provide the auditor a ready list of such accounts. The
auditor then can scrutinise (based on materiality) to know whether the
account has slipped or if not whether has been kept standard by unusual
transaction that cannot be termed as business transaction. The RBI through
its circulars has time and again been emphasising that stray credit at the
quarter end need not qualify to keep account standard. We need to assess
whether account is inherently weak. If so the same may have to be
downgraded. As regards the partial recovery in overdue account (qualifying
the criteria for classification of an account as NPA), such account cannot be
upgraded unless overdue portion is recovered in entirety. As regards
subsequent credit (after the date of balance sheet), the same will not
improvise the classification of an advance.
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Advances-Other than Agriculture
3. Obtain the list of restructured accounts: As we are aware restructured
account portfolio requires separate additional provisioning. It is necessary
to obtain the list of such accounts and ensure whether the restructure is as
per the RBI directives.
4. Obtain the list of bi-lateral, CDR, SDR, S4A or 5/25 Accounts:
Please ensure the compliance with the RBI guidelines in respect of all such
accounts.
5. Obtain the list of unsecured exposures above Rs. 1 Cr.: Unsecured
exposure has significant impact on the bank, if slips to NPA. Many a times
such accounts are reviewed in the traditional manner. These require close
monitoring not only from the perspective of financial parameters of the
prudential guidelines but also non-financial parameters that give signals of
the possible ill health. The banking industry (especially PSUs) has faced
severe damages on account non-identification of such non-financial
parameters.
6. Early mortality cases: Any advance slippage to NPA within 12 months of
its sanction is called early mortality case. Early mortality cases invoke
penalty to the sanctioning authorities. This will have to be checked to
understand the reason for such happening to avoid such cases in future
and also to find out whether there are any cases classified as performing on
some untenable ground to push it beyond early mortality.
Evaluation of Internal Controls over Advances
2.225 The auditor should examine the efficacy of various internal controls over
advances to determine the nature, timing and extent of his substantive
procedures. In general, the internal controls over advances should include, inter
alia, the following:
The bank should make an advance only after satisfying itself as to the credit
worthiness of the borrower by doing KYC compliance, proper credit
appraisal etc. and after obtaining sanction from the appropriate authorities of
the bank. The sanction for an advance should specify, among other things,
the limit of borrowing, nature of security, margin to be kept, interest, terms of
repayment etc. It also needs to be ensured that the loans sanctioned are as
per the Loan Policy of the bank and adhere to the regulatory (RBI) norms
unless a specific exemption is taken in this regard.
All the necessary documents (e.g., agreements, demand promissory notes,
letters of hypothecation, etc.) should be executed by the parties before
advances are made.
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Guidance Note on Audit of Banks (Revised 2019)
The compliance with the terms of sanction and end use of funds should be
ensured.
Sufficient margin as specified in the sanction letter should be kept against
securities taken so as to cover for any decline in the value thereof. The
availability of sufficient margin needs to be ensured at regular intervals.
If the securities taken are in the nature of shares, debentures, etc., the
ownership of the same should be transferred in the name of the bank and
the effective control of such securities be retained as a part of
documentation.
All securities requiring registration should be registered in the name of the
bank or otherwise accompanied by documents sufficient to give title to the
bank.
In the case of goods in the possession of the bank, contents of the packages
should be test checked at the time of receipt. The godowns should be
frequently inspected by responsible officers of the branch concerned, in
addition to the inspectors of the bank.
Surprise checks should be made in respect of hypothecated goods not in the
physical possession of the bank.
Drawing Power Register should be updated every month to record the value
of securities hypothecated. These entries should be checked by an officer.
The accounts should be kept within both the drawing power and the
sanctioned limit.
All the accounts which exceed the sanctioned limit or drawing power or are
otherwise irregular should be brought to the notice of the controlling authority
regularly.
The operation of each advance account should be reviewed at least once a
year, and at more frequent intervals in the case of large advances.
Consideration of Drawing Power/Limits in respect of stocks
hypothecated
2.226 In respect of credit facilities against hypothecation of stocks
(inventories) being the primary security, the Bank's system of appraisal for
determining the maximum permissible finance to borrowers and fixing of limits,
inter alia, should generally take into consideration the level of sundry creditors.
The sanction is expected to be in tune with the appraisal so made. While
sanctioning such credit facility, the bank is expected to stipulate in the
documents, that for computing the Drawing Power, the value of declared stocks
is to be considered only net of the stipulated margin; and that the declared stocks
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Advances-Other than Agriculture
shall not cover the borrower's liability outstanding in the form of sundry creditors
for goods or covered by LCs/ guarantees/ co-acceptances or Buyer's Credit
availed for procurement of material. The Bank should also insist on such
information from borrowers. In case of consortium accounts, the drawing power
calculation and allocation is made by the Lead Bank and is binding on the
Member Banks.
2.227 The Reserve Bank of India has been issuing guidelines on the treatment
of unpaid stocks while arriving at the drawing power available in the borrowal
accounts. The thrust of the guidelines is avoidance of double financing on the
unpaid stocks, if such stocks are taken as eligible for computation of drawing
power.
2.228 The matter having been re-examined by Reserve Bank of India, vide
directive No. IECD.No.32/08.10.01/92-93 dated 28th April, 1993 had advised as
regards the treatment of unpaid stocks while arriving at the drawing power
available in the borrower accounts, wherein the thrust is avoidance of the double
finance on the unpaid stock, if such stocks are taken as eligible for computation
of drawing power. Thus, it would be unrealistic to assume that the composition of
the stock items, the level of stock held and the portion of unpaid stock considered
at the time of appraisal would be static and should be presumed to be at the
same level for subsequent period. For the said reason, the drawing power needs
to be recomputed based on variations, not only in composition and level of stock
but also in the unpaid portion of stocks before the stipulated margin is applied as
per the sanction terms of a working capital finance.
2.229 The auditor should review the policy of the bank in this regard for any
inherent weakness in the credit system, where the stringency in appraisal, is
relaxed while sanctioning the advances, having consequential effect on
monitoring and supervision, and may have effect on the classification status of
the Borrower, where the drawing power falls short of the outstanding.
2.230 Banks usually consider credit facilities by way of Hypothecation of
stocks and a charge on the sundry debtors. The Drawing Power is required to be
computed net of the stipulated margin, based on and applied to the total eligible
current assets comprising:
Net Value of Stock as stated above, and
Net Value of Debtors (i.e., eligible Trade Debtors Less Bills Discounted with
Bank). The bank usually prescribes the conditions as to what comprise
eligible trade debtors, and stipulates the period for debts being considered
as current and good on which the margin is computed.
2.231 For the purposes of classification of advances, the computation of
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drawing power based on realistic value of hypothecated stocks (net of unpaid for
stocks, whether covered by Buyer's Credit, LCs/ Guarantees/ Co-acceptances or
otherwise) and margin as stipulated, is vital, particularly in cases of default, and
in border-line cases where the health status of borrowers may be in question, to
gauge slippages.
2.232 Due care is required to be exercised by the auditor in case of
Documents retained in original at centralised offices where these are not
available at the branches that are advised of drawing power limits; and
consortium advances, where the bank, not being the leader, gets the related
figures of drawing power from the leader bank, without the related evidence
of computation or appropriateness of the drawing power.
The auditor needs to look into this aspect to verify that there is no slippage of the
account into NPA classification.
Long Form Audit Report
2.233 The auditor has to comment on various specific issues as mentioned in
the Long Form Audit Report of the bank. While evaluating the efficacy of internal
controls over advances, the auditor should particularly examine those aspects on
which he is required to comment in his long form audit report. Thus, he should
examine, inter alia, whether the loan applications are complete and in prescribed
form; procedural instructions regarding grant/ renewal/enhancement of facilities
have been complied with; sanctions are within delegated authority and
disbursements are as per terms of the sanction; documentation is complete; and
supervision is timely, effective and as per prescribed guidelines. The auditor can
gather the requisite evidence by examining relevant documents (such as loan
application forms, supporting documentation, sanctions, security documents,
etc.) and by obtaining information and explanations from the branch
management in appropriate cases. The detailed directives / guidance with regard
to such issues are given in a separate Chapter on Long Form Audit Report. The
auditors must familiarise themselves with those issues and guidance relating to
the same and should cover the same during the regular course of audit of
advances.
2.234 Observations relating to procedural significance should be mentioned in
LFAR. Please note that the whole bank LFAR gets finalised within 60 days of
signing of financial statements. Hence during finalisation CSA predominantly
concentrates on main audit report submitted by the branch auditor. Any
observation that requires to be dealt with during finalisation may miss the
attention of CSA if the same is mentioned in LFAR alone. Such observations that
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need to be dealt with for finalisation of the banks financial statements should find
place in main audit report along with appropriate MOC, if required.
Examining the Validity of Recorded Amounts
2.235 The auditor should ascertain the status of balancing of subsidiary
ledgers relating to advances. The total of balances in the subsidiary ledgers
should agree with the control accounts in the General Ledger. The auditor should
also tally the total of the statement of advances with the balances as per general
ledger/ subsidiary ledgers. He should also cross-check the balances of the
advances selected for examination as listed in the statement of advances with
the balances in the relevant advance accounts in the subsidiary ledgers. Banks
often obtain balance confirmation statements from borrowers periodically. Such
statements have a dual advantage in preventing disputes by the customer and
extending the period of limitation by reference to the date of confirmation.
Wherever available, such confirmations may be seen.
2.236 These days most of the banks have their `advances' statements
generated through the system. The auditor should ensure that the fields which
system copies from last year are the same and he should take extra care in
relation with the date of NPA and date of becoming doubtful asset as these facts
have great bearing on the provisioning. The auditor should obtain audit trail from
the bank to verify whether there are any changes or not.
Examination of Loan Documents
2.237 As indicated earlier, the documents relating to advances would be
affected by the legal status of the borrower and the nature of security. Thus,
where the borrower is a company, loan documents would include certificate of
incorporation, memorandum and articles of association, certificate of
commencement of business (in the case of public limited companies), resolution
of board of directors, and special resolution of shareholders [in cases covered by
section 180 (1)(c) of the Companies Act, 2013, etc. Where the borrower is a
partnership firm, loan documents would include copy of partnership deed. Where
the security is in the form of mortgage, apart from mortgage deed (in the case of
English Mortgage) or letter of intent to create mortgage (in the case of Equitable
Mortgage), the evidence of registration of the charge with the Registrar of
Companies would also form part of loan documentation if the borrower is a
company. Each bank has its own set of rules regarding the documents to be
obtained from various types of borrowers and in respect of different kinds of
securities. The formats of many of the documents are also prescribed. The
auditor should evaluate the adequacy of the loan documents in the context of the
rules framed by the bank in this regard.
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Centralisation and location of original loan documents at Loan Processing
Centres
2.238 Of late, there is an increasing propensity in banks to process the loans
and advances, including appraisal, sanction, documentation, initial
disbursements, etc., at Loan Processing Centres/Offices (by whatever name
called) and to execute and physically hold all the documents at such locations,
that may not be in very close proximity to the branch, where the borrowal
accounts are maintained/serviced. The Branch places reliance only on the
Sanction letters, on the presumption that all the required legal and
documentation formalities are correct and complete at the centralized location.
2.239 In the absence of the original documents (or even authenticated copies
thereof) on an updated basis, the auditor would need to request the management
for the files identified for examination by him. The branch auditor must be
satisfied on the authenticity and terms of the sanction (in case the sanction
letters are only computer generated but not authenticated), the completeness of
the records, duly updated, for all accounts where the sanction was so conveyed;
and further whether the number of accounts and amounts recorded at such
centres tally with the corresponding data at the branch. It needs to be confirmed
as to whether there are any cheques held by such centres that remain unbanked
affecting the borrowal account balance. Reference must also be made to any
adverse observations in the related monitoring/supervisory report on the
documentation aspects at the centralized location.
Review of Operation of Account
2.240 The auditor should review the operation of the advance accounts. In
doing so, an intelligent scrutiny of the operation of the account should be carried
out to see that the limit is not generally exceeded; that the account is not
becoming stagnant; that the customer is not drawing against deposits which are
not free from lien; that the account is not window-dressed by running down
overdrafts at the year end and again drawing further advances in the new year,
etc. The audit procedure should be able to highlight disbursals from pre/freshly
sanctioned limits made either to the same borrower or to group entities near the
repayment dates of critical dues.
2.241 The auditor should also examine whether there is a healthy turnover in
the account. It should be seen that the frequency and the amounts of credits in
the account are commensurate with the sanctioned limit and the nature and
volume of business of the borrower. Any unusual items in the account should be
carefully examined by the auditor. If the auditor's review indicates any unhealthy
trends, the account should be further examined. The auditor's examination
should also cover transactions in the post-balance sheet date period. Large
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transactions in major accounts particularly as at the year-end may be looked into,
to identify any irregularities in these accounts. A written note/explanation may be
obtained from the management as regards any major irregularities which may
have a bearing on his report.
2.242 The auditor may also review the following to assess the recoverability of
advances:
(a) Periodic statements submitted by the borrowers indicating the extent of
compliance with terms and conditions.
(b) Latest financial statements of borrowers.
(c) Reports on inspection of security.
(d) Auditors' reports in the case of borrowers enjoying aggregate credit limits
of Rs. 10 lakh (or as approved by Board of Directors of respective banks)
or above for working capital from the banking system.
2.243 The auditor should verify that interest is being charged on all performing
accounts regularly and also should compare the rate of interest with the
agreement and the sanction and with the credit rating reports where the rate of
interest is linked to credit rating. In case the interest rate is to be revised based
on the changes in PLR/BPLR/Base Rate of the bank, it needs to be ensured that
the rate of interest to be charged form the borrower is suitably revised as and
when there are changes in PLR/BPLR/Base Rate. Calculation of interest should
be test-checked. The auditor should examine that interest not received on any
account, which is a non-performing asset as per the guidelines of the RBI, has
not been recognised as income. It may be noted that interest accrued but not due
on advances does not form part of advances.
2.244 The penal interest in case of delayed submission of stock statements,
non-creation of security, overdrawn accounts etc., needs to be charged as per
sanctioned terms and norms of the bank. The compliance of the same should be
checked in detail by the auditors.
2.245 In the case of advances covered by guarantees of
DICGC/ECGC/CGTS, in case of default the auditor should examine whether
appropriate steps have been taken for lodging of claims for guarantees in
accordance with the applicable procedure. The claims declined by
DICGC/ECGC/CGTS should not be considered as recoverable while calculating
the provisions against the respective advances.
2.246 In respect of consortium advances, the auditor should particularly
examine
(a) compliance with the limits stipulated by the consortium in lending moneys to
the borrower;
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(b) the bank's monitoring of securities like stocks, etc., which are in its
custody/charge; and
(c) follow-up with lead bank on pending issues.
2.247 Apart from the usual audit procedures applicable in respect of
advances, the auditor should examine whether the bank has correctly classified
the inter-bank participation certificates. In the case of participations on risk-
sharing basis, the auditor should examine whether any loss has devolved on the
bank as on the balance sheet date and, if so, whether adequate provision in
respect of such loss has been made.
Verification of Security against Advances
2.248 From the view point of security, advances are to be classified in the
balance sheet in the following manner:
(a) Secured by tangible assets.
(b) Covered by bank/government guarantees.
(c) Unsecured.
2.249 An advance should be treated as secured to the extent of the value of
the security on the reporting date. If only a part of the advance is covered by the
value of the security as at the date of the balance sheet, that part only should be
classified as secured; the remaining amount should be classified as unsecured.
2.250 As mentioned earlier, the Reserve Bank has specified that advances
against book debts may be included under the head `secured by tangible assets'.
2.251 The following points are relevant for classifying the advances based on
security.
(a) Government guarantees include guarantees of Central/State Governments
and also advances guaranteed by Central/State Government owned
corporations and financial institutions like IDBI, IFCI, ICICI, State Financial
Corporations, State Industrial Development Corporations, ECGC, DICGC,
CGTS, etc.
(b) Advances covered by bank guarantees also include advances guaranteed
against any negotiable instrument, the payment of which is guaranteed by a
bank.
(c) Advances covered by bank/government guarantees should be included in
unsecured advances to the extent the outstanding in these advances
exceed the amount of related guarantees.
(d) While classifying the advances as secured, the primary security should be
applied first and for the residual balance, if any, the value of collateral
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security should be taken into account. If the advance is still not fully
covered, then, to the extent of bank/government guarantees available, the
advance should be classified as `covered by bank/government guarantee'.
The balance, if any, remaining after the above classification, should be
classified as `unsecured'.
(e) There may be situations where more than one facility is granted to a single
borrower and a facility is secured, apart from primary and collateral securities
relating specifically to that facility, by the residual value of primary security
relating to any other credit facility (or facilities) granted to the borrower. In
such a case, in the event of shortfall in the value of primary security in such a
credit facility, the residual value of primary security of the other facility (or
facilities, as the case may be) may be applied first to the shortfall and the
value of collateral securities should be applied next.
(f) In the case of common collateral security for advances granted to more
than one borrower, if there is a shortfall in value of primary security in any
one or more of the borrowal accounts, the value of collateral security may
be applied proportionately to the shortfall in each borrowal account.
(g) Advances covered by ECGC/DICGC,CGTS guarantees should be treated
as covered by guarantees to the extent of guarantee cover available. The
amount already received from DICGC/ECGC/CGTS and kept in sundry
creditors account pending adjustment should be deducted from advances.
(h) An account which is fully secured but the margin in which is lower than that
stipulated by the bank should nevertheless be treated as fully secured for
the purposes of balance sheet presentation.
(i) All documentary bills under delivery-against-payment terms (i.e., covered by
RR/Airway Bill/Bill of lading) for which the documents are with the bank as on
the balance sheet date should be classified as `secured'.
(j) Documentary bills under delivery-against-acceptance terms which remain
unaccepted as at the close of 31st March (i.e., for which the documents of
title are with the bank on this date) should be classified as secured. All
accepted bills should be classified as `unsecured' unless collaterally
secured.
(k) Cheques purchased including self-cheques (i.e., where the drawer and
payee are one and the same) should be treated as unsecured.
(l) Advances against supply bills, unless collaterally secured, should be
classified as unsecured even if they have been accepted by the drawees.
(m) `Security' means tangible security properly discharged to the bank and will
not include intangible securities like guarantees (including State
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government guarantees), comfort letters, etc. Moreover, the rights,
licenses, authorisations, etc., charged to the banks as collateral in respect
of projects (including infrastructure projects) financed by them, should not
be reckoned as tangible security. (Ref Master Circular No. RBI/2015-
16/99DBR.BP.BC.No.23/21.04.018/2015-16 dated July 1 2015 on
Disclosure in Financial Statements- Notes to Accounts)
2.252 In examining whether an advance is secured and, if so, to what extent,
the auditor is concerned with determining
(a) whether the security is legally enforceable, i.e., whether the necessary legal
formalities regarding documentation, registration, etc., have been complied
with;
(b) whether the security is in the effective control of the bank; and
(c) to what extent the value of the security, assessed realistically, covers the
amount outstanding in the advance.
2.253 The auditor should examine the following aspects in respect of
advances classified as `secured':
(a) Documents executed are complete and in force.
(b) Where documents have not been renewed, the limitation period has not
expired.
(c) Evidence is available as to the market value of the security.
(d) Evidence is available that
i. hypothecated/pledged goods are the property of the borrowers and are
not old/obsolete or otherwise unsaleable;
ii. advances against book debts of borrowers are related to their current
debts and not old/doubtful debts; and
iii. Stocks hypothecated/pledged are paid stocks owned by the borrower.
(e) In the case of companies, the charge is appropriately registered with the
Registrar of Companies and a certificate of registration of charge or other
evidence of registration is held.
(f) Borrowers are regular in furnishing the requisite information regarding the
value of security lodged with the bank.
(g) In respect of the second charge being available in respect of certain assets,
the amount of the lender(s) enjoying the first charge on such asset be
worked out and only the residuary value, if any, available for second charge
holders, be considered.
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2.254 The following paragraphs deal with the different types of securities
against advances generally accepted by banks and the manner in which the
auditor should verify them.
Stock Exchange Securities and Other Securities
2.255 The auditor should verify stock exchange securities and their market
value in the same manner as in the case of investments. The auditor should
examine whether the securities have been registered or assigned in favour of the
bank, wherever required and verify the same with Demat Statement.
2.256 It sometimes happens that a quoted security may not have frequent
transactions on the stock exchange and the quotation included in the official
quotations may be that of a very old transaction. In such a case, the auditor
should satisfy himself as to the market value by scrutiny of balance sheet, etc., of
the company concerned, particularly, if the amount of advance made against
such security is large.
2.257 Banks do not generally make advances against partly paid securities.
If, however, any such shares are accepted by the bank as security and these are
registered in the name of the bank, the auditor should examine whether the
issuing company has called up any amount on such securities and, if so, whether
the amount has been paid in time by the borrower/bank.
Goods
2.258 In respect of hypothecated goods, the auditor should check the quantity
and value of goods hypothecated with reference to the statement received from
the borrower. He should also examine the reasonableness of valuation. Letter of
hypothecation should also be examined by the auditor. If the value of the goods
is higher than the amount mentioned in the letter of hypothecation, the bank's
security is only to the extent of the latter. Auditor should also verify that the Bank
has system of maintenance of proper register in this regard as also system of
scrutiny of stock/book debt statement furnished by the borrower.
2.259 The auditor should also check nature of goods hypothecated/pledged. If
the goods are of perishable nature, it will not have market value.
2.260 In case of goods/book debts, movable assets hypothecated, auditor
should also examine whether the Bank has system in place for periodical
inspection of such goods/debts/assets and records of borrowers by its own
officer or by external agencies like firm of Chartered Accountants. Whether
proper register is maintained in this regard and timely action is taken whenever
there is an adverse remark in the inspection report. Auditor should also check
that there is adequate insurance cover in respect of goods /assets hypothecated
and there is a bankers' clause in the policy.
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2.261 In respect of goods pledged with the bank, the auditor should check the
statement received from the borrower regarding the quantity and value of goods
pledged by him. He should test check the godown registers and the valuation of
the goods. If there is any outstanding delivery order against the goods as on the
balance sheet date, the same should be deducted from the total quantity in hand
in ascertaining the value of the goods constituting the security. The auditor may
also examine the key movement register to verify the movement of goods
inwards and/or outwards.
2.262 Sometimes, goods are in the possession of third parties, such as
clearing and forwarding agents, transporters, brokers, warehouse-keepers, etc. If
these parties have given an undertaking to the bank that they will hand over the
goods or sale proceeds thereof to the bank only, i.e., they have 'attorned' to the
bank the advances made against such goods should be considered as secured.
In such cases, certificates should be obtained by the bank from such third parties
regarding quantities on hand on balance sheet date. The valuation of such goods
should be checked by the auditor. In case the borrower is a company, the auditor
should examine the certificate of registration of charge on the goods
hypothecated with the Registrar of Companies. It may be mentioned that in case
of pledge of goods, registration of charge is not necessary.
Gold Ornaments and Bullion
2.263 The auditor may inspect and weigh (on a test basis) the ornaments on
the closing date. He should also see the assayer's certificate regarding the net
gold content of the ornaments and their valuation. Valuation should also be
checked with reference to the current market price of gold. In context to the
valuation, attention is also invited to the valuation norms as given in the RBI
circular no. DBOD.No.BP.BC.27/21.04.048/2014-15 on "Loans against Gold
Ornaments and Jewellery for Non-Agricultural End-uses" dated July 22, 2014.
2.264 In respect of gold and silver bars, the auditor should inspect the bars on
a test basis and see that the mint seals are intact. The weights mentioned on the
bars may generally be accepted as correct.
Life Insurance Policies
2.265 The auditor should inspect the policies and see whether they are
assigned to the bank and whether such assignment has been registered with the
insurer. The auditor should also examine whether premium has been paid on the
policies and whether they are in force. Certificate regarding surrender value
obtained from the insurer should be examined. The auditor should particularly
see that if such surrender value is subject to payment of certain premia, the
amount of such premia has been deducted from the surrender value.
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2.266 It should be verified whether the policies are assignable in bank's
favour. In certain types of policies, the assignment to third party are restricted.
Bank's Own Deposit Certificates
2.267 The auditor should inspect such certificates and examine whether they
have been properly discharged and whether the lien of the bank is noted on the
face of the certificates as well as in the relevant register of the bank and also in
CBS master data.
Hire-purchase Documents
2.268 These advances may be classified as secured against the
hypothecation of goods. Where there is no hypothecation, the advance will be
classified as unsecured.
Plantations
2.269 These advances are classified as secured against the crop and/or the
fixed assets (viz., mortgage of land) of the plantation. The auditor should
examine the agreement and the title deeds. Regarding the estimate of the crop,
he may examine the record of the garden for the last few years. He should also
ascertain whether the crop is properly insured against natural calamities and
other disasters such as hail, etc.
2.270 Auditor should keep in mind that where moratorium is available for
payment of interest in such plantation projects, the payment of interests becomes
due only after the moratorium or gestation period is over and in such a case the
account will become NPA in case interest is not recovered after the due date of
such interest after moratorium period, if specifically mentioned in the sanction
letter.
Immovable Property
2.271 The auditor should inspect the title deed, the solicitor's/advocate's
opinion taken by the bank in respect thereof, and the mortgage deed. For
valuation, he may rely upon the architect's or valuer's report (which should be
taken at least once in three years) after carrying out appropriate audit procedures
to satisfy himself about the adequacy of the work of the architect/valuer for this
purpose.10 He should also examine the insurance policies.
2.272 In some cases, banks make advances against immovable properties
where the title deeds are not in the name of the borrower. For example, an
advance may be given against the security of a flat in a co-operative group
housing society, the title deeds of which may not be in the name of the borrower.
10 Reference may be made in this regard to SA 620, "Using the Work of an Auditor's Expert".
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In such cases, the auditor should examine the evidence regarding the right or
interest of the borrower in the property mortgaged, e.g., power of attorney, share
certificate of co-operative group housing society, `no objection certificate' from
the society/lessor (in the case of leasehold properties) for offering the property as
security, etc.
2.273 In case the bank have accepted third party property as a security. The
owner of the property should also execute guarantee bond in bank's favour. The
mortgage value in bank's favour should be equal/in excess of loan amount
covered by such mortgage.
Reliance on / review of other reports
2.274 The auditor should take into account the adverse comments, if any, on
advances appearing in the following:
Previous years audit reports.
Latest internal inspection reports of bank officials.
Reserve Bank's latest inspection Report/Asset Quality Review/ Risk Based
Supervision report.
Concurrent /internal audit report.
Report on verification of security.
Any other internal reports specially related to particular accounts.
Manager's charge-handing-over report when incumbent is changed.
2.275 The above reports should be reviewed in detail. The SCAs must review
the Annual Financial Inspection report of RBI relating to the bank and should
check whether the variations in provisions, etc., reported by RBI have been
properly considered by the bank management. The statutory auditors should
consider the issues emerging from recent RBI inspections and obtain an
understanding of changes made by the banks pursuant to the inspection process
to enhance their identification of NPA. Further, the audit procedures should be
suitably re-designed to consider such issues.
Third Party Guarantees
2.276 The auditor should examine the guarantee bonds and the demand
promissory notes in order to verify the third party liability. Auditor should satisfy
that the guarantee is in force as at the date of the balance sheet. In the absence
of a provision to the contrary, a guarantee terminates by revocation or upon
death of the surety. The surety is also discharged (unless there is a specific
covenant to the contrary) if the creditor arranges with the principal debtor for
compromise, or agrees to give time or agrees not to sue him, without consulting
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the surety. If any variation is made in the terms of the contract between the
principal debtor and the creditor without the surety's consent, it discharges the
surety as to transactions subsequent to the variation. The guarantee forms used
by banks normally seek to ensure the continuing obligation of the guarantor in
spite of these contingencies. If such clause is absent then Auditor has to see the
acknowledgement to debt from the borrower as well as guarantor is obtained by
the Bank.
Verification of Bills Purchased and Discounted
2.277 The auditor should familiarise with the guidelines issued by RBI and the
policies framed by the bank itself regarding the discounting and rediscounting of
bills. The auditor should ascertain that the policy framed by the bank conforms to
the requirements laid down by the RBI.
2.278 Bills purchased and discounted have to be shown separately in the
balance sheet as a part of `advances'. Further, under the head `advances outside
India' in the balance sheet, bills purchased and discounted outside India have to
be shown separately. This category will include bills covering export of goods,
bills discounted by foreign branches of the bank and payable in their respective
countries, etc.
2.279 Banks purchase or discount bills of exchange drawn or endorsed by
their customers. The bank credits the amount of the bill to its customer after
deducting the discount. The total amount of such bills is shown as an asset in the
balance sheet.
2.280 In certain eligible cases, the bills purchased or discounted by the bank
may be rediscounted by it with the RBI IDBI/SIDBI. Such bills would not be
included under advance but would constitute a contingent liability.
2.281 Bills purchased and discounted by the bank are generally drawn on
outstation parties and are, therefore, sent by the bank to its branches or agents
for collection immediately after their receipt. They are generally not in the
possession of the bank on the closing date. The auditor therefore has to rely
upon the Register of Bills Purchased and Discounted and the party-wise Register
of Bills maintained by the bank. The auditor should examine these registers and
satisfy himself that:
(a) all the outstanding bills have been taken in the balance sheet;
(b) all the details, including the nature of the bills and documents, are
mentioned in the register and that the bills have been correctly classified;
(c) the bills purchased or discounted from different parties are in accordance
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Guidance Note on Audit of Banks (Revised 2019)
with the agreements with them and the total of outstanding bills of each
party is not in excess of the sanctioned limit; and
(d) the bills are not overdue. If there are any overdue bills, the auditors should
ascertain the reasons for the delay and the action taken by the bank.
2.282 The auditor should examine whether registers of bills purchased and
discounted are properly maintained and the transactions are recorded therein
correctly. He should examine whether the bills and the documents accompanying
the bills are properly endorsed and assigned in favour of the bank. In checking
the bills, it should be ensured that the bills are held along with the documents of
title. In the case of documentary bills, it should be examined whether that the
related RRs/TRs are held along with the invoices/ hundies / bills and that these
have not been parted with. Wherever such RRs/TRs are not held on record, the
fact should be duly considered by the auditor. The auditor should also examine
bills collected subsequent to the year-end to obtain assurance regarding
completeness and validity of the recorded bill amounts.
Verification of Buyer's Credit Transaction
2.283 Following documents are required to be verified by the statutory
auditors during review of Buyers' Credit Transaction and its accounting treatment
in the Indian Bank's books.
(a) (Loan) Agreement, if any, entered between the Indian importer (borrower),
overseas bank (lender), the Indian bank (facilitator);
(b) Underlying documents for import of capital goods or raw materials;
(c) Maximum tenure of buyer's credit as per guidelines of RBI;
(d) SWIFT messages originated by overseas bank specifying the terms of
Buyer's Credit;
(e) The calculation of contingent liability towards LoC/ LoU is inclusive of
interest accrued on the Buyer's Credit as on financial statement date;
(f) Documentation / Agreement between overseas bank and Indian bank, and,
any further confirmatory documents exchanged between overseas bank
and Indian bank;
(g) Review of documents specifying right of recovery against borrower, in case
if the borrower defaults in repayment of Buyer's Credit;
(h) Balance confirmations obtained from the overseas bank;
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Advances-Other than Agriculture
(i) Charge created in records of RoC related to the security offered for Buyer's
Credit vis-à-vis disclosure of Buyer's Credit in the financials of borrowers as
secured / unsecured loan;
(j) Acknowledgement of debt, if any, obtained from the borrower;
(k) The calculation of drawing power for working capital finance availed by the
borrower is net of the Buyer's Credit;
(l) Form 15CA / Form 15CB compliance made by the borrower.
The RBI vide its circular dated March 13, 2018, has advised the AD Category I
banks to discontinue the practice of issuance of LoUs / LoCs for Trade Credits
for imports into India with immediate effect.
Other Aspects
2.284 Sometimes, a customer is sanctioned a cash credit limit at one branch
but is authorised to utilise such overall limit at a number of other branches also,
for each of which a sub-limit is fixed. In such a case, the determination of status
of the account as NPA or otherwise should be determined at the limit-sanctioning
branch with reference to the overall sanctioned limit/drawing power, and not by
each of the other branches where a sub-limit has been fixed. The auditor of the
limit-sanctioning branch should examine whether it receives particulars of all
transactions in the account at sub-limit branches and whether the status of the
account has been determined by considering the total position of operation of the
account at all concerned branches. As far as sub-limit branches are concerned,
they should follow the classification adopted by the limit-sanctioning branch.
2.285 The auditor should examine that any advances made by a banking
company otherwise than in the course of banking business, such as, prepaid
expenses, advance for purchase of assets, etc., is not included under the head
`advances' but is included under `other assets'.
2.286 The amounts of advances in India and those outside India are to be
shown separately in the balance sheet. This classification will depend upon
where the advance was actually made and not where it has been utilised.
Generally speaking, figures of Indian branches will be shown as advances in
India and figures of foreign branches as advances outside India.
2.287 The auditor should examine whether any loan has been granted in
violation of the statutory limitations contained in section 20 of the Banking
Regulations Act, 1949. If any such loan has been granted the report will have to
be drafted with suitable qualifications, as the transaction would be ultra vires.
2.288 It may also be examined whether the bank has a system of ensuring the
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Guidance Note on Audit of Banks (Revised 2019)
end use of the funds granted as compared with the purpose of sanction. The
reports submitted by the inspectors/officers in this regard should be reviewed to
form opinion on the quality of the asset and also to consider reporting any matter
in the LFAR.
2.289 Adverse features in a borrower's account are required to be reported in
LFAR and hence during the course of verification all material information should
be noted and documented in appropriate format. Following is an illustrative but
not an exhaustive format:
1. Name of the Borrower.
2. Constitution.
3. Sanctioned limits as on Balance Sheet date.
4. Any change in limit during the year.
5. Terms of sanction.
6. Details of fulfilment of terms of sanction.
7. Details of Loan documents and observations on the same.
8. Balance outstanding as at balance sheet date.
9. Classification as per bank.
10. Whether classification requires a change.
11. If so the reasons for the differing view and the impact of the same.
12. Whether necessary changes made in Memorandum of Changes.
13. Observations on the conduct of the account.
14. Deficiencies noted in the account.
15. Availability of security and adequacy of its insurance cover along with
Bank's name.
16. Timely submission of stock statement and other statements.
17. Analysis of stock statements vis a vis financial statements.
Drawing Power Consideration
2.290 Working capital borrowal account, drawing power calculated from stock
statement older than 3 months has to be considered as "irregular" (overdue). If
such "irregular" continues for 90 days, account has to be classified as NPA, even
though the account is otherwise operated regularly.
2.291 The stock statements, quarterly returns and other statements submitted
by the borrower to the bank should be scrutinised in detail.
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Advances-Other than Agriculture
2.292 The audited Annual Report submitted by the borrower should be
scrutinised properly. The monthly stock statement of the month for which the
audited accounts are prepared and submitted should be compared and the
reasons for deviations, if any, should be ascertained.
2.293 It needs to be examined whether the drawing power is calculated as per
the extant guidelines formulated by the bank, which should also be in line with
RBI guidelines/directives. Special consideration should be given to proper
reporting of sundry creditors for the purposes of calculating drawing power.
2.294 The stock audit should be carried out by the bank for all accounts
having funded exposure of more than Rs.5 crores. Auditors can also advise for
stock audit in other cases if the situation warrants the same. Branches should
obtain the stock audit reports from lead bank or any other member, as decided in
consortium in the cases where the Bank is not leader of the consortium of
working capital. The report submitted by the stock auditors should be reviewed
during the course of the audit and special focus should be given to the comments
made by the stock auditors on valuation of security and calculation of drawing
power.
2.295 The drawing power needs to be verified carefully in case of working
capital advances to entities engaged in construction business. The valuation of
work in progress should be ensured in consistent and proper manner. It also
needs to be examined whether the mobilization advance being received by the
contractors is reduced while calculating drawing power. Further in respect of
certain businesses such as diamond merchants and jewellers, the auditor should
exercise due caution while verifying realisable value of the inventory of precious
metals, diamonds, jewellery etc. The auditor may also consider obtaining
assistance of an expert in case circumstances so warrant.
2.296 In case of consortium accounts, the drawing power calculation and
allocation is made by the Lead Bank and is binding on the Member Banks.
Lending under Consortium Arrangement / Multiple Banking
Arrangements
2.297 In order to strengthen the information sharing system among banks in
respect of the borrowers enjoying credit facilities from multiple banks, the banks
are required to obtain regular certification by a professional, preferably a
Company Secretary, Chartered Accountants or Cost Accountants regarding
compliance of various statutory prescriptions that are in vogue, as per specimen
given in Annexure III (Part I and II), to the RBI Circular No. DBOD.No.
BP.BC.110/08.12.001/2008-09 dated February 10, 2009.
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Guidance Note on Audit of Banks (Revised 2019)
2.298 The LFAR should include non-compliance of the RBI Circular, indicating
the cases in which the reports have not been obtained for review by the auditors.
2.299 Accounts under Consortium arrangements may, notwithstanding that
these are classified as Standard, due to servicing thereof in a Bank, may
nonetheless be intrinsically weak or may even be NPA in other participating
bank(s), including on the basis of the certificate/report as aforesaid. The auditor
should consider this aspect and classify the account appropriately based on facts
and circumstances, particularly based on any serious adverse
remarks/comments in the certificate issued pursuant to the RBI circular.
2.300 The auditor should check the compliance with RBI guidelines on
unhedged foreign currency exposure. Self-declaration from the client or
Independent auditors' certificate of foreign currency exposure should be obtained
by the Bank. Such declaration/certificate can be cross checked with the
computation of standard asset provisioning.
Retail Assets
2.301 The retail assets in various banks at present form a significant part of
their portfolio. As there are large numbers of accounts in these cases, the same
poses a challenge for the auditors. The classification and provisioning towards
the same should, however, be done as in case of other assets.
2.302 There may be a large number of accounts under retail assets, which
have been restructured/rescheduled during respective years including repetitive
rephasements. The process of the bank to report / record all such
reschedulement/restructuring needs to be reviewed and adequacy of the same
should be checked. In case of restructuring of consumer and personal advances,
the same should immediately be treated as NPA. The accounts are treated as
restructured when the bank, for economic or legal reasons relating to borrower's
financial difficulty, grants to the borrower concessions that the bank would
otherwise not consider. The HO of the bank should instruct properly to branches
in this regard.
Restructuring of cases
2.303 RBI has given guidelines for treatment of restructured accounts in part B
of the Master Circular on Prudential Norms on Income Recognition, Assets
Classification and Provisioning Pertaining to Advances dated July 1, 2015.
Further, RBI has issued circular dated February 12, 2018 regarding Resolution of
Stressed Assets Revised Framework. The provisions of this Circular has been
discussed in Chapter 4 of Part III of Guidance Note. The auditor should verify
compliance with the requirements of the said circular.
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Advances-Other than Agriculture
Once the bank receives an application/proposal in respect of an account for
restructuring, it implies that the account is intrinsically weak. Thereby during the
time the account remains pending for restructuring, the auditors need to take a
view whether provision needs to be made in respect of such accounts pending
approval for restructuring.
Funding of Interest
2.304 In addition, the auditor should also consider the fact that during the
course of restructuring/rescheduling in any manner, the interest element, in
addition to the principal may also be rescheduled by the bank. This
reschedulement of interest may be with or without sacrifice. In some cases future
interest may also be funded apart from the principal. In such cases, the auditor
should examine whether the RBI's requirements with regard to provisioning for
sacrifice have been complied with by the bank. In case of interest sacrifice, the
model prescribed by RBI includes calculation and provisioning for sacrifice on
future interest as well. The auditor should examine the terms of funding of
interest and if the same is in the nature of moratorium for payment of interest,
then the interest would become due only after the moratorium period is over. The
funded interest cannot be recognised as income if the account is treated as NPA.
Sacrifice of interest
2.305 In respect of sacrifice of interest, the auditor should examine whether:
(a) Interest sacrifice involved in the amount of interest has been provided for by
debit to Profit & Loss account and held in a distinct account.
(b) Sacrifice is recomputed on each balance sheet date till satisfactory
completion of all repayment obligations and full repayment of the
outstanding in the account, so as to capture the changes in the fair value
on account of changes in BPLR/ Base Rate, term premium and the credit
category of the borrower and the consequent shortfall in provision or
reversal of the amount of excess provision has been held in the distinct
account.
(c) In the event any security is taken against interest sacrifice, the same has
been valued at Re.1/- till maturity of the security. As per RBI norms, the
interest sacrifice in all the restructured cases needs to be worked out
including for Working Capital Loans. In the case of working capital
facilities, the diminution in the fair value of the cash credit /overdraft
component may be computed reckoning the higher of the outstanding
amount or the limit sanctioned as the principal amount and taking the
tenor of the advance as one year. The term premium in the discount factor
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Guidance Note on Audit of Banks (Revised 2019)
would be as applicable for one year. The fair value of the term loan
components (Working Capital Term Loan and Funded Interest Term Loan)
would be computed as per actual cash flows and taking the term premium
in the discount factor as applicable for the maturity of the respective term
loan components. The process of identifying such interest sacrifice in case
of working capital loans needs to be looked upon in detail.
2.306 In case the bank has agreed to convert existing/future exposure to the
borrower in to Funded Interest Term Loan, such interest should be parked under
sundry liabilities and should not be reckoned as income.
Other Aspects
2.307 Separate norms for classification have been prescribed for accounts
covered under schemes for `Restructuring / Rescheduling of Loans', `Corporate
Debt Restructuring (CDR)' or `Small & Medium Enterprises (SME)'. The auditors
should go through the same to see whether these have been properly applied by
the bank.
2.308 The Branch Auditor is advised to verify the advances based on the
criteria for the selection as per "Illustrative list of Basis of selection of Advances
accounts in case of Bank Branch Audit" as given in the Pen Drive/CD.
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III-3
Scrutiny of Advance Accounts
Presented in Ind AS by
Borrowers
Introduction
3.01 The Ministry of Corporate Affairs (MCA) on 6th April 2016 amended
Schedule III of Companies Act 2013 to include general instructions for
preparation of financial statements of a company whose financial statements are
required to comply with Ind AS.
3.02 The amendment is applicable to following classes of companies from 1
April 2016:
Companies listed/ being listed and Net worth is Rs. 500 crore or more.
Unlisted Companies whose Net worth is Rs. 500 crore or more.
Holding/ Subsidiary/ Joint Venture or associate of above.
3.03 From 1 April 2017, the amendment will also be applicable to following
classes of companies:
All other Companies listed/being listed.
Unlisted Companies whose Net worth is Rs. 250 crore or more and less
than Rs. 500 crore.
Holding/ Subsidiary/ Joint Venture or associate of above.
3.04 The amendment divides Schedule III into two parts i.e. Division I and II.
Division II covers the complete set of Financial Statements under Ind AS which
include:
1. Balance Sheet.
2. Statement of Profit and Loss divided in two parts as profit or Loss section
and Other Comprehensive Income.
3. Statement of changes in equity.
4. Cash Flow Statement.
5. Notes.
Guidance Note on Audit of Banks (Revised 2019)
3.05 Banks often refer to the Financial Statements of companies for credit
decision regarding new lending, review and credit monitoring in the form of end
use of funds, ratio analysis etc. The Financial statements are thus treated as
Base Document for the purpose of Credit Appraisal, Review and monitoring.
Since the accounting treatment, disclosures and formats of Financial statements
have changed due to compliance with Ind AS, it is important for Banks to
understand the intricacies of this changing reporting structure.
Major Financial Impacts (List is illustrative)
3.06
1. Property, Plant & Equipment (IND AS 16)
Key Area Impact
For first time adoption three option First two options will lead to changes in
of transition are available- Debt equity ratio.
a. Recomputation of cost as In case of fair valuation, value adopted
on transition date since by the company vis-a-vis considered
inception. by the bank (for collateral security)
b. Fair Valuation of PPE as on needs to be cross referenced.
transition date. It needs to be analysed whether fair
c. Carrying value of PPE as of value option has been availed and how
transition date as per Indian it impacts the financial position and
GAAP. future cash flows.
The difference between fair value and
carrying value of assets is transferred
to retained earnings as at date of
transition (not revaluation surplus).
This reflects an inflated networth. For
networth assessment, it might be
necessary to evaluate increase in
networth due to fair valuation and
increase due to increase in earnings.
Decommissioning, restoration and Such accounting treatment will have
similar liabilities: following impact:
To be recognised as part of Increased depreciation.
the cost of an item of PPE. Increase in interest cost due to
To be recognised as a liability unwinding of discounted liability.
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Scrutiny of Advance Accounts Presented in Ind AS by Borrowers
in accordance with Ind AS 37. Whenever such type of provision is done,
the nature and impact of such provision
should be analyzed. Detailed calculation
should be checked for analyzing the
possible deviations.
Spare parts There will be addition to PPE incase
Spare parts are to be spare that were earlier classified as
recognized as Property, Plant inventory are reclassified as PPE.
and Equipment if they are It will impact the current ratio
held for use in production or (inventory will decrease) and also
supply of goods or services fixed assets turnover ratio.
and are expected to be used Also, the value of spares included in
during more than one period. PPE needs to be considered while
Otherwise such items are to hypothecating the assets.
be recognized as Inventory
Pre-operative expenses It is essential to note the reason of
Pre-operative expenses are change in valuation of PPE.
specifically excluded from the In case pre-operative expenses have
cost of Property, Plant and been capitalized previously, they need
Equipment (such expenses to be excluded from carrying cost of
were capitalized under PPE. Thus, the opening block of
Previous GAAP). assets will reduce. Also, depreciation
relating to pre-operative expenses
(capitalized under previous GAAP) will
be reversed.
Any movement in PPE also impact the
assets hypothecated and fixed assets
turnover ratio.
2. Investment Property (IND AS 40)
Key Area Impact
IND AS 40 requires separate Information about assets held for capital
disclosure in Balance sheet for appreciation/rental purposes will be
assets which qualifies as separately available.
Investment property as follows: Such readily available information will be
Fair value of Investment useful in assessing the real net worth of the
Properties. company. Also, details of method used to
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Guidance Note on Audit of Banks (Revised 2019)
Revenue generating and non- calculate fair value will be useful in
revenue generating assessing the possible deviations in value.
Investment properties with This disclosure will give an idea of the
details of income and direct income earning capacity. This may also
operating expenses. give indication about the fair value of the
Restrictions on realizability property.
and contractual commitments. This information about all encumbrances
will help in analyzing the practical
usefulness of the property.
From banker's perspective, while
computing the total value of land,
investment property also needs to be
considered.
3. Accounting for Government Grants and disclosure of Government
Assistance (IND AS 20)
Key Area Impact
Government grants are bifurcated It is pertinent to note that IND AS 20 does
in two categories: not recognize the concept of grant in the
Grants related to assets; and nature of promotors contribution. Thus,
concept of capital reserve has been done
Grants related to income.
away with.
Para 24 states that Government
Recognition of grant as operating income
grants related to assets, including
will increase the EBITDA.
non-monetary grants at fair value,
shall be presented in the balance This disclosure requirement allows the
sheet by setting up the grant as stakeholders to assess the nature and
deferred income. impact of liabilities attaching the assistance
received.
Disclosure regarding unfulfilled
conditions and other
contingencies attaching to
government assistance that has
been recognized.
4. Revenue (IND AS 18)
Key Area Impact
Para 9 states that revenue shall Grossing up of excise duty.
be measured at the fair value of This will have an impact while
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Scrutiny of Advance Accounts Presented in Ind AS by Borrowers
the consideration received or comparing information with earlier
receivable. As a result: periods.
Revenue is to be presented Any sales incentive, discounts or
gross of excise duty; and rebates in any form, including cash
Revenue is to be presented discounts given to customers will be
net of incentives, quantity considered as selling price reductions
discounts, trade discounts, and accounted as reduction from
volume rebates, etc. revenue. Under IGAAP, some of these
costs were included in `advertising and
sales promotion' expenses.
Reduction in revenue by large amounts
where the company operates customer
loyalty programs/discount coupons/gift
vouchers, etc.
Para 11 states that when the Whenever the sale is made at deferred
arrangement credit terms, revenue will be reduced and
effectively
constitutes a financing transaction, will be recognized as interest in other
the fair value of the consideration income.
is determined by discounting all
future receipts using an imputed
rate of interest.
Ind AS 115 Revenue from The change from Ind AS 18 to Ind AS
contract with customers 115 is mainly in the timing of
st
(Applicable from 1 April 2018) recognizing revenue.
Ind AS 115 prescribes a five- In case revenue recognized is deferred
step revenue recognition as compared to Ind AS 18, inventory
model. will continue to exist in the books of
Entities will have to focus on accounts. Conversely, if revenue is
defining performance recognized, receivables will increase.
obligation and determining The impact on either receivables or
transfer of control. inventory will affect the drawing power
The income terms may not and current ratio.
necessarily depict the transfer
of control in real sense.
Hence identification of point
of transfer and thereby
recognizing revenue is
essential.
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Guidance Note on Audit of Banks (Revised 2019)
5. Inventories (IND AS 2)
Key Area Impact
Para 36 of IND AS 2 requires The stakeholders will be able to analyze the
disclosure of the amount of any quantum of the non moving inventories. This
write-down of inventories can be utilized while calculating drawing
recognized as an expense in the power.
period.
6. Events after the Reporting Period (IND AS 10)
Key Area Impact
Para 12 states that If an entity This change will have huge impact on the
declares dividends to holders of retained earnings of many companies.
equity instruments (as defined in Dividends recognized as liability will now be
Ind AS 32, Financial Instruments: added back to reserves which will largely
Presentation) after the reporting impact the debt equity ratio.
period, the entity shall not
recognise those dividends as a
liability at the end of the reporting
period.
7. Accounting Policies, Changes in Accounting Estimates and Errors
(IND AS 8)
Key Area Impact
Para 32 states that changes in Earlier, change in the method of depreciation
the useful lives of, or expected was considered as a change in accounting
pattern of consumption of the policy. However, IND AS 8 regards it as
future economic benefits change in estimate.
embodied in, depreciable assets
This change implies that the changes in
are to be regarded as changes
depreciation method will have to be
in estimates.
accounted for prospectively as against the
earlier treatment of retrospective application.
Such change is very important since it will
restrict the companies from profit
management by using changes in
depreciation method as a tool.
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Scrutiny of Advance Accounts Presented in Ind AS by Borrowers
8. Financial Instruments (IND AS 109, IND AS 32)
Key Area Impact
Para 15 of IND AS 32 states that The definition of equity has wide impact on
the issuer of a financial the various instruments issued by the
instrument shall classify the company. This standard gives importance to
instrument, or its component substance over form. Thus, classification of
parts, on initial recognition as a an instrument into equity or liability is very
financial liability, a financial asset crucial.
or an equity instrument in Such classifications might change the entire
accordance with the substance composition of the balance sheet.
of the contractual arrangement
This might have significant impact on the
and the definitions of a financial
debt-equity ratio of the company as well as
liability, a financial asset and an
P&L.
equity instrument.
Real estate and start ups will be most
affected.
Preference shares The reclassification of preference
The preference shares are shares from equity to debt will impact
classified as financial the entire composition of debt and
liability. equity.
The liability was initially The opening equity will go down, the
recognized on fair value and profitability will also have a negative
considering these shares impact.
are issued to promoters, the The major impact will be on the debt-
difference between the fair equity ratio.
value and transaction price Bankers will have to specifically
as deemed equity consider such adjustment as the debt
contribution by promoters. will increase substantially due to this
Subsequently, the liability is adjustment.
measured at amortised cost
using effective interest rate.
The impact on this account
is recognized in the reserve
on the transition date and
the subsequent impact is
recognized
Foreign currency convertible Interest cost will be increased since in these
bonds (FCCB) cases the premium to be paid while
redemption is to be factored at the time of
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Guidance Note on Audit of Banks (Revised 2019)
issue of loan instrument itself.
Structured Instrument Impact on the interest cost to a large extent
Wherever instruments have been structured
to provide for lower interest rates at the
beginning and higher interest rates towards
the end, such instruments will have to be fair
valued w.r.t the prevailing market interest
rates and accounting will have to be done
accordingly.
Compound Financial instruments An instrument may contain an option to
Para 28 of IND AS 32 states that convert the debt instrument into equity.
the issuer of a non-derivative Here, since the instrument contain both the
financial instrument shall features of equity and debt, the amount
evaluate the terms of the needs to be bifurcated into equity and debt
financial instrument to determine by computing the fair value of the equity
whether it contains both a liability portion.
and an equity component. Such
components shall be classified
separately as financial liabilities,
financial assets or equity
instruments in accordance with
paragraph 15.
Classification of investments The strategic investments made by the
For equity instruments not held company will be classified as FVTOCI. The
for trading the standards fluctuations in the fair value will not affect
provides two options FVTOCI P&L but affect the reserves. The Bank can
and FVTPL. judge the group structure and its
performance.
Investments held for trading will
always be classified as FVTPL. All fluctuations in fair value will be accounted
for in P&L. Careful study for the purpose of
profitability is needed here by Banks.
There will be an initial substantial impact on
the networth as the fair value gain/loss will
be transferred to retained earnings. Majorly
the networth of Ind AS compliant entities has
inflated due to this adjustment. But, the
profitability in the future years will be volatile
as the fair value gain/loss will be transferred
to profit or loss each year. For companies
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Scrutiny of Advance Accounts Presented in Ind AS by Borrowers
who are in the process of setting up and
have invested surplus funds, the profit may
be high due to fair valuation of investments
rather than from operations.
Loans extended with conversion Such accounting treatment will ensure the
option real value of loans extended in the balance
Such loans will always be sheet. Wherever the companies are loss
classified as FVTPL since SPPI making, fair value of loans advanced to such
criteria is not met. companies will be a crucial aspect.
Fair valuation of startup Since FVTPL instruments will have direct
companies Crucial aspect impact on P&L Wherever the companies
have invested in startups, fair valuation of
such investments will always be crucial. It
would vary based on the business
performance.
Investments in mutual funds P&L volatility will increase due to the fair
It will be classified as FVTPL valuation of investments on mutual funds.
instrument since SPPI criteria
will not be met. Also, it will
always be held for trading.
Classification of a liability/asset A financial liability/asset implies that the
An entity needs to classify a settlement will be either in cash or by
liability as financial or other transfer of other financial liability/asset.
liability as well as an asset as a Other liabilities/asset implies settlement in
financial or other asset. other than cash mostly through delivery of
The classification of liability/asset services/goods.
into financial or other is very This classification to a large extent provides
important since the provisions of insight about the liabilities in monetary and
IND AS 109 applies to only non monetary terms.
financial liabilities/asset. Thus, the stakeholders might be able to
approximate the cash flows of the company
at a gross level.
Impact of expected credit loss The companies needs to evaluate the
model increases in credit risks associated with the
Para 5.5 of IND AS 109 requires financial assets and make loss allowance in
impairment of financial assets the books of accounts wherever required.
based expected credit loss The stakeholders can enquire about the
model. Two approaches have details of assessment made by the company
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Guidance Note on Audit of Banks (Revised 2019)
been specified: for evaluating the credit risks of the financial
General approach assets.
Simplified approach Similarly such enquiries can be made for
other major financial assets also.
Security deposits Since the deposits are discounted, the
Under Ind AS, all financial opening equity goes down whereas the
assets are required to be profitability goes up. It also impacts the
recognised at fair value. current ratio negatively.
Under Ind AS, security Security deposits are usually seen in all
deposits are measured at companies either in the form of
fair value at inception and electricity deposits, telephone deposits,
measured at the higher of statutory deposits, lease deposits, etc.
the amortised value or the Statutory deposits are not discounted.
obligation amount in case it
is probable that the amount
is payable/receivable.
9. Business Combinations (IND AS 103)
Key Area Impact
No concept of appointed date or IND AS recognizes only the date when the
effective date control is obtained. This implies that
agreements entered into will form basis of
accounting.
Intangible assets needs to be All kinds of intangible assets to be identified
carved out separately from goodwill and accounted for in
a business combination at fair value. This will
provide real information about what the
company is paying for. It will provide true
value of goodwill after identifying all other
intangibles.
Measurement at fair value - The This requirement ensures that the
acquirer shall measure the businesses are being acquired at real values.
identifiable assets acquired and It will provide readily available data to
the liabilities assumed at their stakeholders about the true values of
acquisition-date fair values. businesses being acquired.
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Scrutiny of Advance Accounts Presented in Ind AS by Borrowers
10. Disclosure Impacts
a. Presentation of Financial Statements (IND AS 1)
Key Area Impact
Capital Management This is an important disclosure with regard to
the capital management policy of the
Para 134 states that an entity
company.
shall disclose information that
enables users of its financial This disclosure gives information about
statements to evaluate the what are the objectives of the company
entity's objectives, policies and w.r.t the capital requirements/adequacy.
processes for managing capital.
It describes the policies adopted by the
company to achieve the objectives set
by the company.
Further, it also provides useful
information about the steps which the
company takes to adhere to the
policies.
The above information showcases the overall
thought process of the company i.e. the
policies adopted to maximize shareholder
value, what kind of risks and how much risk
the company is willing to take, the need for
raising capital.
b. Operating segment (IND AS 108)
Key Area Impact
New concept of Chief operating Major change in the disclosure requirements.
decision maker (CODM) Stakeholders will get to know how the
introduced. businesses are getting managed, the overall
decision making process and the allocation of
Operating segments to be
resources of the company.
disclosed based on how CODM
reviews the operating results. Information of revenues against each
product/service offered by the company is
Apart from the segment
useful for analyzing the major stream.
disclosures, following entity wide
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Guidance Note on Audit of Banks (Revised 2019)
disclosures are mandatory: Information about exports and assets located
Information about products outside India will provide information about
and services. the major area of operation of the company.
Information about This will provide information about the
geographical areas. concentration of the source of revenue of the
company which enables to analyse the
Information about major quantum of risks associated.
customers. (revenue above
10%)
c. Financial Instruments (IND AS 107)
Key Area Impact
This standard requires wide Such disclosures enable the stakeholders to
disclosures in relation to analyze what kind of risk the company is
financial instruments. Some of exposed to and the quantum of risk. This will
them are as under: enable to ascertain the possible impact on
the profitability of the company.
Disclosures regarding nature
and extent of risks arising from Credit risk disclosure enables the user of
financial instruments (Para 31- financial statements to understand the effect
39): of credit risk on the amount, timing and
uncertainty of future cash flows.
Credit risk
Liquidity risk disclosures enables the user of
Liquidity risk
financial statements to understand the
Market risk information such as maturity profile of the
financial liabilities which gives an idea about
the requirement of cash and it's sufficiency
as well as information about policies to
manage liquidity needs.
Sensitivity Analysis of market Such information enables the stakeholders to
risks (Para 40-42): analyse the exposure to each type of market
Foreign currency risks risk and the possible volume of change that
could affect the financial position of the
Interest rate risks
company.
Other price risks
Further, the disclosures regarding how
company manages such risks also provides
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Scrutiny of Advance Accounts Presented in Ind AS by Borrowers
useful information regarding the mitigation
plan in case the risk materialize and also the
sufficiency of such management.
All these disclosures regarding the risk
exposure and management gives vast
information and enables the stakeholders for
internal credit rating purposes.
11. Leases (Ind AS 17)
Key Area Impact
Lease of land As per international practices, lease of
As per Ind AS 17, where the land above 999 years is considered as
substantial risks and finance lease, else, as operating lease.
rewards incidental to Many companies have reclassified the
ownership of an asset leased land from finance lease to
(including Land) has been operating lease. This leads to an addition
transferred, it is considered in the non-financial assets and decrease
as Finance lease, else, as in PPE.
Operating Leases. It needs to be analysed if such land has
been hypothecated.
It will also impact the fixed assets
turnover ratio.
Interest free Security Deposit It has an overall negative impact on
under a lease opening equity, profitability during
Under Ind AS, all financial transition, profitability subsequent to
assets are required to be transition and current ratio.
recognised at fair value.
The difference between
the fair value and the
transaction price is
recognized as prepaid rent
and amortised over the
lease term. Deposit asset
is subsequently measured
at amortised cost resulting
into finance income in the
statement of profit and
loss.
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Guidance Note on Audit of Banks (Revised 2019)
12. Deferred tax (Ind AS 12)
Key Area Impact
Deferred taxes are Additional deferrd tax assets/liabilities are
recognized for future tax now created on those adjustments that
consequences of temporary are routed through other than income
differences between the statement.
carrying value of assets and The general impact on opening equity
liabilities in books and their and debt-equity ratio is negative.
respective tax base i.e.,
balance sheet approach.
(Income statement
approach was followed
under Previous GAAP)
13. Employee Benefits (Ind AS 19)
Key Area Impact
Under Ind AS, re- There is no impact on opening equity.
measurements i.e. actuarial The impact on profitability during
gains and losses and the transition and subsequent to transition is
return on plan assets on the usually positive.
net defined benefit liability
EPS is calculated on net profit from
are recognized under other
continuing operations. EPS is not
comprehensive income
calculated on OCI. The re-
(OCI).
measurements thus will not be included
in EPS calculation. Also, such re-
measurements shall form a part of
reserves and be presented in the
statement of changes in equity.
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III-4
Asset Classification, Income
Recognition and Provisioning
Guidelines of the Reserve Bank of India on Income Recognition,
Asset Classification, Provisioning and Other Related Matters
4.01 In its report submitted in 1992, the Committee on Financial System set
up by the RBI under the Chairmanship of Mr. M. Narasimham made several
recommendations concerning accounts of banks. The Committee
recommended that a policy of income recognition should be objective and
based on record of recovery rather than on any subjective considerations.
Likewise, the classification of assets should be done on the basis of objective
criteria which would ensure a uniform and consistent application of norms. As
regards provisioning, the Committee recommended that provisions should be
made on the basis of classification of assets under different categories. Vide its
Circular No. BP.BC.129/21.04.043-92 dated April 27, 1992, the Reserve Bank
issued guidelines to be followed by all scheduled commercial banks (excluding
regional rural banks) for income recognition, asset classification, provisioning
and other related matters. These guidelines (commonly referred to as
`prudential guidelines' or `prudential norms') have since been modified in
several respects through various circulars of the Reserve Bank. The latest
Master Circular No. RBI/2015-16/101DBR.No.BP.BC.2/21.04.048/2015-16 was
issued on July 1, 2015 on `Prudential Norms on Income Recognition, Asset
Classification and Provisioning Pertaining to Advances". The salient points of
the guidelines as presently in force are discussed below:
Non-Performing Assets
4.02 Under the guidelines, income recognition, and provisioning in respect
of a credit facility are based on its status of classification as performing or non-
performing. A credit facility becomes non-performing "when it ceases to
generate income for a bank". Detailed guidelines have been laid down for
determining the status of different kinds of credit facilities (term loans, cash
credits and overdrafts, bills purchased and discounted, and other credit
facilities) as performing or non-performing. These are discussed below:
Guidance Note on Audit of Banks (Revised 2019)
Criteria for Classification of Various Types of Credit Facilities
4.03 In line with the international best practices and to ensure greater
transparency, the RBI has directed the banks to adopt the `90 days' overdue'
norm for identification of NPAs from the year ending March 31, 2004.
4.04 Banks have been charging interest at monthly rests, from April 1,
2002. However, the banks should continue to classify an account as NPA only
if the interest charged during any quarter is not serviced fully within 90 days
from the end of the quarter.
4.05 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 also be treated as 'out of order'. Further, any amount due to the bank
under any credit facility is `overdue' if it is not paid on the due date fixed by the
bank.
4.06 The following criteria are to be applied for determining the status of
various types of credit facilities:
(a) Term Loans: A term loan is treated as a non-performing asset (NPA) if
interest and/or instalment of principal remain overdue for a period of
more than 90 days.
(b) Cash Credits and Overdrafts: A cash credit or overdraft account is
treated as NPA if it remains out of order as indicated above.
(c) Bills Purchased and Discounted: Bills purchased and discounted are
treated as NPA if they remain overdue and unpaid for a period of more
than 90 days.
(d) Securitisation: The asset is to be treated as NPA if the amount of liquidity
facility remains outstanding for more than 90 days, in respect of a
securitisation transaction undertaken in terms of guidelines on
securitisation dated February 1, 2006.
(e) Agricultural Advances: A loan granted for short duration crops will be
treated as NPA, if the instalment of principal or interest thereon remains
overdue for two crop seasons and, a loan granted for long duration crops
will be treated as NPA, if the instalment of principal or interest thereon
remains overdue for one crop season.
(f) Credit Card Accounts: credit card account will be treated as non-
performing asset if the minimum amount due, as mentioned in the
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Asset Classification, Income Recognition and Provisioning
statement, is not paid fully within 90 days from the payment due date
mentioned in the statement as per Circular
DBR.No.BP.BC.30/21.04.048/2015-16 dated July 16 2015. It is further
suggested by RBI that banks should follow this uniform method of
determining over-due status for credit card accounts while reporting to
credit information companies (CIC) and for the purpose of levying of penal
charges, viz., late payment charges, etc., if any.
4.07 As per the guidelines, "long duration" crops would be crops with crop
season longer than one year and crops, which are not "long duration" crops
would be treated as "short duration" crops. The crop season for each crop,
which means the period up to harvesting of the crops raised, would be as
determined by the State Level Bankers' Committee in each State. Depending
upon the duration of crops raised by an agriculturist, the above NPA norms
would also be made applicable to agricultural term loans availed of by him.
4.08 The above norms should be made applicable to all direct agricultural
advances as listed in the Master Direction on Lending to Priority Sector-Target
and Classification. In respect of all other agricultural loans, identification of
NPAs would be done on the same basis as non-agricultural advances, which,
at present, is the 90 days delinquency norm.
Classification Norms relating to NPAs
Temporary Deficiencies
4.09 The classification of an asset as NPA should be based on the record
of recovery. Bank should not classify an advance account as NPA merely due
to the existence of some deficiencies which are temporary in nature such as
non-availability of adequate drawing power based on the latest available stock
statement, balance outstanding exceeding the limit temporarily, non-
submission of stock statements and non-renewal of the limits on the due date,
etc. In the matter of classification of accounts with temporary deficiencies,
banks have to follow the following guidelines:
(a) Banks should ensure that drawings in the working capital account are
covered by the adequacy of the current assets, since current assets are
first appropriated in times of distress. Drawing Power (DP) is required to
be arrived at based on current stock statement. Proper computation of
drawing power (as per Bank's policy) is imperative as the advances are
to be checked with reference thereto. The auditor should review the
Bank's policy for treatment of creditor's balances for computation of DP.
However, considering the difficulties of large borrowers, stock
statements relied upon by the banks for determining drawing power
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Guidance Note on Audit of Banks (Revised 2019)
should not be older than three months. In case of consortium accounts,
the drawing power calculation and allocation is made by the Lead Bank
and is binding on the Member Banks (circular no. No. C&I/Circular/2014-
15/689 dated 29 September 2014 issued by the Indian Banks
Association).
(b) The outstanding in the account based on drawing power calculated from
stock statements older than three months is deemed as irregular.
(c) A working capital borrowing 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 borrower's financial position
is satisfactory.
(d) Regular and ad hoc credit limits need to be reviewed/ regularised not
later than three months from the due date/date of ad hoc sanction. In
case of constraints such as non-availability of financial statements and
other data from the borrowers, the branch should furnish evidence to
show that renewal/ review of credit limits is already on and would be
completed soon. In any case, delay beyond six months is not considered
desirable as a general discipline. Hence, an account where the regular/
adhoc credit limits have not been reviewed/ renewed within 180 days
from the due date/ date of adhoc sanction will be treated as NPA.
Regularisation Near About Balance Sheet date
4.10 The asset classification of borrower accounts where a solitary or a few
credits are recorded before the balance sheet date 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
about the manner of regularisation of the account to eliminate doubts on their
performing status.
Cheque bounce
4.11 In case the account is regularised by making payment through
cheque, the Auditor should review the actual realisation of cheques to assess
the NPA classification. In case, the cheque is bounced, same should not be
considered as credit in the Advance account for assessing the NPA
classification.
Asset Classification to be Borrower-wise not Facility-wise
4.12 All facilities granted to a borrower and investment made in securities
issued by the borrower will have to be treated as NPA/NPI, once any or a part
of the facility/investment has become irregular.
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Asset Classification, Income Recognition and Provisioning
4.13 In case 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 borrower's principal operating
account for the purpose of application of prudential norms on income
recognition, asset classification and provisioning. The following provisions are
given in the master circular in this regard:
(i) The bills discounted under LC favouring a borrower may not be classified
as a Non-performing advance (NPA), when any other facility granted to
the borrower is classified as NPA. However, in case documents under LC
are not accepted on presentation or the payment under the LC is not
made on the due date by the LC issuing bank for any reason and the
borrower does not immediately make good the amount disbursed as a
result of discounting of concerned bills, the outstanding bills discounted
will immediately be classified as NPA with effect from the date when the
other facilities had been classified as NPA.
(ii) The overdue receivables representing positive mark-to-market value of a
derivative contract will be treated as a non-performing asset, if these
remain unpaid for 90 days or more. In case the overdues arising from
forward contracts and plain vanilla swaps and options become NPAs, all
other funded facilities granted to the client shall also be classified as non-
performing asset following the principle of borrower-wise classification as
per the existing asset classification norms. Accordingly, any amount,
representing positive mark-to-market value of the foreign exchange
derivative contracts (other than forward contract and plain vanilla swaps
and options) that were entered into during the period April 2007 to June
2008, which has already crystallised or might crystallise in future and is /
becomes receivable from the client, should be parked in a separate
account maintained in the name of the client / counterparty. This amount,
even if overdue for a period of 90 days or more, will not make other
funded facilities provided to the client, NPA on account of the principle of
borrower-wise asset classification, though such receivable overdue for 90
days or more shall itself be classified as NPA, as per the extant IRAC
norms. The classification of all other assets of such clients will, however,
continue to be governed by the extant IRAC norms.
(iii) If the client concerned is also a borrower of the bank enjoying a Cash
Credit or Overdraft facility from the bank, the receivables mentioned at
item (ii) above may be debited to that account on due date and the impact
of its non-payment would be reflected in the cash credit / overdraft facility
account. The principle of borrower-wise asset classification would be
applicable here also, as per extant norms.
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Guidance Note on Audit of Banks (Revised 2019)
(iv) In cases where the contract provides for settlement of the current mark-
to-market value of a derivative contract before its maturity, only the
current credit exposure (not the potential future exposure) will be
classified as a non-performing asset after an overdue period of 90 days.
(v) As the overdue receivables mentioned above would represent unrealised
income already booked by the bank on accrual basis, after 90 days of
overdue period, the amount already taken to 'Profit and Loss a/c' should
be reversed and held in a `Suspense Account-Crystallised Receivables' in
the same manner as done in the case of overdue advances.
(vi) Further, in cases where the derivative contracts provide for more
settlements in future, the MTM value will comprise of (a) crystallised
receivables and (b) positive or negative MTM in respect of future
receivables. If the derivative contract is not terminated on the overdue
receivable remaining unpaid for 90 days, in addition to reversing the
crystallised receivable from Profit and Loss Account as stipulated in para
above, the positive MTM pertaining to future receivables may also be
reversed from Profit and Loss Account to another account styled as
`Suspense Account Positive MTM'. The subsequent positive changes in
the MTM value may be credited to the `Suspense Account Positive
MTM', not to P&L Account. The subsequent decline in MTM value may be
adjusted against the balance in `Suspense Account Positive MTM'. If
the balance in this account is not sufficient, the remaining amount may be
debited to the P&L Account. On payment of the overdues in cash, the
balance in the `Suspense Account-Crystallised Receivables' may be
transferred to the `Profit and Loss Account', to the extent payment is
received.
(vii) If the bank has other derivative exposures on the borrower, it follows that
the MTMs of other derivative exposures should also be dealt with /
accounted for in the manner as described in para above, subsequent to
the crystallised/settlement amount in respect of a particular derivative
transaction being treated as NPA.
(viii) Since the legal position regarding bilateral netting is not unambiguously
clear, receivables and payables from/to the same counterparty including
that relating to a single derivative contract should not be netted.
(ix) Similarly, in case a fund-based credit facility extended to a borrower is
classified as NPA, the MTMs of all the derivative exposures should be
treated in the manner discussed above.
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Asset Classification, Income Recognition and Provisioning
4.14 The Auditor needs to ensure that each customer of the bank is tagged
under one single Customer ID in respect of all its accounts, including those in
which credit facilities are granted, irrespective of their location, to enable the
bank, (subject to the relaxations/exceptions for the time being applicable to any
account/facility), to accord the same NPA classification status to the
customer/borrower, based on the most adverse classification determined for any
of its account/ facility. The auditor should also review the facilities enjoyed by
such borrower's related or group entities. The NPA classification so made does
not automatically extend to such related or group entities, where the classification
would have to be judged based on independently, i.e., at the entity level and not
at a group level.
Non Financial Parameters
4.15 Normally NPA assessment is done based on record of recovery of
dues in advances account. However, there are many other non-financial
parameters which also should be considered while assessing classification of
NPA account such as:
Inherent weakness in account.
Non-Achievement of DCCO.
Failure to comply with key restructuring conditions.
Erosion in value of security.
All above aspects are dealt with in detail in various paragraphs of this chapter.
Advances to Primary Agricultural Credit Society (PACS) Farmers Service
Society (FSS) ceded to Commercial Banks
4.16 In case of advances granted under the on-lending system, however,
only the particular credit facility granted to PACSs or FSSs, which is in default
for a period of two crop seasons in case of short duration crops and one crop
season in case of long duration crops, as the case may be, after it has become
due will be classified as NPA and not all the credit facilities sanctioned subject
to such conditions as specified in the RBI's latest Master Circular on Prudential
Norms on Income Recognition, Asset Classification and provisioning pertaining
to Advances dated July 1, 2015. The other direct loans & advances, if any,
granted by the bank to the member borrower of a PACS/ FSS outside the on-
lending arrangement will become NPA even if one of the credit facilities
granted to the same borrower becomes NPA.
Erosion in Value of Securities/ Frauds Committed by Borrowers
4.17 In respect of accounts where there are potential threats for recovery
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Guidance Note on Audit of Banks (Revised 2019)
on account of erosion in the value of security or non-availability of security and
existence of other factors such as frauds committed by borrowers, such
accounts need not go through the stages of asset classification. In such cases,
the asset should be straightaway classified as doubtful or loss asset, as
appropriate. Further,
(i) Erosion in the value of securities by more than 50% of the value assessed
by the bank or accepted by RBI inspection team at the time of last
inspection, as the case may be, would be considered as "significant",
requiring the asset to be classified as doubtful straightaway and provided
for adequately.
(ii) The realisable value of security as assessed by bank/approved
valuers/RBI is less than 10% of the outstanding in the borrower accounts,
the existence of the security should be ignored and the asset should be
classified as loss asset. In such cases the asset should either be written
off or fully provided for.
(iii) Provisioning norms in respect of all cases of fraud:
a. The entire amount due to the bank (irrespective of the quantum of
security held against such assets), or for which the bank is liable
(including in case of deposit accounts), is to be provided for over a
period not exceeding four quarters commencing with the quarter in
which the fraud has been detected;
b. However, where there has been delay, beyond the prescribed
period, in reporting the fraud to the Reserve Bank, the entire
provisioning is required to be made at once. In addition, Reserve
Bank of India may also initiate appropriate supervisory action where
there has been a delay by the bank in reporting a fraud, or
provisioning there against;
c. Where the bank chooses to provide for the fraud over two to four
quarters and this results in the full provisioning being made in more
than one financial year, banks should debit 'other reserves' [i.e.,
reserves other than the one created in terms of Section 17(2) of the
Banking Regulation Act 1949] by the amount remaining un-provided
at the end of the financial year by credit to provisions. However,
banks should proportionately reverse the debits to `other reserves'
and complete the provisioning by debiting profit and loss account, in
the subsequent quarters of the next financial year.
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Asset Classification, Income Recognition and Provisioning
Government Guaranteed Advances
4.18 The credit facilities backed by guarantees of Central Government
though overdue may be treated as NPA only when the government repudiates
its guarantee, when invoked. This exemption from classification of Central
Government guaranteed advances as NPA is not for the purpose of recognition
of income. In case of State Government guaranteed loans, this exemption will
not be available and such account will be NPA if interest / principal / other dues
remain overdue for more than 90 days.
Advances under Consortium
4.19 Consortium advances should be based on the record of recovery of
the respective individual member banks and other aspects having a bearing on
the recoverability of the advances. Where the remittances by the borrower
under consortium lending arrangements are pooled with one bank and/or
where the bank receiving remittances is not parting with the share of other
member banks, the account should be treated as not serviced in the books of
the other member banks and therefore, an NPA.
4.20 The banks participating in the consortium, therefore, need to arrange
to get their share of recovery transferred from the lead bank or to 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.
Advances Against Term Deposits, NSCs, KVPs/ IVPs, etc.
4.21 Advances against Term Deposits, NSCs eligible for surrender,
KVP/IVP and life policies need not be treated as NPAs, provided adequate
margin is available in the accounts. Advance against gold ornaments,
government securities and all other securities are not covered by this
exemption and should be classified as NPA as per the extant IRAC norms.
However, in respect of Jewel Loans taken for Agricultural Purposes, the
classification has to be continued in accordance with Crop Seasons only.
Agricultural Advances Affected by Natural Calamities
4.22 Paragraph 4.2.13 of the Master Circular on Prudential Norms on
Income Recognition, Asset Classification and Provisioning deals elaborately
with the classification and income recognition issues due to impairment caused
by natural calamities. Banks may decide on their own relief measures, viz.,
conversion of the short term production loan into a term loan or
reschedulement of the repayment period and the sanctioning of fresh short-
term loan, subject to the guidelines contained in RBI's latest Master Circular on
"Prudential Norms on Income Recognition, Asset Classification and
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Guidance Note on Audit of Banks (Revised 2019)
Provisioning Pertaining to Advances" dated July 1, 2015 and guidelines
contained in RBI FIDD.No.FSD.BC.01/05.10.001/2015-16 dated July 1, 2015 on
"Guidelines for Relief Measures by Bank in Areas Affected by Natural
Calamities". In such cases the NPA classification would be governed by such
rescheduled terms. The Auditors are advised to obtain the latest decisions of
State Level Banking Committee (SLBC) and the minutes of the SLBC meeting
will be accessible in website.
4.23 In such cases of conversion or re-schedulement, the term loan as well
as fresh short-term loan may be treated as current dues and need not be
classified as NPA. The asset classification of these loans would thereafter be
governed by the revised terms & conditions and would be treated as NPA if
interest and/or instalment of principal remain overdue for two crop seasons for
short duration crops and for one crop season for long duration crops. For the
purpose of these guidelines, "long duration" crops would be crops with crop
season longer than one year and crops, which are not 'long duration" would be
treated as "short duration" crops.
4.24 While fixing the repayment schedule in case of rural housing
advances granted to agriculturist under Indira Awas Yojana and Golden Jubilee
Rural Housing Finance Scheme, banks should ensure that the interest/
instalment payable on such advances are linked to crop cycles.
Advances Granted Under Rehabilitation Packages Approved by BIFR/Term
Lending Institutions
4.25 In respect of advances under rehabilitation package approved by
BIFR/term lending institutions, the provision should continue to be made in
respect of dues to the bank on the existing credit facilities as per their
classification as sub-standard or doubtful asset. This classification cannot be
upgraded by the bank unless the package of renegotiated terms has worked
satisfactorily for a period of one year. As regards the additional facilities
sanctioned as per package finalised by BIFR and/or term lending institutions,
the income recognition, asset classification norms would apply after a period of
one year from the date of disbursement.
Transactions Involving Transfer of Assets through Direct Assignment of
Cash Flows and the Underlying Securities
4.26 Originating Bank: The asset classification and provisioning rules in
respect of the exposure representing the Minimum Retention Requirement
(MRR) of the Originator of the asset would be as under:
a) The originating bank may maintain a consolidated account of the amount
representing MRR if the loans transferred are retail loans. In such a case,
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Asset Classification, Income Recognition and Provisioning
the consolidated amount receivable in amortisation of the MRR and its
periodicity should be clearly established and the overdue status of the MRR
should be determined with reference to repayment of such amount.
Alternatively, the originating bank may continue to maintain borrower-wise
accounts for the proportionate amounts retained in respect of those
accounts. In such a case, the overdue status of the individual loan accounts
should be determined with reference to repayment received in each
account.
b) In the case of transfer of a pool of loans other than retail loans, the
originator should maintain borrower-wise accounts for the proportionate
amounts retained in respect of each loan. In such a case, the overdue
status of the individual loan accounts should be determined with reference
to repayment received in each account.
c) If the originating bank acts as a servicing agent of the assignee bank for the
loans transferred, it would know the overdue status of loans transferred
which should form the basis of classification of the entire MRR/individual
loans representing MRR as NPA in the books of the originating bank,
depending upon the method of accounting followed as explained in para (a)
and (b) above.
4.27 Purchasing Bank: In purchase of pools of both retail and non-retail
loans, income recognition, asset classification and provisioning norms for the
purchasing bank will be applicable based on individual obligors and not based on
portfolio. Banks should not apply the asset classification, income recognition and
provisioning norms at portfolio level, as such treatment is likely to weaken the
credit supervision due to its inability to detect and address weaknesses in
individual accounts in a timely manner. If the purchasing bank is not maintaining
the individual obligor-wise accounts for the portfolio of loans purchased, it should
have an alternative mechanism to ensure application of prudential norms on
individual obligor basis, especially the classification of the amounts
corresponding to the obligors which need to be treated as NPAs as per existing
prudential norms. One such mechanism could be to seek monthly statements
containing account-wise details from the servicing agent to facilitate classification
of the portfolio into different asset classification categories. Such details should
be certified by the authorized officials of the servicing agent. Bank's concurrent
auditors, internal auditors and statutory auditors should also conduct checks of
these portfolios with reference to the basic records maintained by the servicing
agent. The servicing agreement should provide for such verifications by the
auditors of the purchasing bank. All relevant information and audit reports should
be available for verification by the Inspecting Officials of RBI during the Annual
Financial Inspections of the purchasing banks.
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Guidance Note on Audit of Banks (Revised 2019)
4.28 The above guidelines prescribed for Originating Bank and Purchasing
Bank do not apply to:
(a) Transfer of loan accounts of borrowers by a bank to other bank/FIs/NBFCs
and vice versa, at the request/instance of borrower;
(b) Inter-bank participations;
(c) Trading in bonds;
(d) Sale of entire portfolio of assets consequent upon a decision to exit the line
of business completely. Such a decision should have the approval of Board
of Directors of the bank;
(e) Consortium and syndication arrangements and arrangement under
Corporate Debt Restructuring mechanism;
(f) Any other arrangement/transactions, specifically exempted by the Reserve
Bank of India.
Post Shipment Supplier's Credit
4.29 In respect of post-shipment credit extended by the banks covering
export of goods to countries for which the ECGC's cover is available, EXIM Bank
has introduced a guarantee-cum-refinance programme whereby, in the event of
default, EXIM Bank will pay the guaranteed amount to the bank within a period of
30 days from the day the bank invokes the guarantee after the exporter has filed
claim with ECGC.
4.30 Accordingly, where the credit extended by banks are guaranteed by
EXIM Bank, the extent to which payment has been received from EXIM bank on
guarantee the advance may not be treated as NPA.
Takeout Finance
4.31 Takeout finance is the product emerging in the context of the funding
of long-term infrastructure projects. Under such an arrangement, the bank or
financial institution financing infrastructure projects will have an arrangement
with any financial institution for transferring to the latter the outstanding in
respect of such financing in their books on a predetermined basis. In view of
the time-lag involved in taking-over, the possibility of a default in the meantime
cannot be ruled out. The norms of asset classification will have to be followed
by the concerned bank/financial institution in whose books the account stands
as balance sheet item as on the relevant date. If the lending institution
observes that the asset has turned NPA on the basis of the record of recovery,
it should be classified accordingly. The lending institution should not recognise
income on accrual basis and account for the same only when it is paid by the
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borrower/ taking over institution (if the arrangement so provides). The lending
institution should also make provisions against any asset turning into NPA
pending its takeover by taking over institution. As and when the asset is taken
over by the taking over institution, the corresponding provisions could be
reversed. However, the taking over institution, on taking over such assets,
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.
Export Project Finance
4.32 Where the actual importer has paid the dues to the bank abroad and
the proceeds have not been made good to the bank granting finance due to
any political reasons, such account need not be classified as NPA if the bank is
able to establish through documentary evidence that the importer has cleared
the dues in full. The account will, however, have to be considered as NPA if at
the end of one year from the date the amount was deposited by the importer in
the bank abroad, the amount has not still been remitted to the bank.
Net Worth of Borrower/Guarantor or Availability of Security
4.33 Since income recognition is based on recoveries, net worth of
borrower/guarantor should not be taken into account for the purpose of treating
an advance as NPA or otherwise, except to the extent provided in Para 4.2.9 of
the Master Circular dated July 1, 2015. Likewise, the availability of security
and/or guarantee is not relevant for determining whether an account is an NPA or
not.
Project Finance Under Moratorium Period
4.34 In the case of bank finance given for industrial projects or for
agricultural plantations etc., where moratorium is available for payment of
interest, payment of interest becomes due after the moratorium or gestation
period is over, and not on the date of debit of interest. Therefore, such amounts
of interest do not become overdue and hence the accounts do not become
NPA, with reference to the date of debit of interest. They become overdue after
due date for payment of interest as per the terms of sanction and consequently
NPA norms would apply to those advances from that due date.
Advances to Staff
4.35 Interest bearing staff advances as a banker should be included as part
of advances portfolio of the bank. 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 first due date
onwards. Such loans/advances should be classified as NPA only when there is
a default in repayment of instalment of principal or payment of interest on the
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respective due dates. The staff advances by a bank as an employer and not as
a banker are required to be included under the sub-head `Others' under the
schedule of Other Assets.
Partial Credit Enhancement to Corporate Bonds
4.36 In a waterfall mechanism, Credit Enhancement (CE) gets drawn only
in a contingent situation of cash flow shortfall for servicing a debt / bond etc.,
and not in the normal course of business. Hence, such an event is indicative of
financial distress of the project. Keeping this aspect in view, a drawn tranche of
the contingent PCE facility will be required to be repaid within 30 days from the
date of its drawal (due date). The facility will be treated as NPA if it remains
outstanding for 90 days or more from the due date and provided for as per the
usual asset classification and provisioning norms. In that event, the bank's
other facilities to the borrower will also be classified as NPA as per extant
guidelines.
NPA Management
4.37 The RBI has issued Master Circular dated July 1, 2015 on Prudential
Norms on Income Recognition, Asset Classification and provisioning pertaining
to Advances. The Circular stresses the importance of effective mechanism and
granular data on NPA management in the banks and provides as follows:
Asset quality of banks is one of the most important indicators of their
financial health. However, it has been observed that existing MIS on the
early warning systems of asset quality, needed improvement. Banks are,
therefore, advised that they should review their existing IT and MIS
framework and put in place a robust MIS mechanism for early detection of
signs of distress at individual account level as well as at segment level
(asset class, industry, geographic, size, etc.). Such early warning signals
should be used for putting in place an effective preventive asset quality
management framework, including a transparent restructuring mechanism
for viable accounts under distress within the prevailing regulatory framework,
for preserving the economic value of those entities in all segments.
The banks' IT and MIS system should be robust and able to generate
reliable and quality information with regard to their asset quality for effective
decision making. There should be no inconsistencies between information
furnished under regulatory/statutory reporting and the banks' own MIS
reporting. Banks are also advised to have system generated segment-wise
information on non-performing assets and restructured assets which may
include data on the opening balances, additions, reductions, (upgradations,
actual recoveries, write-offs etc.) closing balances, provisions held, technical
write-offs, etc.
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Income Recognition
On Advances Granted
4.38 Banks recognise income (such as interest, fees and commission) on
accrual basis, i.e., as it is earned. It is an essential condition for accrual of
income that it should not be unreasonable to expect its ultimate collection. In
view of the significant uncertainty regarding ultimate collection of income
arising in respect of non-performing assets, the guidelines require that banks
should not recognise income on non-performing assets until it is actually
realised.
4.39 If any advance including Bills purchased and discounted, becomes
NPA, the entire interest accrued and credited to the income account in the past
periods should be reversed if the same is not realised. Interest for the current
year if recognised till the date of identification but not realised should also be
reversed. Further,
i. Interest income on advances against term deposits, NSCs, IVPs, KVPs
and life policies may be taken to income account on the due date,
provided adequate margin is available in the accounts.
ii. Fees and commissions earned by the banks as a result of re-
negotiations or rescheduling of outstanding debts should be recognised
on an accrual basis over the period of time covered by the re-negotiated
or rescheduled extension of credit.
iii. If Government guaranteed advances become NPA (subject to what is
stated hereunder in respect of Central Govt. guaranteed accounts), the
interest on such advances should not be taken to income account
unless the interest has been realised.
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. Thus, where the guarantee is not
invoked/repudiated, the related account cannot be classified as NPA
and by implication, the advance is to be treated as "Standard" for the
purpose of provisioning. This exemption from classification of such
Central Government guaranteed advances as NPA is not for the
purpose of recognition of income; and income is to be recognized only
based on realisations made.
Reversal of Income
4.40 If any advance, including bills purchased and discounted, becomes
NPA, the entire interest accrued and credited to income account in the past
periods, should be reversed or provided for if the same is not realised. This will
apply to Government guaranteed accounts also.
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4.41 In respect of NPAs, fees, commission and similar income that have
accrued should cease to accrue in the current period and should be reversed
or provided for with respect to past periods, if uncollected.
4.42 Further, in case of banks which have wrongly recognised income in
the past should reverse the interest if it was recognised as income during the
current year or make a provision for an equivalent amount if it was recognised
as income in the previous year(s).
On Leased Assets
4.43 The finance charge component of finance income (as defined in AS 19
Leases) on the leased asset which has accrued and was credited to income
account before the asset became non-performing, and remaining unrealised,
should be reversed or provided for in the current accounting period.
On Take-out Finance
4.44 In the case of take-out finance, if based on record of recovery, the
account is classified by the lending bank as NPA, it should not recognise
income unless realised from the borrower/taking-over institution (if the
arrangement so provides).
On Partial Recoveries in NPAs (Appropriation of recoveries in NPAs)
4.45 In the absence of a clear agreement between the bank and the
borrower for the purpose of appropriation of recoveries in NPAs (i.e., towards
principal or interest due), banks are required to adopt an accounting policy and
exercise the right of appropriation of recoveries in a uniform and consistent
manner. The appropriate policy to be followed is to recognise income as per
AS 9 when certainty attaches to realisation and accordingly amount
reversed/derecognised or not recognised in the past should be accounted.
4.46 Interest partly/fully realised in NPAs can be taken to income. However,
it should be ensured that the credits towards interest in the relevant accounts
are not out of fresh/additional credit facilities sanctioned to the borrowers
concerned.
Memorandum Account
4.47 On an account turning NPA, banks should reverse the interest already
charged and not collected by debiting Profit and Loss account, and stop further
application of interest. However, banks may continue to record such accrued
interest in a Memorandum account in their books for control purposes. For the
purpose of computing Gross Advances, interest recorded in the Memorandum
account should not be taken into account.
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Classification of Advances
4.48 The guidelines require banks to classify their advances into four broad
categories for the purpose of provisioning as follows:
(a) Standard assets
4.49 A standard asset is one which does not disclose any problems and
which does not carry more than normal risk attached to the business. Such an
asset is not a non-performing asset.
4.50 As per RBI Circular RBI/2017-18/131 DBR.No.BP.BC.101/
2104.048/2017-18 dated February 12, 2018 regarding Resolution of Stressed
Assets, banks should identify incipient stress in loan accounts, immediately on
default by classifying stressed assets as special Mention accounts (SMA) as
per the above catagories.
SMA Basis of Classification
Sub-categories Principal or Interest payment or any other amount wholly or
partly overdue between
SMA-0 1-30 days
SMA-1 31-60 days
SMA-2 61-90 days
Such classification also serves to be useful for bank officers monitoring as well
as audit perspective to check the transactions & methods of keeping these
standard at the balance sheet date.
(b) Sub-standard assets
4.51 A sub-standard asset is one which has remained NPA for a period
less than or equal to 12 months. Such an asset will have well defined credit
weaknesses that jeopardize the liquidation of the debt and are characterized by
the distinct possibility that the banks will sustain some loss, if deficiencies are
not corrected.
(c) Doubtful assets
4.52 An asset is classified as doubtful if it has remained in the sub-standard
category for a period of 12 months. Such an asset has all the inherent
weaknesses as in a substandard asset and an added characteristic that the
weaknesses make the collection or liquidation in full highly improbable or
questionable.
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(d) Loss assets
4.53 A loss asset is one where loss has been identified by:
(a) the bank; or
(b) the internal or external auditors; or
(c) the RBI inspection.
but the amount has not been written off wholly. In other words, such an asset is
considered uncollectible and of such little value that its continuance as a
bankable asset is not warranted although there may be some salvage or
recovery value.
It may be noted that the above classification is meant for the purpose of
computing the amount of provision to be made in respect of advances. The
balance sheet presentation of advances is governed by the Third Schedule to
the Banking Regulation Act, 1949, which requires classification/presentation of
advances altogether differently.
Guidelines on Restructuring of Advances by Banks
4.54 The RBI, vide its Master Circular No.DBR.No.BP.BC.2/21.04.048/2015-
16 dated July 1, 2015 issued prudential guidelines on restructuring of advances
by banks. The Guidelines also contain the organisational framework for
restructuring of advances under consortium/ multiple banking/ syndication
arrangements, i.e., the CDR mechanism.
4.55 In line with the recommendation of the Working Group under the
Chairmanship of Shri B. Mahapatra, to review the existing prudential guidelines
on restructuring of advances by banks/financial institutions, the extant incentive
for quick implementation of restructuring package and asset classification
benefits (paragraphs 4.226 to 4.228 (available on restructuring on fulfilling the
conditions will however be withdrawn for all restructurings effective from April 1,
2015 with the exception of provisions related to changes in DCCO in respect of
infrastructure as well as non-infrastructure project loans. It implies that with effect
from April 1, 2015, a standard account on restructuring (for reasons other than
change in Date of Commencement of Commercial Operations (DCCO)) would be
immediately classified as sub-standard on restructuring as also the non-
performing assets, upon restructuring, would continue to have the same asset
classification as prior to restructuring and slip into further lower asset
classification categories as per the extant asset classification norms with
reference to the pre-restructuring repayment schedule.
4.56 The guidelines issued by the Reserve Bank of India on restructuring of
advances (other than those restructured under a separate set of guidelines
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Asset Classification, Income Recognition and Provisioning
issued by the Rural Planning and Credit Department (RPCD) of the RBI on
restructuring of advances on account of natural calamities) are divided into the
following four categories:
Guidelines on restructuring of advances extended to industrial units.
Industrial units under the Corporate Debt Restructuring (CDR) Mechanism.
Small and Medium Enterprises (SME).
All other advances.
In these four sets of guidelines on restructuring of advances, the differentiations
were broadly made based on whether a borrower is engaged in an industrial
activity or a non-industrial activity. In addition, an elaborate institutional
mechanism was laid down for accounts restructured under CDR Mechanism.
4.57 In the backdrop of extraordinary rise in restructured standard advances,
these prudential norms were further revised by taking into account the
recommendations of the Working Group under the Chairmanship of Shri B.
Mahapatra, to review the existing prudential guidelines on restructuring of
advances by banks/financial institutions. The details of the institutional /
organizational framework for CDR Mechanism and SME Debt Restructuring
Mechanism are given in Annex - 4 to the RBI's Master Circular on "Prudential
Norms on Income Recognition, Asset Classification and Provisioning to
Advances" dated July 1, 2015 to be read along with circular no. DBOD.BP.
BC.No.45/21.04.132/2014-15.
4.58 The CDR Mechanism (Annex - 4 of the Master circular) will also be
available to the corporates engaged in non-industrial activities, if they are
otherwise eligible for restructuring as per the criteria laid down for this purpose.
Further, banks are also encouraged to strengthen the co-ordination among
themselves in the matter of restructuring of consortium / multiple banking
accounts, which are not covered under the CDR Mechanism.
Key Concepts
4.59 Key concepts used in these guidelines are defined in Annex 5 to the
RBI's Master Circular on "Prudential Norms on Income Recognition, Asset
Classification and Provisioning to Advances" dated July 1, 2015.
General Principles and Prudential Norms for Restructured Advances
4.60 The principles and prudential norms laid down in below given
paragraphs are applicable to all advances including the borrowers, who are
eligible for special regulatory treatment for asset classification.
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Eligibility criteria for restructuring of advances
4.61 Banks may restructure the accounts classified under 'standard', 'sub-
standard' and 'doubtful' categories. Banks cannot reschedule / restructure /
renegotiate borrowal accounts with retrospective effect. While a restructuring
proposal is under consideration, the usual asset classification norms would
continue to apply. The process of re- classification of an asset should not stop
merely because restructuring proposal is under consideration. The asset
classification status as on the date of approval of the restructured package by the
competent authority would be relevant to decide the asset classification status of
the account after restructuring/ rescheduling/ renegotiation. In case there is
undue delay in sanctioning a restructuring package and in the meantime the
asset classification status of the account undergoes deterioration, it would be a
matter of supervisory concern.
4.62 Normally, restructuring cannot take place unless alteration / changes in
the original loan agreement are made with the formal consent / application of the
debtor. However, the process of restructuring can be initiated by the bank in
deserving cases subject to customer agreeing to the terms and conditions.
4.63 No account will be taken up for restructuring by the banks unless the
financial viability is established and there is a reasonable certainty of repayment
from the borrower, as per the terms of restructuring package. Any restructuring
done without looking into cash flows of the borrower and assessing the viability of
the projects / activity financed by banks would be treated as an attempt at ever
greening a weak credit facility and would invite supervisory concerns / action.
Banks should accelerate the recovery measures in respect of such accounts.
The viability should be determined by the banks based on the acceptable viability
benchmarks determined by them, which may be applied on a case-by-case
basis, depending on merits of each case. Illustratively, the parameters may
include:
The Return on Capital Employed;
Debt Service Coverage Ratio;
Gap between the Internal Rate of Return;
Cost of Funds; and
The amount of provision required in lieu of the diminution in the fair value of
the restructured advance.
4.64 The viability should be determined by the banks based on the
acceptable viability parameters and benchmarks for each parameter determined
by them. The benchmarks for the viability parameters adopted by the CDR
Mechanism are given in the Appendix to Part B of this Master Circular on
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"Prudential Norms on Income Recognition, Asset Classification and
Provisioning" and individual banks may suitably adopt them with appropriate
adjustments, if any, for specific sectors while restructuring of accounts in non-
CDR cases.
4.65 The borrowers indulging in frauds and malfeasance will continue to
remain ineligible for restructuring. Banks may review the reasons for
classification of the borrowers as willful defaulters, especially in old cases where
the manner of classification of a borrower as a willful defaulter was not
transparent, and satisfy itself that the borrower is in a position to rectify the willful
default. The restructuring of such cases may be done with Board's approval,
while for such accounts the restructuring under the CDR Mechanism may be
carried out with the approval of the Core Group only.
4.66 BIFR cases are not eligible for restructuring without their express
approval. CDR Core Group in the case of advances restructured under CDR
Mechanism, the lead bank in the case of SME Debt Restructuring Mechanism
and the individual banks in other cases, may consider the proposals for
restructuring in such cases, after ensuring that all the formalities in seeking the
approval from BIFR are completed before implementing the package.
Miscellaneous
4.67 The banks should decide on the issue regarding convertibility (into
equity) option as a part of restructuring exercise whereby the banks / financial
institutions shall have the right to convert a portion of the restructured amount
into equity, keeping in view the statutory requirement under Section 19 of the
Banking Regulation Act, 1949, (in the case of banks) and relevant SEBI
Regulations.
4.68 Conversion of debt into preference shares should be done only as a last
resort and such conversion of debt into equity/preference shares should, in any
case, be restricted to a cap (say 10 per cent of the restructured debt). Further,
any conversion of debt into equity should be done only in the case of listed
companies.
4.69 Acquisition of equity shares / convertible bonds / convertible debentures
in companies by way of conversion of debt / overdue interest can be done
without seeking prior approval from RBI, even if by such acquisition the
prudential capital market exposure limit prescribed by the RBI is breached.
However, this will be subject to reporting of such holdings to RBI, Department of
Banking Supervision (DBS), every month along with the regular Department of
Supervision by Banks (DSB) Return on Asset Quality. Nonetheless, banks will
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have to comply with the provisions of Section 19(2) of the Banking Regulation
Act, 1949.
4.70 Acquisition of non-SLR securities by way of conversion of debt is
exempted from the mandatory rating requirement and the prudential limit on
investment in unlisted non-SLR securities, prescribed by the RBI, subject to
periodical reporting to the RBI in the aforesaid DSB return.
4.71 Banks may consider incorporating in the approved restructuring
packages creditor's rights to accelerate repayment and the borrower's right to
pre-pay. Further, all restructuring packages must incorporate `Right to
recompense' clause and it should be based on certain performance criteria of the
borrower. In any case, minimum 75 per cent of the recompense amount should
be recovered by the lenders and in cases where some facility under restructuring
has been extended below base rate, 100 per cent of the recompense amount
should be recovered.
4.72 As stipulating personal guarantee will ensure promoters' "skin in the
game" or commitment to the restructuring package, promoters' personal
guarantee should be obtained in all cases of restructuring and corporate
guarantee cannot be accepted as a substitute for personal guarantee. However,
corporate guarantee can be accepted in those cases where the promoters of a
company are not individuals but other corporate bodies or where the individual
promoters cannot be clearly identified.
Disclosures
4.73 With effect from the financial year 2012-13, banks are required to
disclose in their published annual Balance Sheets, under 'Notes on Accounts'
information relating to number of accounts and amount of advances
restructured, and the amount of diminution in the fair value of the restructured
advances as per the format given in Annex 6 to the RBI circular. The
information would be required for advances restructured under CDR
Mechanism, SME Debt Restructuring Mechanism and other categories
separately. Banks must disclose the total amount outstanding in all the accounts
/ facilities of borrowers whose accounts have been restructured along with the
restructured part or facility. This means even if only one of the facilities /
accounts of a borrower has been restructured, the bank should also disclose the
entire outstanding amount pertaining to all the facilities / accounts of that
particular borrower. The disclosure format prescribed in Annex-6, inter-alia,
includes the following:
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i. details of accounts restructured on a cumulative basis excluding the
standard restructured accounts which cease to attract higher provision and
risk weight (if applicable);
ii. provisions made on restructured accounts under various categories; and
iii. details of movement of restructured accounts.
4.74 This implies that once the higher provisions and risk weights (if
applicable) on restructured advances (classified as standard either ab initio or on
upgradation from NPA category) revert to the normal level on account of
satisfactory performance during the prescribed period, such advances should no
longer be required to be disclosed by banks as restructured accounts in the
"Notes on Accounts" in their Annual Balance Sheets. However, the provision for
diminution in the fair value of restructured accounts on such restructured
accounts should continue to be maintained by banks as per the existing
instructions.
4.75 It has been reiterated that the basic objective of restructuring is to
preserve economic value of units, not ever greening of problem accounts. This
can be achieved by banks and the borrowers only by careful assessment of the
viability, quick detection of weaknesses in accounts and a time-bound
implementation of restructuring packages. (Text of RBI Master circular on
"Prudential Norms on Income Recognition, Asset Classification and Provisioning
pertains to Advances" for Annex 1 to 6 is given in Pen Drive/CD.)
The Guidelines for various type of Restructuring discussed below are as under:
i. Joint Lenders Forum (JLF) and Corrective Action Plan (CAP).
ii. Strategic Debt Restructuring (SDR).
iii. Scheme for Sustainable structuring of Stressed Assets (S4A).
iv. Corporate Debt Restructuring (CDR) Mechanism.
v. Resolution of Stressed Assets Revised Framework w.e.f. February 12,
2018.
Guidelines on Joint Lenders Forum (JLF) and Corrective
Action Plan (CAP)
4.76 These guidelines are applicable for lending under Consortium and
Multiple Banking Arrangements (MBA) [except instructions in paragraphs 4.77,
4.111, 4.118 and 4.119 below and in case of dissemination of Information,
which are applicable in all cases of lending], and should be read with prudential
norms on `Restructuring of Advances by banks' as contained in Part B of this
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Master Circular no. RBI/2015-16/101 DBR.No.BP.BC.2/ 21.04.048/2015-16
dated July 1, 2015 issued prudential guidelines on restructuring of advances by
banks.
Formation of Joint Lenders' Forum
4.77 Bank is required to classify the loan accounts into 3 categories as
special mention accounts as given below:
1) SMA-0: Principal or interest payment not overdue for more than 30 days but
account showing signs of incipient stress as given in appendix to Part C of
Master Circular no. RBI/2015-16/101DBR.No.BP.BC.2/21.04.048/ 2015-16
dated July 1, 2015.
2) SMA-1: Principal or interest payment overdue between 31-60 days.
3) SMA-2: Principal or interest payment overdue between 61-90 days.
Banks are required to report credit information, including classification of an
account as SMA to CRILC (Central Repository of Information on Large Credits)
on all their borrowers having aggregate fund-based and non-fund based
exposure of Rs.50 million and above. Except the exemption granted for Crop
loans, interbank exposure and exposure to NABARD, SIDBI, EXIM Bank and
NHB from reporting as per Reserve Bank of India circular no.
DBOD.BP.BC.No.45/21.04.132/2014-15 dated October 21, 2014.
4.78 Reserve Bank of India vide circular no. DBOD.BP.BC.No.45/21.04.132/
2014-15 dated October 21, 2014 clarified that bank must report Cash credit (CC)
and Overdraft (OD) accounts, including overdraft arising out of devolved
LCs/Invoked guarantees to CRILC as SMA 2 when these are `out of order' for
more than 60 days. Similarly, bills purchased or discounted (other than those
backed by LCs issued by banks) and derivative exposures with receivables
representing positive mark to market value remaining overdue for more than 60
days should be reported to CRILC as SMA-2.
4.79 Further, Banks should continue to report the credit information and SMA
status to CRILC on loans including loans extended by their overseas branches.
However, formation of JLF will not be mandatory in cases of offshore borrowers
which do not have any presence in India, either by way of a subsidiary, parent or
a group entity. Further, the inclusion of offshore lenders as part of JLF shall not
be mandatory. Formation of JLF will not be mandatory on reporting of investment
portfolio as SMA, except in cases of bonds/debentures acquired on private
placement basis or due to conversion of debt under restructuring of advances.
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1) Banks should mandatorily form a committee to be called Joint Lenders'
Forum (JLF) if the aggregate exposure (AE) [fund based and non-fund
based taken together] of lenders in that account is Rs 1000 million and
above and the account is reported by any of the lenders to CRILC as SMA-
2.
2) Lenders also have the option of forming a JLF even when the AE in an
account is less than Rs.1000 million and/or when the account is reported as
SMA-0 or SMA-1.
4.80 Existing Consortium Arrangement for consortium accounts will serve as
JLF with the Consortium Leader as convener, for accounts under Multiple
Banking Arrangements (MBA), the lender with the highest AE will convene JLF.
In case of a borrower's request for formation of JLF, the account should be
reported as SMA-0 on such request to CRILC and the lender should form the JLF
immediately if the AE is Rs 1000 million and above. The formation of JLF is
optional for other cases of SMA-0 reporting.
4.81 All the lenders should formulate and sign an Agreement (which may be
called JLF agreement) incorporating the broad rules for the functioning of the
JLF. The Indian Banks' Association (IBA) has prepared a Master JLF agreement
and operational guidelines for JLF which can be adopted by all lenders. JLF
formation and subsequent corrective actions will be mandatory in accounts
having AE of Rs.1000 million and above, in other cases also the lenders will have
to monitor the asset quality closely and take corrective action for effective
resolution as deemed appropriate.
Corrective Action Plan (CAP) by JLF
4.82 The options under Corrective Action Plan (CAP) by the JLF would
generally include
a) Rectification: Obtaining a specific commitment from the borrower to
regularise the account so that the account comes out of SMA status or does
not slip into the NPA category. Commitment should be supported by
identifiable cash flows without loss or sacrifice to existing lenders, additional
funding through equity/strategic investors. These measures are intended to
turnaround the entity/company without any changes to the terms and
conditions of the loan.
b) Restructuring: Consider the possibility of Restructuring the account if it is
prima facie viable and the borrower is not a willful defaulter (i.e. there is no
diversion of funds, fraud or malfeasances etc. At this stage, commitment
from promoters for extending their personal guarantees along with their net
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worth statement supported by copies of legal titles to assets may be
obtained along with a declaration that they would not undertake any
transaction that would alienate assets without the permission of the JLF.
c) Recovery: Once the first two options at (a) and (b) above are seen as not
feasible, due recovery process may be resorted to. The JLF may decide the
best recovery process to be followed, among the various legal and other
recovery options available, with a view to optimising the efforts and results.
4.83 The decisions agreed upon by a minimum of 60% of creditors by value
and 50% of creditors by number in the JLF would be considered as the basis for
proceeding with the restructuring of the account, and will be binding on all
lenders under the terms of the ICA (Inter creditor agreement). However, if the
JLF decides to proceed with recovery, the minimum criteria for binding decision,
if any, under any relevant laws/Acts would be applicable.
4.84 The JLF is required to arrive at an agreement on the option to be
adopted for CAP within 45 days from (i) the date of an account being reported as
SMA-2 by one or more lender, or (ii) receipt of request from the borrower to form
a JLF, with substantiated grounds, if it senses imminent stress. The JLF should
sign off the detailed final CAP within the next 30 days from the date of arriving at
such an agreement.
4.85 If the JLF decides on option of rectification or restructuring given above,
but the account fails to perform as per the agreed terms under the option, the
JLF should initiate recovery.
4.86 Joint Lenders' Forum Empowered Group (JLF EG)
A. Sometimes Boards of the banks find it difficult to approve the decisions
taken by JLF as the JLFs do not have senior level representations from the
participating lenders. In this regard, it is clarified that, although RBI has not
explicitly prescribed the level of representation in its guidelines, banks are
expected to depute sufficiently empowered senior level officials for
deliberations and decisions in the meetings of JLF.
B. Nevertheless, it has been decided that JLF will finalise the CAP and the
same will be placed before an Empowered Group (EG) of lenders, which
will be tasked to approve the rectification/restructuring packages under
CAPs. The JLF-EG shall have the following composition:
i. A representative each of SBI and ICICI Bank as standing members;
ii. A representative each of the top three lenders to the borrower. If SBI
or ICICI Bank is among the top three lenders to the borrower, then a
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representative of the fourth largest or a representative each of the
fourth and the fifth largest lenders as the case may be;
iii. A representative each of the two largest banks in terms of advances
who do not have any exposure to the borrower; and
iv. The participation in the JLF-EG shall not be less than the rank of an
Executive Director in a PSB or equivalent.
The JLF convening bank will convene the JLF-EG and provide the secretarial
support to it.
Restructuring under JLF
4.87 If the JLF decide to restructure as CAP, it can be referred to CDR cell or
restructure the same independent of CDR mechanism. For restructuring process
refer Master Circular no. RBI/2015-16/101DBR.No.BP.BC.2/21.04.048/2015-16
dated July 1, 2015 along with clarification issued by Reserve bank of India
circular no. DBOD.BP.BC.No.45/21.04.132/2014-15 dated October 21, 2014.
Restructuring of Doubtful accounts under JLF
4.88 In terms of paragraph 4.3.6 of the circular DBOD.BP.BC.No.97/
21.04.132/2013-14 dated February 26, 2014, while generally no account
classified as doubtful should be considered by the JLF for restructuring, in cases
where a small portion of debt is doubtful i.e. the account is standard/sub-
standard in the books of at least 90% of creditors (by value), the account may
then be considered under JLF for restructuring.
4.89 In partial modification of the above, it has been decided that a JLF may
decide on restructuring of an account classified as `doubtful' in the books of one
or more lenders similar to that of SMA2 and sub-standard assets, if the account
has been assessed as viable under the Technology Economic Viability (TEV)
and the JLF-EG concurs with the assessment and approves the proposal.
Asset Classification Norms
4.90 While a restructuring proposal is under consideration by the JLF/CDR,
the usual asset classification norm would continue to apply. The process of re-
classification of an asset should not stop merely because restructuring proposal
is under consideration by the JLF/CDR.
4.91 The auditor should also verify whether that in case a standard asset has
been restructured, it has been downgraded to "substandard" asset immediately.
As mentioned in paragraph 20.2.3 in Part B of this Master Circular on
Prudential Norms on Income Recognition, Asset Classification and
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Provisioning, the special asset classification benefit as given below has been
withdrawn for all restructurings with effect from April 1, 2015 with the exception of
provisions related to changes in Date of Commencement of Commercial
Operations (DCCO) in respect of infrastructure and non-infrastructure project
loans.
4.92 Incentive for quick implementation of a restructuring package, the
special asset classification benefit on restructuring of accounts as per extant
instructions would be available for accounts undertaken for restructuring under
these guidelines, subject to adherence to the overall timeframe for approval of
restructuring package detailed in paragraphs 28.3 and 28.4 of Master Circular
no. RBI/2015-16/101 DBR.No.BP.BC.2/21.04.048/2015-16 dated July 1, 2015 to
be read along with Reserve bank of India circular no. DBOD.BP.BC.No.45/
21.04.132/ 2014-15 dated October 21, 2014 and implementation of the approved
package within 90 days from the date of approval. The asset classification status
as on the date of formation of JLF would be the relevant date to decide the asset
classification status of the account after implementation of the final restructuring
package.
Strategic Debt Restructuring:
4.93 RBI circular DBOD.BP.BC.No.97/21.04.132/2013-14 dated February 26,
2014 on "Framework for Revitalising Distressed Assets in the Economy
Guidelines on Joint Lenders' Forum (JLF) and Corrective Action Plan (CAP)",
wherein change of management was envisaged as a part of restructuring of
stressed assets. Paragraph 5.3 of the circular states that the general principle of
restructuring should be that the shareholders bear the first loss rather than the
debt holders. With this principle in view and also to ensure more `skin in the
game' of promoters, JLF/Corporate Debt Restructuring Cell (CDR) may consider
the following options when a loan is restructured:
Possibility of transferring equity of the company by promoters to the lenders
to compensate for their sacrifices;
Promoters infusing more equity into their companies;
Transfer of the promoters' holdings to a security trustee or an escrow
arrangement till turnaround of company. This will enable a change in
management control, should lenders favour it.
4.94 It has been observed that in many cases of restructuring of accounts,
borrower companies are not able to come out of stress due to operational/
managerial inefficiencies despite substantial sacrifices made by the lending
banks. In such cases, change of ownership will be a preferred option. Further,
under JLF and CDR mechanism, the restructuring package should also stipulate
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the timeline during which certain viability milestones (e.g. improvement in certain
financial ratios after a period of time, say, 6 months or 1 year and so on) would
be achieved. The JLF must periodically review the account for achievement/non-
achievement of milestones and should consider initiating suitable measures
including recovery measures as deemed appropriate. With a view to ensuring
more stake of promoters in reviving stressed accounts and provide banks with
enhanced capabilities to initiate change of ownership in accounts which fail to
achieve the projected viability milestones, banks may, at their discretion,
undertake a `Strategic Debt Restructuring (SDR)' by converting loan dues to
equity shares, which will have the following features:
(i) At the time of initial restructuring, the JLF must incorporate, in the terms
and conditions attached to the restructured loan/s agreed with the borrower,
an option to convert the entire loan (including unpaid interest), or part
thereof, into shares in the company in the event the borrower is not able to
achieve the viability milestones and/or adhere to `critical conditions' as
stipulated in the restructuring package. This should be supported by
necessary approvals/authorisations (including special resolution by the
shareholders) from the borrower company, as required under extant
laws/regulations, to enable the lenders to exercise the said option
effectively. Restructuring of loans without the said approvals/authorisations
for SDR is not permitted. If the borrower is not able to achieve the viability
milestones and/or adhere to the `critical conditions' referred to above, the
JLF must immediately review the account and examine whether the
account will be viable by effecting a change in ownership. If found viable
under such examination, the JLF may decide on whether to invoke the
SDR, i.e. convert the whole or part of the loan and interest outstanding into
equity shares in the borrower company, so as to acquire majority
shareholding in the company;
(ii) Provisions of the SDR would also be applicable to the accounts which have
been restructured before the date of this circular provided that the
necessary enabling clauses, as indicated in the above paragraph, are
included in the agreement between the banks and borrower;
(iii) The decision on invoking the SDR by converting the whole or part of the
loan into equity shares should be taken by the JLF as early as possible but
within 30 days from the above review of the account. Such decision should
be well documented and approved by the majority of the JLF members
(minimum of 60% of creditors by value and 50% of creditors by number);
(iv) In order to achieve the change in ownership, the lenders under the JLF
should collectively become the majority shareholder by conversion of their
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dues from the borrower into equity. However, the conversion by JLF lenders
of their outstanding debt (principal as well as unpaid interest) into equity
instruments shall be subject to the member banks' respective total holdings
in shares of the company conforming to the statutory limit in terms of
Section 19(2) of Banking Regulation Act, 1949;
(v) Post the conversion, all lenders under the JLF must collectively hold 51% or
more of the equity shares issued by the company;
(vi) The share price for such conversion of debt into equity will be determined
as per the method given para 4.95;
(vii) Henceforth, banks should include necessary covenants in all loan
agreements, including restructuring, supported by necessary
approvals/authorisations (including special resolution by the shareholders)
from the borrower company, as required under extant laws/regulations, to
enable invocation of SDR in applicable cases;
(viii) The JLF must approve the SDR conversion package within 90 days from
the date of deciding to undertake SDR;
(ix) The conversion of debt into equity as approved under the SDR should be
completed within a period of 90 days from the date of approval of the SDR
package by the JLF. For accounts which have been referred by the JLF to
CDR Cell for restructuring in terms of paragraph 4.2 of circular
DBOD.BP.BC.No.97/21.04.132/2013-14 dated February 26, 2014 cited
above, JLF may decide to undertake the SDR either directly or under the
CDR Cell;
(x) The invocation of SDR will not be treated as restructuring for the purpose of
asset classification and provisioning norms;
(xi) On completion of conversion of debt to equity as approved under SDR, the
existing asset classification of the account, as on the reference date
indicated at para 4.95(ii) below, will continue for a period of 18 months from
the reference date. Thereafter, the asset classification will be as per the
extant IRAC norms, assuming the aforesaid `stand-still' in asset
classification had not been given. However, when banks' holdings are
divested to a new promoter, the asset classification will be as per the para
4.94(xiii) below;
(xii) Banks should ensure compliance with the provisions of Section 6 of
Banking Regulation Act and JLF should closely monitor the performance of
the company and consider appointing suitable professional management to
run the affairs of the company;
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(xiii) JLF and lenders should divest their holdings in the equity of the company
as soon as possible. On divestment of banks' holding in favour of a `new
promoter', the asset classification of the account may be upgraded to
`Standard'. However, the quantum of provision held by the bank against the
said account as on the date of divestment, which shall not be less than
what was held as at the `reference date', shall not be reversed. At the time
of divestment of their holdings to a `new promoter', banks may refinance the
existing debt of the company considering the changed risk profile of the
company without treating the exercise as `restructuring' subject to banks
making provision for any diminution in fair value of the existing debt on
account of the refinance. Banks may reverse the provision held against the
said account only when all the outstanding loan/facilities in the account
perform satisfactorily during the `specified period' (as defined in the extant
norms on restructuring of advances), i.e. principal and interest on all
facilities in the account are serviced as per terms of payment during that
period. In case, however, satisfactory performance during the specified
period is not evidenced, the asset classification of the restructured account
would be governed by the extant IRAC norms as per the repayment
schedule that existed as on the reference date indicated at para 4.95(ii)
below, assuming that `stand-still' / above upgrade in asset classification had
not been given. However, in cases where the bank exits the account
completely, i.e. no longer has any exposure to the borrower, the provision
may be reversed/absorbed as on the date of exit;
(xiv) The asset classification benefit provided at the above paragraph is subject
to the following conditions:
a) The `new promoter' should not be a person/entity/subsidiary/associate
etc. (domestic as well as overseas), from the existing promoter/
promoter group. Banks should clearly establish that the acquirer does
not belong to the existing promoter group; and
b) The new promoters should have acquired at least 51 per cent of the
paid up equity capital of the borrower company. If the new promoter is a
non-resident, and in sectors where the ceiling on foreign investment is
less than 51 per cent, the new promoter should own at least 26 per cent
of the paid up equity capital or up to applicable foreign investment limit,
whichever is higher, provided banks are satisfied that with this equity
stake the new non-resident promoter controls the management of the
company.
c) Vide circular dated 10th November, 2016, it has been decided to modify
paragraph (xiv)(b) of circular DBR.BP.BC.No.101/21.04.132/2014-15
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dated June 8, 2015 and paragraph 7 of circular DBR.BP.BC.No.82 /
21.04.132/2015-16 dated February 25, 2016 as under:
"The new promoter should have acquired at least 26 percent of the paid
up equity capital of the borrower company and shall be the single
largest shareholder of the borrower company. Further, the new
promoter shall be in `control' of the borrower company as per the
definition of `control' provided in the Companies Act 2013 / regulations
issued by the Securities and Exchange Board of India / any other
applicable regulations / accounting standards as the case may be."
In terms of extant instructions, JLFs are required to adhere to certain
prescribed timelines during SDR process. In partial modification of the
extant instructions, it is advised that the JLF can have flexibility in the
time taken for completion of individual activities up to conversion of debt
into equity in favour of lenders (i.e. up to 210 days from the review of
achievement of milestones/critical conditions) as per the SDR 4
package approved by JLF. It is also clarified that the benefit of `stand-
still' in asset classification will apply from the reference date itself.
However, if the targeted conversion of debt into equity shares does not
take place within 210 days from the review of achievement of
milestones/critical conditions, the benefit will cease to exist. Thereafter,
the loans will be classified as per the conduct of the account as per the
extant Income Recognition, Asset Classification and Provisioning
norms.
It is clarified that `stand-still' clause only applies to asset classification
and banks shall not recognize income on accrual basis if the interest is
not serviced within 90 days from the due date.
Banks shall make disclosures on invocation of SDR in annual financial
statements as per the format given.
4.95 The conversion price of the equity shall be determined as per the
guidelines given below:
(i) Conversion of outstanding debt (principal as well as unpaid interest) into
equity instruments should be at a `Fair Value' which will not exceed the
lowest of the following, subject to the floor of `Face Value' (restriction under
section 53 of the Companies Act, 2013):
a) Market value (for listed companies): Average of the closing prices of
the instrument on a recognized stock exchange during the ten trading
days preceding the `reference date' indicated at (ii) below;
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b) Break-up value: Book value per share to be calculated from the
company's latest audited balance sheet (without considering
'revaluation reserves', if any) adjusted for cash flows and financials
post the earlier restructuring; the balance sheet should not be more
than a year old. In case the latest balance sheet is not available this
break-up value shall be Re.1.
(ii) The above Fair Value will be decided at a `reference date' which is the date
of JLF's decision to undertake SDR.
4.96 The above pricing formula under Strategic Debt Restructuring Scheme
has been exempted from the Securities and Exchange Board of India (SEBI)
(Issue of Capital and Disclosure Requirements) Regulations, 2009 subject to
certain conditions, in terms of SEBI (Issue of Capital and Disclosure
Requirements) (Second Amendment) Regulations, 2015 notified vide the Gazette
of India Extraordinary PartIIISection 4, published on May 5, 2015. Further, in
the case of listed companies, the acquiring lender on account of conversion of
debt into equity under SDR will also be exempted from the obligation to make an
open offer under regulation 3 and regulation 4 of the provisions of the Securities
and Exchange Board of India (Substantial Acquisition of Shares and Takeovers)
Regulations, 2011 in terms of SEBI (Substantial Acquisition of Shares and
Takeovers) (Second Amendment) Regulations, 2015. This has been notified vide
the Gazette of India Extraordinary PartIIISection 4 published on May 05, 2015.
Banks should adhere to all the prescribed conditions by SEBI in this regard.
4.97 In addition to conversion of debt into equity under SDR, banks may also
convert their debt into equity at the time of restructuring of credit facilities under
the extant restructuring guidelines. However, exemption from regulations of
SEBI, as detailed in paragraph 4.96 above, shall be subject to adhering to the
guidelines stipulated in the above paragraphs.
4.98 Acquisition of shares due to such conversion will be exempted from
regulatory ceilings/restrictions on Capital Market Exposures, investment in Para-
Banking activities and intra-group exposure. However, this will require reporting
to RBI (reporting to DBS, CO every month along with the regular DSB Return on
Asset Quality) and disclosure by banks in the Notes to Accounts in Annual
Financial Statements. Equity shares of entities acquired by the banks under SDR
shall be assigned a 150% risk weight for a period of 18 months from the
`reference date' indicated in paragraph 4.95(ii). After 18 months from the
`reference date', these shares shall be assigned risk weights as per the extant
capital adequacy regulations.
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4.99 Equity shares acquired and held by banks under the scheme shall be
exempt from the requirement of periodic mark-to-market (stipulated vide
Prudential Norms for Classification, Valuation and Operation of Investment
Portfolio by Banks) for the 18 months' period indicated at para 4.94(xi).
4.100 Conversion of debt into equity in an enterprise by a bank may result in
the bank holding more than 20% of voting power, which will normally result in an
investor-associate relationship under applicable accounting standards. However,
as the lender acquires such voting power in the borrower entity in satisfaction of
its advances under the SDR, and the rights exercised by the lenders are more
protective in nature and not participative, such investment may not be treated as
investment in associate in terms of paragraph 10.2.3 of Annexure to circular
DBOD.No.BP.BC.89/21.04.018/2002-03 dated March 29, 2003 on `Guidelines on
Compliance with Accounting Standards (AS) by Banks'.
4.101 With reference to the provisions contained in circular DBR.BP.BC.No.
101/21.04.132/2014-15 dated June 8, 2015 on "Strategic Debt Restructuring", it
is advised that in cases of failure of rectification or restructuring as a CAP as
decided by JLF in terms of paragraph 3 of circular DBOD.BP.BC.No.97/
21.04.132/ 2013-14 dated February 26, 2014, JLF will have the option to initiate
SDR to effect change of management of the borrower company subject to
compliance with the conditions as stated above.
Audit Procedure for Accounts falling under CDR Programme
4.102 The details of the institutional/organizational framework for CDR
Mechanism and SME Debt Restructuring Mechanism are given in Annexure-4 to
the RBI's Master Circular on "Prudential Norms on Income Recognition, Assets
Classification and Provisioning to Advances" dated July 01,2015 to be read along
with circular no. DBOD.BP.BC.No.45/21.04.132/2014-15. Following audit
procedures are to be carried out to assess / gain an understanding about the
borrower account.
(a) Review the present classification of the account under IRAC norms
adopted by the bank and corresponding provision made in the books of
accounts, if any. If the account is already treated as NPA in the books of
the bank, the same cannot be upgraded only because of the CDR
package.
(b) Review the Debtor- Creditor Agreement (DCA) and Inter Creditor
Agreement (ICA) with respect to availability of such agreements and
necessary provisions in the agreement for reference to CDR cell in case of
necessity, penal clauses, stand-still clause, to abide by the various elements
of CDR system etc., (DCA may be entered into at the time of original
sanction of loan or at the time of reference to CDR).
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(c) Auditor has to ascertain the terms of rehabilitation along with the
sacrifices, if any, assumed in the rehabilitation program to verify whether
such sacrifices have been accounted in the books of accounts of the
lender. Ascertain whether any additional financing / conversion of loan into
equity have been envisaged in the rehabilitation / restructuring program.
4.103 There are two Categories of CDR system namely Category 1 CDR
system and Category 2 CDR system. Category 1 CDR system covers borrower
accounts classified as `Standard' and `Sub-Standard' assets whereas Category 2
CDR system covers advances classified as `Doubtful' asset. Corporates
classified as willful defaulter, indulging in fraud or misfeasance even in a single
bank will not be considered for CDR scheme. Auditor needs to ascertain whether
the borrower account falls under Category 1 CDR system or Category 2 CDR
system or classified as willful defaulter, fraud etc.
4.104 Auditor should also ascertain whether account has been referred to
BIFR, as such cases are not eligible for restructuring under CDR system. Large
value BIFR cases may be eligible for restructuring under CDR if specifically
recommended by CDR core group. Auditor has to verify the necessary
approvals/ recommendations by CDR core group if auditor comes across any
BIFR cases.
4.105 Auditor has to examine whether the accounts wherein recovery suits
have been filed, the initiative to resolve under CDR system is taken by at least by
75% of the creditors by value and 60% in number provided the account meets
the basic criteria for becoming eligible under CDR mechanism.
Treatment of accounts restructured under CDR program:
Classification and Provisioning
4.106 The criteria for classification of accounts will be on the basis of record of
recovery as per the existing prudential norms. The asset classification will be as
per the lender bank's record of recovery and will be bank specific.
4.107 The auditor should examine whether the lender has applied the usual
asset classification norms pending outcome of the account with the CDR Cell.
The asset classification status should be restored to the position, which existed
at the time of reference to the cell if the restructuring under the CDR system
takes place.
4.108 The auditor should also verify whether that in case a standard asset has
been restructured it has been downgraded to "substandard" asset. The auditor
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should also verify whether the proper disclosure in the Notes to Accounts in
respect of CDR of SME undertaken by the bank during the year, as prescribed in
the RBI's circular, has been made.
Guidelines on Scheme for Sustainable Structuring of Stressed
Assets (S4A)
4.109
Resolution of large borrowal accounts which are facing severe financial
difficulties may, inter-alia, require co-ordinated deep financial restructuring
which often involves a substantial write-down of debt and/or making large
provisions.
In order to ensure that adequate deep financial restructuring is done to give
projects a chance of sustained revival, the Reserve Bank, after due
consultation with banks, has decided to facilitate the resolution of large
accounts, which satisfy the conditions set out in the following paragraphs.
Eligible Accounts
For being eligible under the scheme, the account (In respect of
Securitisation Companies/ Reconstruction Companies (SCs/RCs), only
those accounts are eligible which, in addition to meeting the listed criteria,
have been acquired against consideration in cash only, i.e. not by issuing
any Security Receipts) should meet all the following conditions:
(i) The project has commenced commercial operations;
(ii) The aggregate exposure (including accrued interest) of all institutional
lenders in the account is more than Rs.500 crore (including Rupee
loans, Foreign Currency loans/External Commercial Borrowings);
(iii) The debt meets the test of sustainability as outlined in Debt
Sustainability below.
Debt Sustainability
A debt level will be deemed sustainable if the Joint Lenders Forum
(JLF)/Consortium of lenders/bank conclude through independent techno-
economic viability (TEV) that debt of that principal value amongst the current
funded/non-funded liabilities owed to institutional lenders can be serviced
over the same tenor as that of the existing facilities even if the future cash
flows remain at their current level. For this scheme to apply, sustainable debt
should not be less than 50 percent of current funded liabilities. This is
referred to as Part A in paragraph 2 of Sustainable Debt below.
Sustainable Debt
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1. The resolution plan may involve one of the following options with regard
to the post-resolution ownership of the borrowing entity:
(a) The current promoter continues to hold majority of the shares or
shares required to have control;
(b) The current promoter has been replaced with a new promoter, in
one of the following ways:
(i) Through conversion of a part of the debt into equity under
SDR mechanism which is thereafter sold to a new promoter;
(ii) In the manner contemplated as per Prudential Norms on
Change in Ownership of Borrowing Entities (Outside SDR
Scheme);
(c) The lenders have acquired majority shareholding in the entity
through conversion of debt into equity either under SDR or
otherwise; and
(i) allow the current management to continue; or
(ii) hand over management to another agency/professionals
under an operate and manage contract.
Note: Where malfeasance on the part of the promoter has been
established, through a forensic audit or otherwise, this scheme
shall not be applicable if there is no change in promoter or the
management is vested in the delinquent promoter.
2. In any of the circumstances mentioned above, the JLF/consortium/bank
shall, after an independent TEV, bifurcate the current dues of the
borrower into Part A and Part B as described below:
(a) Determine the level of debt (including new funding required to be
sanctioned within next six months and non-funded credit facilities
crystallising within next 6 months) that can be serviced (both
interest and principal) within the respective residual maturities of
existing debt, from all sources, based on the cash flows available
from the current as well as immediately prospective (not more than
six months) level of operations. For this purpose, free cash flows
(i.e., cash flow from operations minus committed capital
expenditure) available for servicing debt as per latest
audited/reviewed financial statement will be considered. Where
there is more than one debt facility, the maturity profile of each
facility shall be that which exists on the date of finalising this
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resolution plan. For the purpose of determining the level of debt
that can be serviced, the assessed free cash flow shall be
allocated to servicing each existing debt facility in the order in
which its servicing falls due. The level of debt so determined will
be referred to as Part A in these guidelines.
(b) The difference between the aggregate current outstanding debt,
from all sources, and Part A will be referred to as Part B in these
guidelines.
(c) The security position of lenders will, however, not be diluted and
Part A portion of loan will continue to have at least the same
amount of security cover as was available prior to this resolution.
The Resolution Plan
The Resolution Plan shall have the following features:
(a) There shall be no fresh moratorium granted on interest or principal
repayment for servicing of Part A.
(b) There shall not be any extension of the repayment schedule or
reduction in the interest rate for servicing of Part A, as compared
to repayment schedule and interest rate prior to this resolution.
(c) Part B shall be converted into equity/redeemable cumulative
optionally convertible preference shares. However, in cases where
the resolution plan does not involve change in promoter, banks
may, at their discretion, also convert a portion of Part B into
optionally convertible debentures. All such instruments will
continue to be referred to as Part B instruments in this circular for
ease of reference.
Valuation and marking to market
For the purpose of this scheme, the fair value for Part B instruments will
be arrived at as per the following methodologies:
(a) Equity - The equity shares in the bank's portfolio should be marked
to market preferably on a daily basis, but at least on a weekly basis.
Equity shares for which current quotations are not available or
where the shares are not listed on the stock exchanges, should be
valued at the lowest value arrived using the following valuation
methodologies:
o Break-up value (without considering 'revaluation reserves', if
any) which is to be ascertained from the company's latest
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audited balance sheet (which should not be more than one
year prior to the date of valuation). In case the latest audited
balance sheet is not available the shares are to be valued at
Re.1 per company. The independent TEV will assist in
ascertaining the break-up value.
o Discounted cash flow method where the discount factor is the
actual interest rate charged to the borrower plus 3 per cent,
subject to floor of 14 per cent. Further, cash flows ( cash flow
available from the current as well as immediately prospective
(not more than six months) level of operations) occurring within
85 per cent of the useful economic life of the project only shall
be reckoned.
(b) Redeemable cumulative optionally convertible preference shares/
optionally convertible debentures - The valuation should be on
discounted cash flow (DCF) basis. These will be valued with a
discount rate of a minimum mark up of 1.5 per cent over the
weighted average actual interest rate charged to the borrower for
the various facilities. Where preference dividends are in arrears, no
credit should be taken for accrued dividends and the value
determined as above on DCF basis should be discounted further by
at least 15 per cent if arrears are for one year, 25 per cent if arrears
are for two years, so on and so forth (i.e., with 10 percent
increments).
Where the resolution plan does not involve a change in promoter or
where existing promoter is allowed to operate and manage the company
as minority owner by lenders, the principle of proportionate loss sharing
by the promoters should be met. In such cases, lenders shall, therefore,
require the existing promoters to dilute their shareholdings, by way of
conversion of debt into equity /sale of some portion of promoter's equity
to lenders, at least in the same proportion as that of part B to total dues
to lenders. JLF/Consortium/bank should also obtain promoters' personal
guarantee in all such cases, for at least the amount of Part A.
The upside for the lenders will be primarily through equity/quasi equity,
if the borrowing entity turns around. The terms for exercise of option for
the conversion of preference shares/debentures to equity shall be
clearly spelt out. The existing promoter or the new promoter, as the
case may be, may have the right of first refusal in case the lenders
decide to sell the share, at a price beyond some predetermined price.
The lenders may also include appropriate covenants to cover the use of
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cash flows arising beyond the projected levels having regard to quasi-
equity instruments held in Part B.
Other important principles for this scheme are the following:
(a) The JLF/Consortium/bank shall engage the services of credible
professional agencies to conduct the TEV and prepare the
resolution plan. While engaging professional agencies, the
JLF/Consortium/bank shall ensure that the agency is reputed, truly
independent/free from any conflict of interest, has proven expertise
and will be in a position to safeguard the interest of lenders while
preserving the economic value of the assets.
(b) The resolution plan shall be agreed upon by a minimum of 75
percent of lenders by value and 50 percent of lenders by number in
the JLF/ consortium/ bank.
(c) At individual bank level, the bifurcation into Part A and part B shall
be in the proportion of Part A to Part B at the aggregate level.
Overseeing Committee
a) An Overseeing Committee (OC), comprising of eminent persons, will be
constituted by IBA in consultation with RBI. The members of OC cannot
be changed without the prior approval of RBI.
b) The resolution plan shall be submitted by the JLF/consortium/bank to
the OC.
c) The OC will review the processes involved in preparation of resolution
plan, etc. for reasonableness and adherence to the provisions of these
guidelines, and opine on it.
d) The OC will be an advisory body.
Asset Classification and Provisioning
(A) Where there is a change of promoter
In case a change of promoter takes place, i.e. a new promoter comes
in, the asset classification and provisioning requirement will be as per
the `SDR' scheme or `outside SDR' scheme as applicable.
(B) Where there is no change of promoters
(i) In view of the need to provide reasonable time to the overseeing
committee to review the processes involved in the resolution plan,
the Asset classification as on the date of lenders' decision to
resolve the account under these guidelines (reference date) will
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continue for a period of 180 days from this date. This standstill
clause is permitted to enable JLF/consortium/bank to formulate the
resolution plan, submit the same to the overseeing committee
formed under the guidelines and implement it.
Banks should normally submit the resolution plan to the overseeing
committee within 90 days from the reference date. It is expected
that the overseeing committee would review the processes involved
in preparation of resolution plan, etc. for reasonableness and
adherence to the provisions of these guidelines, and convey its final
opinion on it within a period of 45 days. Subsequently, banks shall
implement the resolution plan within the next 45 days. However,
banks will have flexibility on the above time lines, within the overall
period of 180 days. If the resolution plan is not implemented within
this period, the asset classification will be as per the extant asset
classification norms, assuming there was no such `stand-still'. It is
clarified that `stand-still' clause only applies to asset classification
and banks shall not recognize income on accrual basis if the
interest is not serviced within 90 days from the due date.
(ii) In respect of an account that is `Standard' as on the reference date,
the entire outstanding (both Part A and part B) may be treated as
'Standard' subject to provisions made upfront by the lenders
being at least the higher of 40 percent of the amount held in part
B or 20 percent of the aggregate outstanding (sum of Part A and
part B). For this purpose, the provisions already held in the account
can be reckoned. These provisions may be reversed one year after
the date of implementing the resolution plan or one year after
completion of the longest pre-existing moratorium, whichever is
later, subject to satisfactory performance of Part A and Part B
during this period.
(iii) In respect of an account that is classified as a non-performing asset
as on the reference date, the Part B instruments shall continue to
be classified as non- performing investment and provided for as a
non-performing asset as per extant prudential norms, as long as
such instruments remain in Part B. The sustainable portion (Part A)
may optionally be treated as `Standard' upon implementation of the
resolution plan by all banks, subject to provisions made upfront by
the lenders being at least the higher of 50 percent of the amount
held in part B or 25 percent of the aggregate outstanding (sum
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of Part A and part B). For this purpose, the provisions already
held in the account can be reckoned.
(iv) In all cases, lenders may upgrade Part B to standard category and
reverse the associated enhanced provisions after one year of
satisfactory performance of Part A loans. In case of any pre-
existing moratorium in the account, this upgrade will be permitted
one year after completion of the longest such moratorium, subject
to satisfactory performance of Part A debt during this period.
However, in all cases, the required MTM provisions on Part B
instruments must be maintained at all times. The transition benefit
available in terms of paragraph 9(B)(vi) can however be availed.
Banks shall make disclosures in their annual financial statements
on application of the Scheme for Sustainable Structuring of
Financial Assets, as per the format in the Appendix. These
disclosures shall be made with respect to the accounts under the
observation period specified at (iv) above.
Disclosures on the Scheme for Sustainable Structuring of Stressed
Assets (S4A), as on (INR Crore)
No. of accounts Aggregate Amount outstanding Provision
where S4A has amount Held
been applied outstanding
In Part A In Part B
Classified as XXXXX XXXXX XXXXX XXXXX
Standard
Classified as XXXXX XXXXX XXXXX XXXXX
NPA
(v) Any provisioning requirement on account of difference between the
book value of Part B instruments and their fair value as indicated in
para 7.2 ibid, in excess of the minimum requirements prescribed
as per the above para (ii) and (iii), shall be made within four
quarters commencing with the quarter in which the resolution plan
is actually implemented in the lender's books, such that the MTM
provision held is not less than 25 percent of the required provision
in the first quarter, not less than 50 percent in the second quarter
and so on. For this purpose, the provision already held in the
account can be reckoned.
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(vi) If the provisions held by the bank in respect of an account prior to
this resolution are more than the cumulative provisioning
requirement prescribed in the applicable sub-paragraphs above,
the excess can be reversed only after one year from the date of
implementation of resolution plan (i.e. when it is reflected in the
books of the lender, hereinafter referred to as `date of
restructuring'), subject to satisfactory performance during this
period.
(vii) The resolution plan and control rights should be structured in such
a way so that the promoters are not in a position to sell the
company/firm without the prior approval of lenders and without
sharing the upside, if any, with the lenders towards loss in Part B.
(viii) If Part A subsequently slips into NPA category, the account will be
classified with slippage in category with reference to the
classification obtaining on the reference date and necessary
provisions should be made immediately.
(ix) Where a bank/NBFC/AIFI chooses to make the prescribed
provisions/write downs over more than one quarter and this results
in the full provisioning/write down remaining to be made as on the
close of a financial year, banks/NBFCs/AIFIs should debit 'other
reserves' [i.e., reserves other than the one created in terms of
Section 17(2) of the Banking Regulation Act 1949] by the amount
remaining un-provided/not written down at the end of the financial
year, by credit to specific provisions. However, bank/NBFC/AIFI
should proportionately reverse the debits to `other reserves' and
complete the provisioning/write down by debiting profit and loss
account, in the subsequent quarters of the next financial year.
Banks shall make suitable disclosures in Notes to Accounts with
regard to the quantum of provision made during the year under this
scheme and the quantum of unamortised provisions debited to
`other reserves' as at the end of the year.
Mandatory Implementation
Once the resolution plan prepared/presented by the lenders is ratified by the
OC, it will be binding on all lenders. They will, however, have the option to
exit as per the extant guidelines on Joint Lenders' Forum (JLF) and
Corrective Action Plan (CAP).
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Timelines for Stressed Assets Resolution
4.110 RBI Circular DBR.BP.BC.No.67/21.04.048/2016-17 dated May 05, 2017
describes the timelines for stressed assets resolution.
"Framework for Revitalising Distressed Assets in the Economy Guidelines
on Joint Lenders' Forum (JLF) and Corrective Action Plan (CAP)" aims at
early identification of stressed assets and timely implementation of a
corrective action plan (CAP) to preserve the economic value of stressed
assets. In order to ensure that the CAP is finalised and formulated in an
expeditious manner, the Framework specifies various timelines within which
lenders have to decide and implement the CAP. The Framework also
contains disincentives, in the form of asset classification and accelerated
provisioning where lenders fail to adhere to the provisions of the
Framework. Despite this, delays have been observed in finalising and
implementation of the CAP, leading to delays in resolution of stressed
assets in the banking system.
CAP can also include resolution by way of Flexible Structuring of Project
Loans, Change in Ownership under Strategic Debt Restructuring, Scheme
for Sustainable Structuring of Stressed Assets (S4A), etc.
Lenders must scrupulously adhere to the timelines prescribed in the
Framework for finalising and implementing the CAP. To facilitate timely
decision making, it has been decided that, henceforth, the decisions agreed
upon by a minimum of 60 percent of creditors by value and 50 percent of
creditors by number in the JLF would be considered as the basis for
deciding the CAP, and will be binding on all lenders, subject to the exit (by
substitution) option available in the Framework. Lenders shall ensure that
their representatives in the JLF are equipped with appropriate mandates,
and that decisions taken at the JLF are implemented by the lenders within
the timelines.
It shall be noted that
(i) the stand of the participating banks while voting on the final proposal
before the JLF shall be unambiguous and unconditional;
(ii) any bank which does not support the majority decision on the CAP
may exit subject to substitution within the stipulated time line, failing
which it shall abide the decision of the JLF;
(iii) the bank shall implement the JLF decision without any additional
conditionalities; and
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(iv) the Boards shall empower their executives to implement the JLF
decision without requiring further approval from the Board.
Accelerated Provision Norms
4.111 In cases where banks fail to report SMA status of the accounts to
CRILC or resort to methods with the intent to conceal the actual status of the
accounts or evergreen the account, banks will be subjected to accelerated
provisioning for these accounts and/or other supervisory actions as deemed
appropriate by RBI. The current provisioning requirement and the revised
accelerated provisioning in respect of such non-performing accounts are
provided in para 31.1 of Master Circular no. RBI/2015-16/101 DBR.No.BP.BC.2/
21.04.048/ 2015-16 dated July 1, 2015.
4.112 Further, any of the lenders who have agreed to the restructuring
decision under the CAP by JLF and is a signatory to the ICA and DCA, but
changes their stance later on, or delays/refuses to implement the package, will
also be subjected to accelerated provisioning requirement as indicated at para
31.1 of the aforementioned Master Circular, on their exposure to this borrower
i.e., if it is classified as an NPA. If the account is standard in those lenders'
books, the provisioning requirement would be 5%.
4.113 Presently, asset classification is based on record of recovery at
individual banks and provisioning is based on asset classification status at the
level of each bank. However, if lead bank or the bank with second largest AE as
per Reserve bank of India circular no. DBOD.BP.BC.No.45/21.04.132/2014-15
dated October 21, 2014 fail to convene the JLF or fail to agree upon a common
CAP within the stipulated time frame, the account will be subjected to
accelerated provisioning as indicated at para 31.1 of the aforementioned Master
Circular, if it is classified as an NPA. If the account is standard in those lenders'
books, the provisioning requirement would be 5%.
4.114 If an escrow maintaining bank under JLF/CDR mechanism does not
appropriate proceeds of repayment by the borrower among the lenders as per
agreed terms resulting into down gradation of asset classification of the account
in books of other lenders, the account with the escrow maintaining bank will
attract the asset classification which is lowest among the lending member banks
but will also be subjected to corresponding accelerated provision instead of
normal provision. Further, such accelerated provision will be applicable for a
period of one year from the effective date of provisioning or till rectification of the
error, whichever is later.
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Duration of application of extant penal provisions (5% in case of
Standard account and accelerated provision in case of NPAs)
4.115 Penal provisions are applicable under certain cases vide circular
DBOD.BP.BC.No.97/21.04.132/ 2013-14 dated February 26, 2014. While the
duration of such penal provision has been specified in case of an escrow account
maintaining bank which does not appropriate proceeds of repayment by the
borrower among the lenders as per agreed terms resulting into down gradation of
asset classification of the account in books of other lenders, the duration has not
been prescribed in other cases. Banks are advised that the penal provisions in
the other cases under the Framework will be applicable for the following
durations:
Sl. Reason for Penal Provision Duration
No.
(i) Banks fail to report SMA status of From the date of imposition of
the accounts to CRILC or resort to penal provision as advised by
methods with the intent to conceal RBI Inspection/Statutory Auditor
the actual status of the accounts or till one year or rectification of
evergreen the account. defect, whichever is later.
(ii) Lenders who have agreed to the
restructuring decision under the CAP
by JLF and are signatories to the
ICA and DCA, but change their
stance later on, or delay/refuse to
implement the package.
(iii) Lenders fail to convene the JLF or
fail to agree upon a common CAP
within the stipulated time frame.
(iv) Accelerated provision for existing From the date of notification as
loans/exposures of banks to wilful defaulter in the list of wilful
companies having director/s (other defaulters till the removal of the
than nominee directors of name from the list.
government/financial institutions
brought on board at the time of
distress), whose name/s appear
more than once in the list of wilful
defaulters.
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Disagreement on restructuring as CAP and Exit Option
4.116 In terms of para 10.3 of circular DBOD.BP.BC.No.45 / 21.04.132 / 2014-
15 dated October 21, 2014 banks, irrespective of whether they are within or
outside the minimum 75 per cent and 60 per cent, can exercise the exit option for
providing additional finance only by way of arranging their share of additional
finance to be provided by a new or existing creditor.
4.117 It has been brought to notice that sometimes disagreement arises
among lenders on deciding the CAP on rectification or restructuring, resulting in
delay in initiating timely corrective action. Although co-operation among lenders
for deciding a CAP by consensus is desirable for timely turn-around of a viable
account, it is also important to enable all lenders to have an independent view on
the viability of account and consequent participation in rectification or
restructuring of accounts, without allowing them to free ride on efforts made by
others. In view of this, it has been decided that dissenting lenders who do not
want to participate in the rectification or restructuring of the account as CAP,
which may or may not involve additional financing, will have an option to exit their
exposure completely by selling their exposure to a new or existing lender(s)
within the prescribed timeline for implementation of the agreed CAP. The exiting
lender will not have the option to continue with their existing exposure and
simultaneously not agreeing for rectification or restructuring as CAP. The new
lender to whom the exiting lender sells its stake may not be required to commit
any additional finance, if the agreed CAP involves additional finance. In such
cases, if the new lender chooses to not to participate in additional finance, the
share of additional finance pertaining to the exiting lender will be met by the
existing lenders on a pro-rata basis.
Wilful Defaulter and Non-Cooperative Borrower
4.118 The provisioning in respect of existing loans/exposures of banks to
companies having director/s (other than nominee directors of
government/financial institutions brought on board at the time of distress), whose
name/s appear more than once in the list of wilful defaulters, will be 5% in cases
of standard accounts; if such account is classified as NPA, it will attract
accelerated provisioning as indicated at para 31.1 of Master Circular on
Prudential Norms. This is a prudential measure since the expected losses on
exposures to such borrowers are likely to be higher. It is reiterated that no
additional facilities should be granted by any bank/FI to the listed wilful
defaulters, in terms of paragraph 2.5 (a) of Master Circular on Wilful Defaulters
dated July 1, 2015.
4.119 With a view to discouraging borrowers/defaulters from being
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unreasonable and non-cooperative with lenders in their bona fide
resolution/recovery efforts, banks may classify such borrowers as non-
cooperative borrowers, after giving them due notice if satisfactory clarifications
are not furnished. Banks will be required to report classification of such
borrowers to CRILC. Further, banks will be required to make higher/accelerated
provisioning in respect of new loans/exposures to such borrowers as also new
loans/exposures to any other company promoted by such promoters/ directors or
to a company on whose board any of the promoter / directors of this non-
cooperative borrower is a director. The provisioning applicable in such cases will
be at the rate of 5% if it is a standard account and accelerated provisioning as
per para 31.1 of Master Circular on Prudential Norms, if it is an NPA. Reporting
of non-cooperative borrower has to be read along with Reserve Bank of India
circular no. DBR.No.CID.BC.54/20.16.064/2014-15.
Resolution of Stressed Assets Revised Framework w.e.f. February
12, 2018
4.120 The RBI has issued a circular dated February 12, 2018 about
`Resolution of Stressed Assets Revised Framework', wherein the existing
provisions w.r.t. stress assets have been revised in entirety with discontinuation
of various enabling provisions for retention of class of assets (under Corrective
Action Plan (CAP), Strategic Debt Restructuring (SDR), Scheme for Sustainable
Structuring of Stressed Assets (S4A). All accounts including the one where any
of the schemes have been invoked but not yet implemented, shall be governed
by revised framework.
4.121 RBI had put a comma for restructuring by discontinuing special
regulatory treatment for Asset classification from 31 March 2015. However, the
introduction / continuation of schemes like CAP, SDR, S4A, etc. allowed banks to
keep accounts standard after restructuring. With the new guidelines issued on
February 12, 2018, the RBI has overhauled the restructuring framework by
discontinuing prevalent restructuring schemes like CAP, SDR, S4A, etc. The new
framework goes one step ahead as it aims at resolution of stressed asset and not
just restructuring. With the enactment of Insolvency & Bankruptcy Code, 2016
(IBC), the process of resolution in case of failure of restructuring can be
expedited.
4.122 The key highlights of the Resolution of Stressed Assets Revised
Framework are as under;
1. Early identification and reporting of stress
a. Lenders shall identify emerging stress in loan accounts and categorise
the same as under:
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Asset Classification, Income Recognition and Provisioning
SMA Sub - Basis for classification Principal or interest
Categories payment or any other amount wholly or partly
overdue between
SMA 0 1 30 days
SMA 1 31 60 days
SMA 2 61 90 days
b. The lenders to report credit information and SMA classification of all
borrower entities in default with aggregate exposure of Rs.5 crore and
above to CRILC.
2. Implementation of resolution plan (RP)
a. All lenders should put Board approved policies for resolution of stressed
assets under this framework with timelines.
b. Lenders (singly or jointly) shall initiate steps to cure the default.
c. The resolution plan may involve any of the following actions:
i. Regularisation of the account by payment of all overdues by
borrower entity.
ii. Sale of exposures to other entities / investors.
iii. Change in ownership.
iv. Restructuring.
d. RP shall be clearly documented by all lenders irrespective of (and
including no) change in terms and conditions.
3. Implementation Conditions for RP
a. Borrower entity is no longer in default with any of the lenders.
b. Resolution plan involves restructuring.
i. Completion of documentation by all lenders.
ii. New capital structure and / or revised terms and conditions of
existing loans get reflected in books of all lenders and borrower.
c. RPs involving restructuring / change in ownership where exposure is
Rs.100 crores and above:
i. Independent Credit Evaluation (ICE) by authorized Credit rating
agencies (CRA) of residual debt.
ii. Exposure of Rs. 500 Crore and above, ICE from two CRAs & that
not more than Rs.500 Crore, ICE from one CRA.
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iii. RP 4 or better shall be considered for implementation.
iv. If ICE from more than one CRA all CRA should give RP4 or better.
v. Payment to CRA should be made by lenders. (instead of borrower
as per earlier norms)
vi. ICE is applicable for all large accounts immediately. (i.e., from
February 12, 2018) irrespective whether restructuring is carried out
before March 01, 2018.
4. Timelines for Large Accounts to be referred under IBC
i. Aggregate exposure of Rs. 2000 crores and above on or after March 01,
2018. (reference date)
ii. Resolution initiated in new or existing framework or restructured
standard account, RP shall be implemented as per following timelines:
i) Default on 1 March 2018 within 180 days.
ii) Default after 1 March 2018, within 180 days from default.
iii. If, RP not implemented within timeline then insolvency application under
Insolvency and Bankruptcy Code, 2016 (IBC) within 15 days from date
of expiry of timeline.
iv. RP implemented no default within specified period. (one year from end
of moratorium period or date by which 20% of principal and capitalised
interest is repaid, whichever is later)
v. If default during specified period referred file insolvency petition within
15 days of default.
vi. Default after specified period to be considered as Fresh default.
vii. Aggregate Exposure below 2000 crore & not less than Rs. 100 crore
separate guidelines to be issued.
viii. Borrower under Specific instructions by RBI, earlier instructions
continue.
5. Prudential Norms applicable to any restructuring (whether under IBC or
outside IBC framework:
i. During process of RP, usual asset classification norms continue to
apply.
ii. Restructuring Standard advance to be downgraded as NPA. NPA
remain in existing bucket.
iii. Ageing criteria as per Extant norms continues.
iv. Upgraded based on
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i) Satisfactory performance during `specified period'.
ii) Aggregate Exposure of Rs.100 crore and above, satisfactory
performance and Credit rating of BBB- or better at the end of
specified period from CRA.
iii) Aggregate Exposure of Rs.500 crore and above, credit rating by
two CRAs and all ratings should be BBB- or better.
v. Default during specified period then NPA date will be reckoned as per
pre-restructuring repayment schedule.
vi. Provisioning as per Extant IRAC norms.
vii. Existing restructured accounts as per norms applicable to existing
restructuring schemes.
viii. Additional Finance Classified as "Standard" during specified period. In
case of default or non-upgradation as per restructured debt.
ix. Income recognition: For Restructured Standard asset, income would be
recognized on Accrual basis and for Additional Finance to restructured
NPA and Restructured NPA, income would be recognized on Cash
basis, except in case wherein the restructuring is accompanied by
change in ownership.
6. Conversion of principal into Debt / Equity & unpaid interest into FITL, Debt or
Equity Instrument:
i. Asset classification Same as per restructured account.
ii. Valuation Equity: Marked to Market, if quoted. Otherwise breakup value
as per previous year balance sheet. If previous year balance sheet
portfolio is valued at Re.1. No set off for depreciation with appreciation
in other shares.
iii. Unrealised income recognition
i) FITL / Debt: On sale or redemption
ii) Unquoted Equity: On sale
iii) Quoted equity: Market value of equity on date of upgradation not
exceeding unrealized income.
7. Change in ownership
In case of change in ownership, Advance can be classified as standard, if
(i) Acquirer is not a person disqualified as per IBC.
(ii) New promoter holds 26% equity and largest shareholder.
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(iii) New promoter shall be in control of borrowing entity.
(iv) RP implemented as per existing guidelines - Such accounts, will
continue to be classified as standard based on satisfactory performance
during specified period. In case of default, the facilities would be
classified as Sub standard and future upgradation would be contingent
on implementation of fresh RP.
Provision held cannot be reversed till demonstration of satisfactory
performance during specified period.
8. Sale & Leaseback transaction as restructuring will be treated as
restructuring in case of debt of buyer and seller, if
(i) Seller is in financial difficulty; and,
(ii) More than 50% revenue of buyer from leased asset to seller; and,
(iii) 25% or more loan by buyer for purchase of asset are funded by lenders
of seller.
9. Refinancing of Exposure in foreign or Indian Currency
Foreign Currency / Export Advances for the purpose of repayment of rupee
loan to be treated as restructuring, if borrower is in financial difficulty; and
(i) Foreign currency borrowing from Indian Banking System or based on
BGs, LCs Letter of comfort from Indian banking System; or
(ii) Rupee loans for refinancing.
In case of extension of DCCO, the existing IRAC norms are applicable.
Upgradation of Loan Accounts Classified as NPAs
4.123
(i) If arrears of interest and principal are paid by the borrower in the case of
loan accounts classified as NPAs, the account should no longer be
treated as non-performing and may be classified as `standard' accounts.
Upgradation is allowed only if the account reaches "no overdues" status.
This should not be misunderstood with "overdues brought within 90 days".
Upgradation of a restructured/ rescheduled/CDR accounts is governed by
the restructuring / reschedulement/CDR norms.
(ii) Auditor has to verify that any upgrading of accounts classified as `Sub-
Standard' or `Doubtful' category wherein restructuring / rephasement of
principal or interest has taken place should be upgraded to the `Standard
Asset' category only after a period of one year after the date when first
payment of interest or of principal, whichever is earlier, falls due under the
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Asset Classification, Income Recognition and Provisioning
rescheduled terms, subject to satisfactory performance during the period.
The total amount becoming due during this period of one year should be
recovered and there should be no overdues to make it eligible for
upgradation. If the amount which has become due during this one year
period is on a lower side vis a vis total amount outstanding, the other
aspects of the account, viz financial performance, availability of security,
operations in account, etc., should be reviewed in detail and only if found
satisfactory, the account should be upgraded.
(iii) Recovery in an advance which was rescheduled cannot give the advance a
better classification than the previous one. NPA accounts can be upgraded
to Performing Accounts, provided all overdue are adjusted.
(iv) Upgradation within the NPA category is not permitted i.e. a Doubtful
account cannot be made Sub-standard even if the overdue are reduced to
less than 12 months.
Relief for MSME borrowers registered under GST
4.124 The RBI has issued a circular dated February 07, 2018 granting relief
for MSME Borrowers registered under GST, thus, the auditors need to be vigilant
as regards the applicability of the said circular and eligibility of the borrower. This
circular applies only to borrowers which are classified as micro, small and
medium enterprise under the MSMED Act, 2006. The exposure of banks to such
borrowers would be classified as standard assets subject to conditions specified
in the circular:
1. The borrower is registered under the GST regime as on January 31, 2018.
2. The aggregate exposure including non-fund-based facilities of banks and
NBFCs, to the borrower does not exceed Rs. 25 crores as on January 31,
2018.
Thus, the overall exposure of the borrower (including that of multiple
banking, consortium banking) as on January 31, 2018 should not exceed Rs.
25 crores, i.e. the overall exposure of the borrower to banks and NBFCs
combined should not exceed the cap of Rs. 25 crores. Further, it is to be
noted that as per RBI Master Circular on Exposure Norms `Exposure' shall
include credit exposure (funded and non-funded credit limits) and investment
exposure (including underwriting and similar commitments). The sanctioned
limits or outstandings, whichever are higher, shall be reckoned for arriving at
the exposure limit. However, in the case of fully drawn term loans, where
there is no scope for re-drawal of any portion of the sanctioned limit, banks
may reckon the outstanding as the exposure.
3. The borrower's account should be standard account as on August 31, 2017.
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It would be pertinent to note that some banks may be following a system of
marking of accounts as NPA in the system as at quarter-end instead of
marking the accounts on on-going basis. However, the borrower account
needs to be tested for classification purpose as on August 31, 2017 and in
case if such account is a NPA account as per the extant of IRAC norms
specified by RBI as on August 31, 2017, irrespective of the account being
marked or not by the bank, such accounts will not be eligible for relief
granted by this circular.
4. The amount from the borrower, overdue as on September 01, 2017 and
payments from the borrower due between September 01, 2017 and January
31, 2018 are paid not later than 180 days from their respective original due
date.
As per para 2.3 of Master Circular of RBI on IRAC norms `any amount due
to the bank under any credit facility is `overdue' if it is not paid on the due
date fixed by the bank'. Thus, the extension period of 180 days granted for
the repayment of the overdue amount as on September 01, 2017 as well as
the amounts due between the specified period is restricted to the extent of
180 days from the respective `due date'. Further, as per the email dated April
03, 2018 from DBR, Reserve Bank of India, Central Office "It is clarified
that CC/OD limits are part of the aggregate exposure to the borrower.
OD/CC accounts which become `out of order' as per para 2.2 of our master
circular on IRAC norms dated July 1, 2015 between September 01, 2017
and January 31, 2018 may continue to be classified as standard provided
that the irregularity in the account is removed within a period not exceeding
90 days from the original date of the account becoming `out of order'.
5. A provision of 5% shall be made against such exposures which are not
classified as NPA (due to the relaxation as provided above), which otherwise
would have been classified as NPA as per usual IRAC norms (of accounts
overdue beyond 90 days period).
6. The additional time provided is for the purpose of asset classification only
and not for income recognition.
Thus, if an account is otherwise eligible to be classified as NPA as per usual
IRAC norms (of accounts overdue beyond 90 days period) but is classified as PA
based on the above-mentioned relaxation granted, the income is required to be
recognised on realisation basis and not on accrual basis.
4.125 Further RBI has issued a circular RBI/2017-18/186 DBR.No.BP.BC.
108/21.04.048/2017-18 dated June 06, 2018 for Encouraging Formalisation of
MSME Sector. This circular is in continuity with the February 07, 2018 Circular on
MSME Borrowers registered under GST, thus, the auditors needs to be vigilant
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as regards the applicability of these both circulars and eligibility of the borrowers.
This circular applies only to borrowers which are classified as micro, small and
medium enterprise under the MSMED Act, 2006. The exposure of banks to such
borrowers would be classified as standard assets subject to conditions specified
in the circular as detailed below:
i. The aggregate exposure, including non-fund based facilities, of banks and
NBFCs to the borrower does not exceed 250 million as on May 31, 2018.
ii. The borrower's account was standard as on August 31, 2017.
iii. The payments due from the borrower as on September 1, 2017 and falling
due thereafter up to December 31, 2018 were/are paid not later than 180
days from their original due date.
iv. In respect of dues payable by GST-registered MSMEs from January 1,
2019 onwards, the 180 days past due criterion shall be aligned to the extant
IRAC norms in a phased manner, as given in the Annexure below.
However, for MSMEs that are not registered under GST as on December
31, 2018, the asset classification in respect of dues payable from January
1, 2019 onwards shall immediately revert to the extant IRAC norms.
Period during which any payment falls due Time Permitted
September 01, 2017 December 31, 2018 180 days
January 01, 2019 February 28, 2019 150 days
March 01, 2019 April 30, 2019 120 days
May 01, 2019 onwards 90 days
v. The other terms and conditions of the circular dated February 07, 2018
remain unchanged.
4.126 The RBI has recently issued a circular RBI/2018-19/100
DBR.No.BP.BC.18/21.04.048/2018-19 dated January 01, 2019 permitting one
time restructuring of existing loans of MSMEs classified as `Standard' without a
downgrade in asset classification subject to certain conditions. The said circular
is issued with reference to the earlier circulars related to MSME borrowers issued
on February 07, 2018 and June 06, 2018. The one time restructuring as stated
above is subject to conditions in specified in the circular as detailed below:
i. The aggregate exposure, including non-fund based facilities, of banks and
NBFCs to the borrower does not exceed 250 million as on January 01,
2019.
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ii. The borrower's account (can be in default but) is standard as on January
01, 2019 and continues to be standard asset till the date of implementation
of the restructuring.
iii. The borrower is registered under GST as on the date of implementation of
restructuring. However, this condition will not apply to MSMEs which are
exempt from GST registration.
iv. The restructuring of the borrower account is implemented on or before
March 31, 2020. A restructuring would be treated as implemented if the
following conditions are met:
a. All related documentation including execution of necessary agreements
between lenders and borrowers / creation of security charges / perfection of
securities are completed by all lenders; and,
b. The new capital structure and / or changes in the terms and conditions of
existing loans gets duly reflected in books of all lenders and the borrower.
v. A provision of 5% in addition to the provision already held shall be made
w.r.t. the accounts restructured under these instructions. Such provision
can be reversed at the end of specified period subject to the account
demonstrating satisfactory performance during the specified period.
`Specified Period' means a period of one year from the commencement of
the first payment of interest or principal, whichever is later, on the credit
facility with longest period of moratorium under the terms of restructuring
package. `Satisfactory Performance' means no payment (interest and/or
principal) shall remain overdue for a period of more than 30 days. In case of
cash credit / overdraft account, satisfactory performance means that the
outstanding in the account shall not be more than the sanctioned limit or
drawing power, whichever is lower, for a period of more than 30 days.
vi. Subsequent to the restructuring, NPA Classification of these accounts shall
be as per extant IRAC norms.
vii. Appropriate disclosure in the financial statements under `Notes on
Accounts' related to MSME restructured accounts under these instructions
would be required specifying number of accounts restructured and Amount.
viii. All other instructions applicable to restructuring of loans to MSME
borrowers shall continue to be applicable.
The RBI has further clarified that the accounts classified as NPA can be
restructured, however, the extant asset classification norms governing
restructuring of NPAs continues to apply.
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As a general rule, barring the above one-time exception, any MSME account,
which is restructured must be downgraded to NPA upon restructuring and will slip
into progressively lower asset classification and higher provisioning requirements
as per extant IRAC norms. Such an account may be considered for upgradation
to `standard' only if it demonstrates satisfactory performance during the specified
period.
Provisioning for Loans and Advances
4.127 The RBI's Master Circular of July 1, 2015 on Income Recognition,
Asset Classification and Provisioning Pertaining to Advances contains the
principles to be followed by the bank in calculating the provisions required for
the NPAs in conformity with the prudential norms. The circular also requires
the bank to take into consideration aspects such as time lag between an
account becoming an NPA, its recognition as such, realisation of security and
the erosion over time in the value of security charged to the bank, while
calculating the required amount of provision. The specific requirements of the
Master Circular in respect of provisioning are as follows:
(a) Loss assets
4.128 The entire amount should be written off. If the assets are permitted to
remain in the books for any reason, 100 percent of the outstanding should be
provided for.
(b) Doubtful assets
4.129 The provisioning for doubtful assets under loans and advances is as
under:
(i) Full provision to the extent of the unsecured portion should be made. In
doing so, the realisable value of the security available, to which the bank
has a valid recourse, should be determined on a realistic basis. Auditor
should verify whether that the security is considered based on the latest
information available with the bank. DICGC/ECGC cover is also taken
into account.
(ii) In regard to the secured portion, provision may be made on the following
basis, at the rates ranging from 25% to 100% of secured portion
depending upon the period for which the asset has remained doubtful. In
case the advance covered by CGTSI guarantee becomes non-
performing, no provision need be made towards the guaranteed portion.
The amount outstanding in excess of the guaranteed portion should be
provided for as per the extant guidelines on provisioning for non-
performing advances.
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Period for which the advance has been % of provision on
considered as doubtful secured portion
Upto 1 year 25
More than 1 year and upto 3 years 40
More than three years 100
Valuation of Security: With a view to bringing down divergence arising out of
difference in assessment of the value of security, in cases of NPAs with
balance of Rs. 5 crore and above, stock audit at annual intervals by external
agencies appointed as per the guidelines approved by the Board is mandatory
in order to enhance the reliability on stock valuation. Collaterals, such as
immovable properties charged in favour of the bank are required to be got
valued once in three years by valuers appointed as per the guidelines
approved by the Board of Directors.
(c) Sub-standard assets
4.130 A general provision of 15% on total outstanding should be made
without making any allowance for DICGC/ECGC cover and securities available.
Unsecured exposures, which are identified, as sub-standard would attract an
additional provision of 10%. (i.e., total 25% of total outstanding). However, in
view of certain safeguards such as escrow accounts available in respect of
infrastructure lending, infrastructure loan accounts which are classified as sub-
standard will attract a provisioning of 20 per cent instead of the aforesaid
prescription of 25 per cent. To avail of this benefit of lower provisioning, the
banks should have in place an appropriate mechanism to escrow the cash
flows and also have a clear and legal first claim on these cash flows.
Unsecured exposure' is defined as an exposure (including all funded and non-
funded exposures) where realisable value of the tangible security properly
charged to the bank, as assessed by bank/approved valuers/RBI inspectors, is
not more than 10%, ab initio, of the outstanding exposure. `Security' means
tangible security properly discharged to the bank and will not include intangible
securities like guarantees (including State government guarantees), comfort
letters, etc.
4.131 In order to enhance transparency and ensure correct reflection of the
unsecured advances in Schedule 9 of the banks' balance sheet, the following
RBI requirements are applicable from the financial year 2009-10 onwards:
a) For determining the amount of unsecured advances for reflecting in
schedule 9 of the published balance sheet, the rights, licenses,
authorisations, etc., charged to the banks as collateral in respect of
projects (including infrastructure projects) financed by them, should not be
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reckoned as tangible security. Hence such advances shall be reckoned as
unsecured.
b) However, banks may treat annuities under Build-Operate-Transfer (BOT)
model in respect of road / highway projects and toll collection rights, where
there are provisions to compensate the project sponsor if a certain level of
traffic is not achieved, as tangible securities subject to the condition that
banks' right to receive annuities and toll collection rights is legally
enforceable and irrevocable.
c) It is noticed that most of the infrastructure projects, especially
road/highway projects are user-charge based, for which the Planning
Commission has published Model Concession Agreements (MCAs). These
have been adopted by various Ministries and State Governments for their
respective public-private partnership (PPP) projects and they provide
adequate comfort to the lenders regarding security of their debt. In view of
the above features, in case of PPP projects, the debts due to the lenders
may be considered as secured to the extent assured by the project
authority in terms of the Concession Agreement, subject to the following
conditions:
i) User charges / toll / tariff payments are kept in an escrow account
where senior lenders have priority over withdrawals by the
concessionaire;
ii) There is sufficient risk mitigation, such as pre-determined increase in
user charges or increase in concession period, in case project
revenues are lower than anticipated;
iii) The lenders have a right of substitution in case of concessionaire
default;
iv) The lenders have a right to trigger termination in case of default in
debt service; and
v) Upon termination, the Project Authority has an obligation of (i)
compulsory buy-out and (ii) repayment of debt due in a pre-
determined manner.
In all such cases, banks must satisfy themselves about the legal
enforceability of the provisions of the tripartite agreement and factor in
their past experience with such contracts.
d) Banks should also disclose the total amount of advances for which
intangible securities such as charge over the rights, licenses, authority,
etc., has been taken as also the estimated value of such intangible
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collateral. The disclosure may be made under a separate head in "Notes to
Accounts". This would differentiate such loans from other entirely
unsecured loans.
4.132 As per the existing instructions of RBI, in the Balance Sheet of the
banks, the amounts comprising Debtors (though not tangible assets), charged
as security are grouped as secured by tangible assets and disclosure is made
with a remark in parenthesis in the Schedule 9, without any quantification of the
advances covered by security of Debtors. The amounts comprising the
intangibles as per the RBI's Master Circular on Income recognition and Asset
Classification Norms will need to be culled out of the secured exposures and
quantified to be reflected as unsecured advances; which would also require
corresponding reclassification of advances for the earlier year. More
importantly, in case of NPAs, the unsecured portion would attract a higher
provision, when segregated from the secured portion.
(d) Standard Assets
4.133 The bank is required to make a general provision for standard assets
at the following rates for the funded outstanding on global loan portfolio basis.
The general provision towards standard assets as per Master Circular is as
follows:
a) Farm Credit to Agricultural and Small and Micro Enterprises (SMEs)
sectors - 0.25%.
b) Advances to Commercial Real Estate (CRE) sector 1.00%.
c) Advances to Commercial Real Estate Residential Housing Sector (CRE -
RH) at 0.75 per cent.
For this purpose, CRE-RH would consist of loans to builders/developers
for residential housing projects (except for captive consumption) under
CRE segment. Such projects should ordinarily not include non-residential
commercial real estate. However, integrated housing projects comprising
of some commercial space (e.g. shopping complex, school, etc.) can also
be classified under CRE-RH, provided that the commercial area in the
residential housing project does not exceed 10% of the total Floor Space
Index (FSI) of the project. In case the FSI of the commercial area in the
predominantly residential housing complex exceeds the ceiling of 10%,
the project loans should be classified as CRE and not CRE-RH.
d) Housing loans extended at teaser rates 2.00%- The provisioning on
these assets would revert to 0.40 per cent after 1 year from the date on
which the rates are reset at higher rates if the accounts remain `standard'.
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Asset Classification, Income Recognition and Provisioning
e) In terms of RBI Circular No. RBI/2016-17/317-DBR.BP.BC.No.
72/08.12.015/2016-17 dated June 7,2017, the bank should make standard
asset provision of 0.25% on individual housing loan sanctioned on or after
7th June 2017. In respect of individual housing loan sanctioned before that
date provisions @ 0.40% is required to be made on standard assets in
terms of Circular No. DBR.BP.BC.No.44/ 08.12.015/ 2015-16 dated
October 8, 2015.
f) Restructured accounts classified as standard advances will attract a higher
provision (as prescribed from time to time) in the first two years from the
date of restructuring. In cases of moratorium on payment of
interest/principal after restructuring, such advances will attract the
prescribed higher provision for the period covering moratorium and two
years thereafter.
Restructured accounts classified as non-performing advances, when
upgraded to standard category will attract a higher provision (as prescribed
from time to time) in the first year from the date of upgradation.
As per para 17.4.1 of IRAC Norms, with effect from April 1, 2016 provision on
new restructured standard accounts would be made at 5 per cent. The phased
manner plan for increase in the provision to 5 per cent was in existence till
March 31, 2016.
All other loans and advances not included in (a), (b), (c), (d) and (e) above -
0.40%.
4.134 It is clarified that the Medium Enterprises will attract 0.40% standard
asset provisioning. The definition of the terms Micro Enterprises, Small
Enterprises, and Medium Enterprises shall be in terms of Master Circular on
Lending to Micro, Small & Medium Enterprises (MSME) Sector.
4.135 While the provisions on individual portfolios are required to be
calculated at the rates applicable to them, the excess or shortfall in the
provisioning, vis-a-vis the position as on any previous date, should be
determined on an aggregate basis. If the provisions required to be held on an
aggregate basis are less than the provisions held as on November 15, 2008,
the provisions rendered surplus should not be reversed to P&L account but
should continue to be maintained at the level, existed as on November 15,
2008. In case of shortfall determined on aggregate basis, the balance should
be provided for by debit to P&L account.
4.136 The provisions on standard assets should not be reckoned for arriving
at net NPAs. The provisions towards Standard Assets need not be netted from
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Guidance Note on Audit of Banks (Revised 2019)
gross advances but included as 'Contingent Provisions against Standard
Assets' under 'Other Liabilities and Provisions - Others' in Schedule 5 of the
balance sheet.
4.137 Banks shall make additional provision of 2% (in addition to country risk
provision that is applicable to all overseas exposures) against standard assets
representing all exposures to the step-down subsidiaries of Indian companies,
to cover the additional risk arising from complexity in the structure, location of
different intermediary entities in different jurisdictions exposing the Indian
company, and hence the bank, to greater political and regulatory risk. All the
step-down subsidiaries, including the intermediate ones, must be wholly owned
subsidiary of the immediate parent company or its entire shares shall be jointly
held by the immediate parent company and the Indian parent company and / or
its wholly owned subsidiary. The immediate parent should, wholly or jointly with
Indian parent company and / or its wholly owned subsidiary, have control over
the step-down subsidiary.
4.138 A high level of unhedged foreign currency exposures of the entities
can increase the probability of default in times of high currency volatility.
Hence, banks are required to estimate the riskiness of unhedged position of
their borrowers as per the instructions contained in RBI circular
DBOD.No.BP.BC.85/21.06.200/2013-14 dated January 15, 2014 and circular
DBOD.No.BP.BC.116/21.06.200/2013-14 dated June 3, 2014 and make
incremental provisions on their exposures to such entities:
Likely Loss / EBID (%) Incremental Provisioning
Requirement on the total
credit exposures over and
above extant standard asset
provisioning
Upto 15 per cent 0
More than 15 per cent and upto 30 per cent 20 bps
More than 30 per cent and upto 50 per cent 40 bps
More than 50 per cent and upto 75 per cent 60 bps
More than 75 per cent 80 bps
Provisioning requirements for derivative exposures
4.139 Credit exposures computed as per the current marked to market value
of the contract, arising on account of the interest rate & foreign exchange
derivative transactions, and gold, shall also attract provisioning requirement as
applicable to the loan assets in the 'standard' category, of the concerned
counterparties. All conditions applicable for treatment of the provisions for
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standard assets would also apply to the aforesaid provisions for derivative and
gold exposures.
Provisioning Norms for Leased Assets
4.140
i) Substandard assets
a) 15 percent of the sum of the net investment in the lease and the
unrealised portion of finance income net of finance charge
component. The terms `net investment in the lease', `finance income'
and `finance charge' are as defined in `AS 19 Leases' issued by the
ICAI.
b) Unsecured lease exposures which are identified as `substandard'
would attract additional provision of 10 per cent, i.e., a total of 25 per
cent.
ii) Doubtful; and
iii) Loss assets
This is same as for Loan Assets.
Provisioning Coverage Ratio
4.141
i. Provisioning Coverage Ratio (PCR) is essentially the ratio of provisioning
to gross non-performing assets and indicates the extent of funds a bank
has kept aside to cover loan losses.
ii. From a macro-prudential perspective, RBI had required that the banks
should build up provisioning and capital buffers in good times i.e. when the
profits are good, which can be used for absorbing losses in a downturn.
This was aimed at enhancing the soundness of individual banks, as also
the stability of the financial sector. It was, therefore, decided that banks
should augment their provisioning cushions consisting of specific provisions
against NPAs as well as floating provisions, and ensure that their total
provisioning coverage ratio, including floating provisions, is not less than 70
per cent. Accordingly, banks were advised to achieve this norm not later
than end-September 2010.
RBI has further advised the banks that:
a. the PCR of 70 percent may be with reference to the gross NPA
position in banks as on September 30, 2010;
b. the surplus of the provision under PCR vis-a-vis as required as per
prudential norms should be segregated into an account styled as
"countercyclical provisioning buffer", computation of which may be
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Guidance Note on Audit of Banks (Revised 2019)
undertaken as per the format given in Annex 3 to the RBI's Master
Circular on "Prudential Norms on Income Recognition, Asset
Classification and Provisioning pertaining to Advances" dated July 1,
2015; and
c. this buffer will be allowed to be used by banks for making specific
provisions for NPAs during periods of system wide downturn, with the
prior approval of RBI. As a countercyclical measure, vide RBI circular
No. DBOD.No.BP. 95/21.04.048/2013-14 on "Utilisation of Floating
Provisions/Counter Cyclical Provisioning Buffer" dated February 7,
2014 banks were permitted to utilise upto 33 per cent of countercyclical
provisioning buffer / floating provisions held by them as on March 31,
2013, for making specific provisions for non-performing assets, as per
the policy approved by their Board of Directors;
d. banks are required to build up `Dynamic Provisioning Account' during
good times and utilize the same during downturn. Under the proposed
framework, banks are expected to either compute parameters such as
probability of default, loss given default, etc. for different asset classes
to arrive at long term average annual expected loss or use the
standardized parameters prescribed by RBI towards computation of
Dynamic Provisioning requirement. Dynamic loan loss provisioning
framework is expected to be in place with improvement in the system.
Meanwhile, banks should develop necessary capabilities to compute
their long term average annual expected loss for different asset
classes, for switching over to the dynamic provisioning framework.
iii. The PCR of the bank should be disclosed in the Notes to Accounts to the
Balance Sheet.
Accounting and Provisioning Norms for Equipment Leasing Activity
4.142 While the accounting and provisioning norms discussed above shall
also apply in respect of equipment leasing activities the bank should follow the
AS 19 on "Leases" issued by ICAI in accounting for lease transactions.
Provisioning for Certain Specific Types of Advances
4.143 The guidelines also deal with provisioning for certain specific types of
advances as follows.
Advances Guaranteed by ECGC
4.144 In the case of advances guaranteed by ECGC, provision should be
made only for the balance in excess of the amount of such guarantee. Further,
while arriving at the provision required to be made for doubtful assets,
realisable value of the securities should first be deducted from the outstanding
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Asset Classification, Income Recognition and Provisioning
balance in respect of the amount guaranteed by these Corporations and then
provision should be made. (For examples on calculation of the provision, refer
the Master Circular on Income Recognition, Asset Classification and
Provisioning Pertaining to Advances, dated July 1, 2015)
Advance covered by guarantees of Credit Guarantee Fund Trust for Micro
and Small Enterprises (CGTMSE) or Credit Risk Guarantee Fund Trust for
Low Income Housing (CRGFTLIH)
4.145 In case the advance covered by CGTMSE or CRGFTLIH guarantee
becomes non-performing, no provision need be made towards the guaranteed
portion. The amount outstanding in excess of the guaranteed portion should be
provided for as per the extant guidelines on provisioning for non- performing
advances. For illustrative examples of provisioning in case of advances
covered by CGTSI guarantee, refer the paragraph 5.9.5 of the Master Circular
No. on Prudential Norms on Income Recognition, Asset Classification and
Provisioning Pertaining to Advances, dated July 1, 2015.
4.146 After statutory audit, RBI conducts annual financial inspection of banks.
Auditors may go through the divergence reported by RBI, if any, in terms of
classification as well as provisioning and whether the same divergence has been
appropriately addressed /clarified, by Banks. Accordingly, auditor would be well
advised to consider these aspects while take final view on classification
/provisioning of such accounts.
Treatment of interest suspense account
4.147 Amounts 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.
Disclosures
4.148 The information with respect to NPAs required to be disclosed under
"Notes to Accounts" in the financial statements of banks is discussed in the
Chapter 8 "Disclosure Requirement in Financial Statements" of Part III of the
Guidance Note on Audit of Banks, 2019 edition (Section A Statutory Central
Audit).
Provisioning Norms
Normal provisions
4.149 Banks will hold provision against these advances as per the existing
provisioning norms.
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Guidance Note on Audit of Banks (Revised 2019)
Income Recognition
4.150 The banks may recognise income on accrual basis in respect of the
three categories of projects under implementation which are classified as
'standard'. RBI, however, prohibits banks from recognising income on accrual
basis in respect of the above three categories of projects under implementation
which are classified as a `substandard' asset. Banks may recognise income in
such accounts only on realisation on cash basis.
Reserve for Exchange Rate Fluctuations Account (RERFA)
4.151 When exchange rate movements of Indian rupee turn adverse, the
outstanding amount of foreign currency denominated loans (where actual
disbursement was made in Indian Rupee) which become overdue goes up
correspondingly, with its attendant implications of provisioning requirements.
Such assets should not normally be revalued. In case such assets need to be
revalued as per requirement of accounting practices or for any other
requirement, the following procedure may be adopted:
The loss on revaluation of assets has to be booked in the bank's Profit &
Loss Account.
Besides the provisioning requirement as per Asset Classification, banks
should treat the full amount of the Revaluation Gain relating to the
corresponding assets, if any, on account of Foreign Exchange Fluctuation
as provision against the particular assets.
Provisioning For Country Risk
4.152 Banks are required to make provisions, with effect from the year
ending 31 March 2003, on the net funded country exposures on a graded scale
ranging from 0.25 to 100 percent according to the risk categories mentioned
below. To begin with, banks are required to make provisions as per the
following schedule:
Risk Category ECGC Provisioning
Classification requirement (per cent)
Insignificant A1 0.25
Low A2 0.25
Moderate B1 5
High B2 20
Very high C1 25
Restricted C2 100
Off-credit D 100
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Asset Classification, Income Recognition and Provisioning
4.153 Banks are required to make provision for country risk in respect of a
country where its net funded exposure is one per cent or more of its total assets.
The provision for country risk shall be in addition to the provisions required to be
held according to the asset classification status of the asset. In the case of `loss
assets' and `doubtful assets', provision held, including provision held for country
risk, may not exceed 100% of the outstanding. Banks may not make any
provision for `home country' exposures i.e. exposure to India. The exposures of
foreign branches of Indian banks to the host country should be included. Foreign
banks shall compute the country exposures of their Indian branches and shall
hold appropriate provisions in their Indian books. However, their exposures to
India will be excluded. Banks may make a lower level of provisioning (say 25% of
the requirement) in respect of short-term exposures (i.e., exposures with
contractual maturity of less than 180 days).
4.154 Provisioning norms for sale of financial assets to Securitisation
Company (SC) / Reconstruction company (RC)
(i) When a bank / FI sells its financial assets to SC/ RC, on transfer the
same will be removed from its books.
(ii) If the sale of financial assets to SC/RC, is at a price below the net book
value (NBV) (i.e., book value less provisions held), the shortfall should be
debited to the profit and loss account of that year. Banks can also use
countercyclical / floating provisions for meeting any shortfall on sale of
NPAs i.e., when the sale is at a price below the net book value (NBV).
However, for assets sold on or after February 26, 2014 and upto March
31, 2015, as an incentive for early sale of NPAs, banks can spread over
any shortfall, if the sale value is lower than the NBV, over a period of two
years. This facility of spreading over the shortfall will be subject to
necessary disclosures in the Notes to Account in Annual Financial
Statements of the banks. The RBI vide Notification dated May 21, 2015
had decided to extend this dispensation for assets sold on or after March
31, 2015 and up to March 31, 2016.
Further RBI has vide notification DBR.No.BP.BC.102/21.04.048/2015-16
dated June 13, 2016 has decided to extend the dispensation of amortising
the shortfall up to March 31, 2017. However, for the assets sold from the
period April 1, 2016 to March 31, 2017, banks will be allowed to amortise
the shortfall over a period of only four quarter from the quarter in which
the sale took place.
Further, where a bank chooses to make the necessary provisions over
more than one quarter and this results in the full provisioning remaining to
be made as on the close of a financial year, banks should debit 'other
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Guidance Note on Audit of Banks (Revised 2019)
reserves' [i.e., reserves other than the one created in terms of Section 17(2)
of the Banking Regulation Act 1949] by the amount remaining un-provided
at the end of the financial year, by credit to specific provisions. However,
banks should proportionately reverse the debits to `other reserves' and
complete the provisioning by debiting profit and loss account, in the
subsequent quarters of the next financial year.
Banks shall make suitable disclosures in Notes to Accounts with regard to
the quantum of provision made during the year to meet the shortfall in
sale of NPAs to SCs/RCs and the quantum of unamortised provision
debited to `other reserves' as at the end of the year.
(iii) For assets sold on or after February 26, 2014, banks can reverse the
excess provision on sale of NPAs, if the sale value is for a value higher
than the NBV, to its profit and loss account in the year the amounts are
received. However, banks can reverse excess provision arising out of
sale of NPAs only when the cash received (by way of initial consideration
and / or redemption of SRs / PTCs) is higher than the net book value
(NBV) of the asset. Further, reversal of excess provision will be limited to
the extent to which cash received exceeds the NBV of the asset. With
regard to assets sold before February 26, 2014, excess provision, on
account of sale value being higher than NBV, should not be reversed but
should be utilized to meet the shortfall/ loss on account of sale of other
financial assets to SC/RC.
(iv) When banks/ FIs invest in the security receipts/ pass-through certificates
issued by SC/RC in respect of the financial assets sold by them to the
SC/RC, the sale shall be recognised in books of the banks / FIs at the
lower of:
the redemption value of the security receipts/ pass-through
certificates, and
the NBV of the financial asset.
The above investment should be carried in the books of the bank / FI at
the price as determined above until its sale or realization, and on such sale
or realization, the loss or gain must be dealt with in the same manner as at
(ii) and (iii) above.
4.155 All instruments received by banks/FIs from SC/RC as sale
consideration for financial assets sold to them and also other instruments
issued by SC/ RC in which banks/ FIs invest will be in the nature of non SLR
securities. Accordingly, the valuation, classification and other norms applicable
to investment in non-SLR instruments prescribed by RBI from time to time
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Asset Classification, Income Recognition and Provisioning
would be applicable to bank's/ FI's investment in debentures/ bonds/ security
receipts/PTCs issued by SC/ RC. However, if any of the above instruments
issued by SC/RC is limited to the actual realisation of the financial assets
assigned to the instruments in the concerned scheme the bank/ FI shall reckon
the Net Asset Value (NAV), obtained from SC/RC from time to time, for
valuation of such investments.
4.156 Banks'/ FIs' investments in debentures/ bonds/ security receipts/PTCs
issued by a SC/RC will constitute exposure on the SC/RC. As only a few
SC/RC are being set up now, banks'/ FIs' exposure on SC/RC through their
investments in debentures/ bonds/security receipts/PTCs issued by the SC/ RC
may go beyond their prudential exposure ceiling. In view of the extra ordinary
nature of event, banks/ FIs will be allowed, in the initial years, to exceed
prudential exposure ceiling on a case-to-case basis.
4.157 Banks/ FIs, which sell their financial assets to an SC/ RC, shall be
required to make the disclosures in the Notes on Accounts to their Balance
sheets. For guidelines on the presentation of the disclosures, refer para 6.6 of
the master circular BR.No.BP.BC.2/21.04.048/2015-16 - Prudential norms on
Income Recognition, Asset Classification and Provisioning pertaining to
Advances.
4.158 Prudential Guidelines on provisioning in case of Revitalising Stressed
Assets in the Economy.
Pursuant to the RBI notification DBR.BP.BC.No.82/ 21.04.132 / 2015-16 dated
February 25, 2016 on Review of Prudential Guidelines- Revitalising Stressed
Assets in the Economy, the classification of the advances and provisioning
thereon will be as follows:
Category A-
In case the lender agreed to Corrective Action Plan (CAP) in the Joint Leander
Forum (JLF) meeting and also conveyed final approval to the CAP within the
stipulated period.
Asset classification- As per the extant asset classification norms
Provisioning- As per the extant provisioning norms.
Category-B
In case the lender agreed to CAP as approved in the JLF meeting but
conveyed final approval and signed off the detailed final CAP after the
stipulated period but within the prescribed implementation period.
Asset classification: Lowest asset classification of the borrower among all the
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JLF lenders.
Provisioning- A penal provisioning of 10 per cent in addition to provisioning
applicable as per Lowest asset classification of the borrower with any JLF
lender, for one year from the date of sign off of CAP.
Category-C
In case the lender agreed to CAP, as approved, in the JLF meeting but failed to
convey final approval and sign off the detailed final CAP within prescribed
implementation period.
Asset classification: Lowest asset classification of the borrower among all the
JLF lenders.
Provisioning: A penal provisioning of 15 per cent in addition to provisioning
applicable as per Lowest asset classification of the borrower with any JLF
lender, for one year from the date of sign off of CAP.
As the prescribed implementation period is over, the lender has to compulsorily
abide by the terms of the approved CAP.
4.159 RBI vide their circular dated 1 September 2016 has issued guidelines
on Sale of Stressed Assets by Banks. In terms of these guidelines, the Board
of the bank need to lay down detailed policies and guidelines on sale of
stressed assets to SC/ RC which should, inter alia, cover the following aspects:
i. Financial assets to be sold.
ii. Norms and procedure for sale for such financial assets.
iii. Valuation procedure to be followed to ensure that the realisable value of
financial assets is reasonably estimated.
iv. Delegation of powers of various functionaries for taking decision on the
sale of the financial assets; etc.
Auditors need to ensure that the Bank comply with the RBI Guidelines issued
on 1 September vide circular number RBI/2016-17/56 DBR.No.BP.BC.9/
21.04.048/2016-17. In addition to the existing disclosure, Banks need to
comply with the disclosure requirement in this circular.
4.160 Disclosure Requirements
A. Details of financial assets sold to SC/RC: (Amounts in Rupees crore)
1. No. of accounts sold.
2. Aggregate outstanding. (net of provisions)
3. Aggregate consideration received.
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Asset Classification, Income Recognition and Provisioning
4. Additional consideration realized in respect of accounts transferred in
earlier years.
5. Aggregate gain / loss over net book value.
B. Details of Book Value of investments in Security receipts: (Amounts in Rupees
crore)
1. Book Value of investments in Security receipts - Backed by NPA's sold by
bank as underlying.
2. Book Value of investments in Security receipts Backed by NPA's sold by
other banks / financial institutions/ non banking financial companies as
underlying.
3. Totals of above.
Other Aspects
4.161 Certain other important aspects of the guidelines relating to
provisioning are discussed below.
Floating Provisions
Principle for Creation and Utilisation of Floating Provisions by Banks
4.162 RBI mandates banks to hold floating provisions in respect of
"Advances" as well as "Investments" separately. The Master Circular of July 1,
2015 on Prudential Norms on Income Recognition, Asset Classification and
Provisioning Pertaining to Advances, requires the Board of Directors of banks
to lay down a policy regarding the level to which floating provisions can be
created. The floating provisions should not be used for making specific
provisions as per the extant prudential guidelines in respect of nonperforming
assets or for making regulatory provisions for standard assets. The floating
provisions can be used only for contingencies under extraordinary
circumstances for making specific provisions in impaired accounts after
obtaining board's approval and with prior permission of RBI. The boards of the
banks should lay down an approved policy as to what circumstances would be
considered extraordinary.
4.163 It is clarified that the extra-ordinary circumstances refer to losses
which do not arise in the normal course of business and are exceptional and
non-recurring in nature. These extra-ordinary circumstances could broadly fall
under three categories viz. General, Market and Credit. Under general
category, there can be situations where bank is put unexpectedly to loss due to
events such as civil unrest or collapse of currency in a country. Natural
calamities and pandemics may also be included in the general category.
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Market category would include events such as a general melt down in the
markets, which affects the entire financial system. Among the credit category,
only exceptional credit losses would be considered as an extra-ordinary
circumstance.
4.164 Floating provisions cannot be reversed by credit to the profit and loss
account. They can only be utilised for making specific provisions in
extraordinary circumstances as mentioned above. Until such utilisation, these
provisions can be netted off from gross NPAs to arrive at disclosure of net
NPAs. Alternatively, they can be treated as part of Tier II capital within the
overall ceiling of 1.25 % of total risk weighted assets. Banks should make
comprehensive disclosures on floating provisions in the "notes on accounts" to
the balance sheet on (a) opening balance in the floating provisions account, (b)
the quantum of floating provisions made in the accounting year, (c) purpose
and amount of draw down made during the accounting year, and (d) closing
balance in the floating provisions account.
Additional Provisions for NPAs at higher than prescribed rates
4.165 A bank may voluntarily make specific provisions for advances at rates
which are higher than the rates prescribed under existing regulations, to
provide for estimated actual loss in collectible amount, provided such higher
rates are approved by the Board of Directors and consistently adopted from
year to year. Such additional provisions are not to be considered as floating
provisions. The additional provisions for NPAs, like the minimum regulatory
provision on NPAs, may be netted off from gross NPAs to arrive at the net
NPAs.
Loss Assets
4.166 Every bank should have board approved policy for classification of
advance account as Loss Asset. The Auditor should review the policy and ensure
that all important criteria for classification of account as Loss Asset is covered in
policy.
Further, the Bank should consistently apply policy to all advance accounts and in
case of any deviation same also need to be approved by board. The auditor
should ensure compliance with policy of classification of account as Loss Asset.
Write-off of NPAs
4.167 The banks should either make full provision as per the guidelines or
write off the advances and claim the tax benefits as are applicable, by evolving
appropriate methodology in consultation with their auditors/tax consultants.
Recoveries made in such accounts should be offered for tax purposes as per
the rules. Banks may write-off advances at Head Office level, even though the
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advances are still outstanding in the branch books. At the branch level,
provision requirement as per classification norms shall be made and in respect
of loss assets 100% provision shall be made.
Guidelines on Sale/Purchase of NPAs
4.168 The Master Circular on Advances require the Board of Directors of the
banks to lay down policy in respect of the aspects relating to sale/ purchase of
NPAs, including:
(a) Non-performing financial assets that may be purchased/ sold;
(b) Norms and procedure for purchase/ sale of such financial assets;
(c) Valuation procedure to be followed to ensure that the economic value of
financial assets is reasonably estimated based on the estimated cash
flows arising out of repayments and recovery prospects;
(d) Delegation of powers of various functionaries for taking decision on the
purchase/ sale of the financial assets etc.; and
(e) Accounting policy.
4.169 RBI also casts a responsibility on the Board to satisfy itself that the bank
has adequate skills to purchase non-performing financial assets and deal with
them in an efficient manner which will result in value addition to the bank.
4.170 Banks should, while selling NPAs, work out the net present value of the
estimated cash flows associated with the realisable value of the available
securities net of the cost of realisation. The sale price should generally not be
lower than the net present value so arrived.
4.171 The estimated cash flows are normally expected to be realised within a
period of three years and at least 10% of the estimated cash flows should be
realised in the first year and at least 5% in each half year thereafter, subject to
full recovery within three years.
4.172 A bank may purchase/sell nonperforming financial assets from/to other
banks only on `without recourse' basis, i.e., the entire credit risk associated with
the nonperforming financial assets should be transferred to the purchasing bank.
Selling bank shall ensure that the effect of the sale of the financial assets should
be such that the asset is taken off the books of the bank and after the sale there
should not be any known liability devolving on the selling bank.
4.173 Banks should ensure that subsequent to sale of the non-performing
financial assets to other banks. They do not have any involvement with reference
to assets sold and do not assume operational, legal or any other type of risks
relating to the financial assets sold. Consequently, the specific financial asset
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should not enjoy the support of credit enhancements / liquidity facilities in any
form or manner.
4.174 Under no circumstances can a sale to other banks be made at a
contingent price whereby in the event of shortfall in the realisation by the
purchasing banks, the selling banks would have to bear a part of the shortfall.
Further, NPAs can be sold to other banks only on cash basis. The entire sale
consideration should be received upfront and the asset can be taken out of the
books of the selling bank only on receipt of the entire sale consideration.
4.175 A non-performing financial asset should be held by the purchasing bank
in its books at least for a period of 15 months before it is sold to other banks.
Banks should not sell such assets back to the bank, which had sold the NPFA.
4.176 Banks are also permitted to sell/buy homogeneous pool within retail
non-performing financial assets, on a portfolio basis provided each of the non-
performing financial assets of the pool has remained as non-performing financial
asset for at least 2 years in the books of the selling bank. The pool of assets
would be treated as a single asset in the books of the purchasing bank.
4.177 The selling bank should pursue the staff accountability aspects as per
the existing instructions in respect of the non-performing assets sold to other
banks.
4.178 Prudential norms for banks for the purchase/sale transactions issued by
RBI, from time to time, should be adhered to.
4.179 As per the Master Circular on Prudential Norms on Advances dated July
1, 2015, if the sale is in respect of Standard Asset and the sale consideration is
higher than the book value, the excess provisions may be credited to Profit and
Loss Account. Excess provisions which arise on sale of NPAs can be admitted
as Tier II capital subject to the overall ceiling of 1.25% of total Risk Weighted
Assets. Accordingly, these excess provisions that arise on sale of NPAs would
be eligible for Tier II status.
Asset Classification Norms
4.180 The asset classification norms for sale/purchase of NPAs are as follows:
(i) The non-performing financial asset purchased, may be classified as
`standard' in the books of the purchasing bank for a period of 90 days from
the date of purchase. Thereafter, the asset classification status of the
financial asset purchased, shall be determined by the record of recovery in
the books of the purchasing bank with reference to cash flows estimated
while purchasing the asset which should be in compliance with
requirements as discussed in preceding paragraphs.
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(ii) The asset classification status of an existing exposure (other than
purchased financial asset) to the same obligor in the books of the
purchasing bank will continue to be governed by the record of recovery of
that exposure and hence may be different.
(iii) Where the purchase/sale does not satisfy any of the prudential
requirements prescribed in these guidelines the asset classification status
of the financial asset in the books of the purchasing bank at the time of
purchase shall be the same as in the books of the selling bank. Thereafter,
the asset classification status will continue to be determined with reference
to the date of NPA in the selling bank.
(iv) Any restructure/reschedule/rephrase of the repayment schedule or the
estimated cash flow of the non-performing financial asset by the purchasing
bank shall render the account as a non-performing asset.
Provisioning Norms
Books of Selling Bank
4.181 The provisioning norms for books of selling bank are as under:
(i) When a bank sells its nonperforming financial assets to other banks, the
same will be removed from its books on transfer.
(ii) If the sale is at a price below the net book value (NBV) (i.e., book value
less provisions held), the shortfall should be debited to the profit and loss
account of that year.
(iii) If the sale is for a value higher than the NBV, the excess provision shall
not be reversed but will be utilised to meet the shortfall/ loss on account of
sale of other non-performing financial assets.
Books of Purchasing Bank
4.182 The provisioning norms for books of purchasing bank are as under:
The asset shall attract provisioning requirement appropriate to its asset
classification status in the books of the purchasing bank.
Accounting of Recoveries
4.183 Any recovery in respect of a non-performing asset purchased from other
banks should first be adjusted against its acquisition cost. Recoveries in excess
of the acquisition cost can be recognised as profit.
Capital Adequacy
4.184 For the purpose of capital adequacy, banks should assign 100% risk
weights to the non-performing financial assets purchased from other banks. In
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case the nonperforming asset purchased is an investment, then it would attract
capital charge for market risks also.
Exposure Norms
4.185 The purchasing bank will reckon exposure on the obligor of the specific
financial asset. Hence these banks should ensure compliance with the prudential
credit exposure ceilings (both single and group) after reckoning the exposures to
the obligors arising on account of the purchase.
Disclosure Requirements
4.186 Banks which purchase nonperforming financial assets from other banks
shall be required to make the following disclosures in the Notes on Accounts to
their Balance sheets:
A. Details of non-performing financial assets purchased: (Amounts in Rupees
crore)
1. (a) No. of accounts purchased during the year.
(b) Aggregate outstanding.
2. (a) Of these, number of accounts restructured during the year.
(b) Aggregate outstanding.
B. Details of nonperforming financial assets sold: (Amounts in Rupees crore)
1. No. of accounts sold.
2. Aggregate outstanding.
3. Aggregate consideration received.
4. Additional consideration realized in respect of accounts transferred in
earlier years.
5. Aggregate gain / loss over net book value.
C. Details of Book Value of investments in Security receipts: (Amounts in
Rupees crore)
1. Book Value of investments in Security receipts - Backed by NPA's sold by
bank as underlying.
2. Book Value of investments in Security receipts Backed by NPA's sold by
other banks / financial institutions/ non banking financial companies as
underlying.
3. Totals of above.
The purchasing bank shall furnish all relevant reports to RBI, Credit Information
Company which has obtained Certificate of Registration from RBI and of which
the bank is a member etc. in respect of the nonperforming financial assets
purchased by it.
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Auditor's Report in case of Bank Borrowers
4.187 The RBI vide its circular no. DBOD.No. CAS(COD)BC.146/27-77
dated December 22, 1977 had prescribed that all borrowers having credit limit
of Rs.10 lakh and above from the banking system should get their annual
accounts audited by chartered accountants. Further the RBI vide its circular
DBOD.No.BP.BC.33/21.04.018/2002-03 dated October 21, 2002 has
authorised the Board of Directors of banks to fix a suitable cut off limit with
reference to the borrowing entity's overall exposure on the banking system,
over which audit of accounts of borrower by chartered accountants would be
mandatory.
Sale/ Purchase of NPAs
4.188 In case of a sale/ purchase of NPAs by the bank, the auditor should
examine the policy laid down by the Board of Directors in this regard relating to
procedures, valuation and delegation of powers.
4.189 The auditor should also examine that:
(i) only such NPA has been sold which has remained NPA in the books of the
bank for at least 2 years.
(ii) the assets have been sold/ purchased "without recourse' only.
(iii) subsequent to the sale of the NPA, the bank does not assume any legal,
operational or any other type of risk relating to the sold NPAs.
(iv) the NPA has been sold at cash basis only.
(v) the bank has not purchased an NPA which it had originally sold.
4.190 In case of sale of an NPA, the auditor should also examine that:
(i) on the sale of the NPA, the same has been removed from the books of the
account.
(ii) the short fall in the net book value (NBV) has been charged to the profit and
loss account.
(iii) where the sale is for a value higher than the NBV, no profit is recognised
and the excess provision has not been reversed but retained to meet the
shortfall/ loss on account of sale of other non-performing financial assets.
4.191 Similarly, in case of purchase of NPAs, the auditor should verify that:
(i) the NPA purchased has been subjected to the provisioning requirements
appropriate to the classification status in the books of the selling bank.
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Guidance Note on Audit of Banks (Revised 2019)
(ii) any recovery in respect of an NPA purchased from other banks is first
adjusted against its acquisition cost and only the recovered amount in
excess of the acquisition cost has been recognised as profit.
(iii) for the purpose of capital adequacy, bank has assigned 100% risk weights
to the NPAs purchased from other banks.
Verification of Provision for Non-performing assets
4.192 An important aspect of audit of advances relates to their classification and
provisioning. This implies that a proper provision should be made in respect of
advances where the recovery is doubtful. As mentioned earlier, the Reserve Bank
has prescribed objective norms for determining the quantum of provisions required
in respect of advances. The auditors must familiarise himself fully with the norms
prescribed by RBI in this regard. However, these norms should be construed as
laying down the minimum provisioning requirements and wherever a higher
provision is warranted in the context of the threats to recovery, such higher
provision should be made. Provisions of section 15 of the Banking Regulation Act,
1949, which applies to banking companies, nationalised banks, State Bank of
India, its subsidiaries, and regional rural banks, the bank concerned should make
adequate provision for bad debts to the satisfaction of its auditor before paying any
dividends on its shares.
4.193 The accounting entry for provision in respect of debts that are doubtful
of recovery is usually made at the head office level and is not recorded in the
books at the branch level. The amount of provision to be made at the head office
level is based largely on the classification of various advances into standard,
sub-standard, doubtful and loss categories. The auditor should carefully examine
whether the classification made by the branch is appropriate. In doing so, he
should particularly examine the classification of advances where there are
threats to recovery. The auditor should also examine whether the secured and
the unsecured portions of advances have been segregated correctly and
provisions have been calculated properly.
4.194 As per the Reserve Bank guidelines, if an account has been regularised
before the balance sheet date by payment of overdue amount through genuine
sources, the account need not be treated as NPA. Where, subsequent to
repayment by the borrower (which makes the account regular), the branch has
provided further funds to the borrower (including by way of subscription to its
debentures or in other accounts of the borrower), the auditor should carefully
assess whether the repayment was out of genuine sources or not. 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 satisfaction of Statutory Auditors about the
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Asset Classification, Income Recognition and Provisioning
manner of regularisation of the account to eliminate doubts on their performing
status.
4.195 The statutory auditors should consider the issues emerging from recent
RBI inspections and obtain an understanding of changes made by the banks
pursuant to the inspection process to enhance their identification of NPA.
Further, the audit procedures should be suitably re-designed to consider such
issues. It is to be examined whether that the classification is made as per the
position as on date and hence classification of all standard accounts be reviewed
as on balance sheet date. The sample of loans selected during the statutory
audit should have greater considerations of large corporate borrowers in Special
Mention Accounts II (SMA-II) Category, projects where implementation is
delayed and accounts subjected to any form of restructuring. The date of NPA is
of significant importance to determine the classification and hence specific care
be taken in this regard. The regularisation and / or closure of account subsequent
to the date of balance sheet will not have any impact on improvisation of the
classification of advance as on the date of NPA.
Projects under Implementation
4.196 For all projects financed by the FIs/ banks after 28th May 2002, the date
of completion of the project should be clearly spelt out at the time of financial
closure of the project.
Project Loans
4.197 There are occasions when the completion of projects is delayed for
legal and other extraneous reasons like delays in Government approvals etc. All
these factors, which are beyond the control of the promoters, may lead to delay
in project implementation and involve restructuring/reschedulement of loans by
banks. Accordingly, the following asset classification norms would apply to the
project loans before commencement of commercial operations. These guidelines
will, however, not be applicable to restructuring of Advances classified as
Commercial Real Estate exposures; Advances classified as Capital Market
exposure; and Consumer and Personal Advances which will continue to be dealt
with in terms of the extant provisions.
4.198 For this purpose, all project loans have been divided into the following
two categories:
a. Project Loans for infrastructure sector.
b. Project Loans for non-infrastructure sector.
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Guidance Note on Audit of Banks (Revised 2019)
'Project Loan' would mean any term loan which has been extended for the
purpose of setting up of an economic venture. Banks must fix a Date of
Commencement of Commercial Operations (DCCO) for all project loans at the
time of sanction of the loan / financial closure (in the case of multiple banking or
consortium arrangements).
Project Loans for Infrastructure Sector
4.199
(i) A loan for an infrastructure project will be classified as NPA during any time
before commencement of commercial operations as per record of recovery
(90 days overdue), unless it is restructured and becomes eligible for
classification as 'standard asset' in terms of paras (iii) to (v) below.
(ii) A loan for an infrastructure project will be classified as NPA if it fails to
commence commercial operations within two years from the original DCCO,
even if it is regular as per record of recovery, unless it is restructured and
becomes eligible for classification as 'standard asset' in terms of paras (iii)
to (v) below.
(iii) If a project loan classified as 'standard asset' is restructured any time during
the period up to two years from the original date of commencement of
commercial operations (DCCO), in accordance with the provisions of Part B
of this Master Circular, it can be retained as a standard asset if the fresh
DCCO is fixed within the following limits, and further provided the account
continues to be serviced as per the restructured terms.
(a) Infrastructure Projects involving court cases
Up to another 2 years (beyond the existing extended period of 2 years
i.e. total extension of 4 years), in case the reason for extension of date
of commencement of production is arbitration proceedings or a court
case.
(b) Infrastructure Projects delayed for other reasons beyond the control of
promoters
Up to another 1 year (beyond the existing extended period of 2 years
i.e. total extension of 3 years), in other than court cases.
(iv) It is re-iterated that the dispensation is subject to adherence to the
provisions regarding restructuring of accounts as contained in the Master
Circular which would inter alia require that the application for restructuring
should be received before the expiry of period of two years from the original
DCCO and when the account is still standard as per record of recovery.
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The other conditions applicable would be:
a. In cases where there is moratorium for payment of interest, banks
should not book income on accrual basis beyond two years from the
original DCCO, considering the high risk involved in such restructured
accounts.
b. Banks should maintain provisions on such accounts as long as these
are classified as standard assets as under:
Particulars Provisioning Requirement
If the revised DCCO is within two 0.40 per cent
years from the original DCCO
prescribed at the time of
financial closure
If the DCCO is extended beyond Project loans restructured with effect
two years and upto four years or from June 1, 2013:
three years from the original 5.00 per cent From the date of such
DCCO, as the case may be, restructuring till the revised DCCO or
depending upon the reasons for 2 years from the date of restructuring,
such delay whichever is later
Stock of project loans classified as
restructured as on June 1, 2013:
3.50 per cent - with effect from
March 31, 2014 (spread over the
four quarters of 2013-14)
4.25 per cent - with effect from
March 31, 2015 (spread over the
four quarters of 2014-15)
5.00 per cent - - with effect from
March 31, 2016 (spread over the
four quarters of 2015-16)
The above provisions will be
applicable from the date of
restructuring till the revised DCCO or
2 years from the date of restructuring,
whichever is later.
(v) For the purpose of these guidelines, mere extension of DCCO would not be
considered as restructuring, if the revised DCCO falls within the period of
two years from the original DCCO. In such cases the consequential shift in
repayment period by equal or shorter duration (including the start date and
end date of revised repayment schedule) than the extension of DCCO
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would also not be considered as restructuring provided all other terms and
conditions of the loan remain unchanged.
(vi) In case of infrastructure projects under implementation, where Appointed
Date (as defined in the concession agreement) is shifted due to the inability
of the Concession Authority to comply with the requisite conditions, change
in date of commencement of commercial operations (DCCO) need not be
treated as `restructuring', subject to following conditions:
a. The project is an infrastructure project under public private partnership
model awarded by a public authority;
b. The loan disbursement is yet to begin;
c. The revised date of commencement of commercial operations is
documented by way of a supplementary agreement between the
borrower and lender; and
d. Project viability has been reassessed and sanction from appropriate
authority has been obtained at the time of supplementary agreement.
Change in Ownership
4.200
i. In order to facilitate revival of the projects stalled primarily due to
inadequacies of the current promoters, if a change in ownership takes place
any time during the periods quoted in paragraphs 4.2.15.3 of the circular or
before the original DCCO, banks may permit extension of the DCCO of the
project up to two years in addition to the periods quoted at paragraph
4.2.15.3 of the circular as the case may be, without any change in asset
classification of the account subject to the conditions stipulated in the
following paragraphs. Banks may also consequentially shift/extend
repayment schedule, if required, by an equal or shorter duration.
ii. In cases where change in ownership and extension of DCCO (as indicated
in paragraph 4.2.15.5 (i) of the circular) takes place before the original
DCCO, and if the project fails to commence commercial operations by the
extended DCCO, the project will be eligible for further extension of DCCO in
terms of guidelines quoted at paragraph 4.2.15.3 of the circular. Similarly,
where change in ownership and extension of DCCO takes place during the
period quoted in paragraph 4.2.15.3 (i) of the circular, the account may still
be restructured by extension of DCCO in terms of guidelines quoted at
paragraph 4.2.15.3 (ii) of the circular, without classifying the account as
non-performing asset.
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Asset Classification, Income Recognition and Provisioning
iii. The provisions of paragraphs 4.2.15.4 (i) and 4.2.15.4 (ii) of the circular are
subject to the following conditions:
a. Banks should establish that implementation of the project is
stalled/affected primarily due to inadequacies of the current
promoters/management and with a change in ownership there is a very
high probability of commencement of commercial operations by the
project within the extended period;
b. The project in consideration should be taken-over/acquired by a new
promoter/promoter group with sufficient expertise in the field of
operation. If the acquisition is being carried out by a special purpose
vehicle (domestic or overseas), the bank should be able to clearly
demonstrate that the acquiring entity is part of a new promoter group
with sufficient expertise in the field of operation;
c. The new promoters should own at least 51 per cent of the paid up
equity capital of stake in the acquired project. If the new promoter is a
non-resident, and in sectors where the ceiling on foreign investment is
less than 51 per cent, the new promoter should own atleast 26 per cent
of the paid up equity capital or up to applicable foreign investment limit,
whichever is higher, provided banks are satisfied that with this equity
stake the new non-resident promoter controls the management of the
project;
d. Viability of the project should be established to the satisfaction of the
banks;
e. Intra-group business restructuring/mergers/acquisitions and/or
takeover/acquisition of the project by other entities/subsidiaries/
associates etc. (domestic as well as overseas), belonging to the existing
promoter/promoter group will not qualify for this facility. The banks
should clearly establish that the acquirer does not belong to the existing
promoter group;
f. Asset classification of the account as on the `reference date' would
continue during the extended period. For this purpose, the `reference
date' would be the date of execution of preliminary binding agreement
between the parties to the transaction, provided that the
acquisition/takeover of ownership as per the provisions of
law/regulations governing such acquisition/takeover is completed within
a period of 90 days from the date of execution of preliminary binding
agreement. During the intervening period, the usual asset classification
norms would continue to apply. If the change in ownership is not
completed within 90 days from the preliminary binding agreement, the
`reference date' would be the effective date of acquisition/takeover as
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Guidance Note on Audit of Banks (Revised 2019)
per the provisions of law/regulations governing such
acquisition/takeover;
g. The new owners/promoters are expected to demonstrate their
commitment by bringing in substantial portion of additional monies
required to complete the project within the extended time period. As
such, treatment of financing of cost overruns for the project shall be
subject to the guidelines prescribed in paragraph 13 of the circular.
Financing of cost overrun beyond the ceiling prescribed in paragraph 13
of the circular would be treated as an event of restructuring even if the
extension of DCCO is within the limits prescribed above;
h. While considering the extension of DCCO (up to an additional period of
2 years) for the benefits envisaged hereinabove, banks shall make sure
that the repayment schedule does not extend beyond 85 per cent of the
economic life/concession period of the project; and
i. This facility would be available to a project only once and will not be
available during subsequent change in ownership, if any.
iv. Loans covered under this guideline would attract provisioning as per the
extant provisioning norms depending upon their asset classification status.
Project Loans for Non-Infrastructure Sector
4.201
(i) A loan for a non-infrastructure project will be classified as NPA during any
time before commencement of commercial operations as per record of
recovery (90 days overdue), unless it is restructured and becomes eligible
for classification as 'standard asset' in terms of paras (iii) to (iv) below.
(ii) A loan for a non-infrastructure project will be classified as NPA if it fails to
commence commercial operations within one year from the original DCCO,
even if is regular as per record of recovery, unless it is restructured and
becomes eligible for classification as 'standard asset' in terms of paras (iii)
to (iv) below.
(iii) In case of non-infrastructure projects, if the delay in commencement of
commercial operations extends beyond the period of one year from the date
of completion as determined at the time of financial closure, banks can
prescribe a fresh DCCO, and retain the "standard" classification by
undertaking restructuring of accounts in accordance with the provisions
contained in this Master Circular, provided the fresh DCCO does not extend
beyond a period of two years from the original DCCO. This would among
others also imply that the restructuring application is received before the
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Asset Classification, Income Recognition and Provisioning
expiry of one year from the original DCCO, and when the account is still
"standard" as per the record of recovery.
The other conditions applicable would be:
a. In cases where there is moratorium for payment of interest, banks
should not book income on accrual basis beyond one year from the
original DCCO, considering the high risk involved in such restructured
accounts.
b. Banks should maintain provisions on such accounts as long as these
are classified as standard assets as under:
Particulars Provisioning Requirement
If the revised DCCO is within one 0.40 per cent
year from the original DCCO
prescribed at the time of financial
closure
If the DCCO is extended beyond one Project loans restructured with
year and upto two years from the effect from June 1, 2013:
original DCCO prescribed at the time 5.00 per cent From the date of
of financial closure restructuring for 2 years
Stock of Project loans classified
as restructured before June 01,
2013:
3.50 per cent - with effect
from March 31, 2014 (spread
over the four quarters of
2013-14)
4.25 per cent - with effect
from March 31, 2015 (spread
over the four quarters of
2014-15)
5.00 per cent - with effect
from March 31, 2016 (spread
over the four quarters of
2015-16)
The above provisions will be
applicable from the date of
restructuring for 2 years.
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Guidance Note on Audit of Banks (Revised 2019)
(iv) For this purpose, mere extension of DCCO would not be considered as
restructuring, if the revised DCCO falls within the period of two years from
the original DCCO. In such cases the consequential shift in repayment
period by equal or shorter duration (including the start date and end date of
revised repayment schedule) than the extension of DCCO would also not
be considered as restructuring provided all other terms and conditions of
the loan remain unchanged.
Other Issues
4.202
(i) All other aspects of restructuring of project loans before commencement of
commercial operations would be governed by the provisions of Part B of
Master Circular on Prudential norms on Income Recognition, Asset
Classification and Provisioning Pertaining to Advances. Restructuring of
project loans after commencement of commercial operations will also be
governed by these instructions.
(ii) Any change in the repayment schedule of a project loan caused due to an
increase in the project outlay on account of increase in scope and size of
the project, would not be treated as restructuring if:
(a) The increase in scope and size of the project takes place before
commencement of commercial operations of the existing project.
(b) The rise in cost excluding any cost-overrun in respect of the original
project is 25% or more of the original outlay.
(c) The bank re-assesses the viability of the project before approving the
enhancement of scope and fixing a fresh DCCO.
(d) On re-rating, (if already rated) the new rating is not below the previous
rating by more than one notch.
(iii) Project loans for Commercial Real Estate
CRE projects mere extension of DCCO would not be considered as
restructuring, if the revised DCCO falls within the period of one year from
the original DCCO and there is no change in other terms and conditions
except possible shift of the repayment schedule and servicing of the loan by
equal or shorter duration compared to the period by which DCCO has been
extended. However, the asset classification benefit would not be available
to CRE projects if they are restructured.
(iv) Multiple revisions of the DCCO and consequential shift in repayment
schedule for equal or shorter duration (including the start date and end date
of revised repayment schedule) will be treated as a single event of
restructuring provided that the revised DCCO is fixed within the respective
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Asset Classification, Income Recognition and Provisioning
time limits stipulated at paragraphs 4.2.15.3 (iii) and 4.2.15.4 (iii) of the
Master Circular No. RBI/2015-16/101DBR.No.BP.BC.2/21.04.048/2015-16
on Prudential norms on Income Recognition, Asset Classification and
Provisioning pertaining to Advances, dated July 1, 2015 and all other terms
and conditions of the loan remained unchanged.
(v) Banks, if deemed fit, may extend DCCO beyond the respective time limits
stipulated at paragraphs 4.2.15.3 (iii) and 4.2.15.4 (iii) of the Master Circular
No. RBI/2015-16/101 DBR.No.BP.BC.2/21.04.048/2015-16 on Prudential
norms on Income Recognition, Asset Classification and Provisioning
pertaining to Advances, dated July 1, 2015; however, in that case, banks
will not be able to retain the `standard' asset classification status of such
loan accounts.
(vi) In all the above cases of restructuring where regulatory forbearance has
been extended, the Boards of banks should satisfy themselves about the
viability of the project and the restructuring plan.
4.203
(i) The RBI vide its Circular No. RBI/2014-15/182 DBOB.
No.BP.BC.33/21.04.048/2014-15 dated August 14, 2014 on "Prudential
Norms on Income Recognition, Assets Classification and Provisioning
Pertaining to Advances Project under Implementation" mentions that
banks have represented to RBI that in respect of funding of cost overruns,
which may arise on account of extension of DCCO within the above (i.e.;
two years and one year for infrastructure and non-infrastructure projects
from original DCCO date with other terms and conditions remain
unchanged), time limits may be allowed without treating the loans as
restructured.
(ii) In cases where banks have specifically sanctioned a `standby facility' at the
time of initial financial closure to fund cost overruns, they may fund cost
overruns as per the agreed terms and conditions.
(iii) In cases Where the initial financial closure does not envisage such
financing of cost overruns, based on the representations from banks, it has
been decided to allow banks to fund cost overruns, which may arise on
account of extension of DCCO within the time limits quoted at paragraph (i)
above, without treating the loans as `restructured asset' subject to the
following conditions:
(a) Banks may fund additional `Interest during Construction', which may
arise on account of delay in completion of a project;
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Guidance Note on Audit of Banks (Revised 2019)
(b) Other cost overruns (excluding Interest during Construction) up to a
maximum of 10% of the original project cost;
(c) Debt Equity Ratio as agreed at the time of initial financial closure
should remain unchanged subsequent to funding cost overruns or
improve in favour of the lenders and the revised Debt Service
Coverage Ratio should be acceptable to the lenders;
(d) Disbursement of funds for cost overruns should start only after the
Sponsors/Promoters bring in their share of funding of the cost
overruns; and
(e) All other terms and conditions of the loan should remain unchanged or
enhanced in favour of the lenders.
Flexible structuring of Long Term Project Loans to Infrastructure and
Core Industries
4.204
(i) In view of the challenges faced by Banks, the RBI has clarified in its circular
no. DBOD.No.BP.BC.24/21.04.132/2014-15 on Flexible Structuring of Long
Term Project Loans to Infrastructure and Core Industries dated July 15,
2014, that it has no objection to banks' to fix longer amortisation period for
loans to projects in infrastructure and core industries sectors, say 25 years,
based on the economic life or concession period of the project, with periodic
refinancing, say every 5 years. For details refer to the circular.
(ii) The RBI has further clarified in its circular no. DBOD.No.BP.BC.24/
21.04.132/2014-15 Flexible Structuring of Long Term Project Loans to
Infrastructure and Core Industries dated December 15, 2014 that the
flexible structuring of existing loans will be allowed in addition to new loans
as per the norms given in the circular.
(iii) For detailed guidelines on the Flexible structuring of Long Term Project
Loans, refer para 10 and 11 of the master circular DBR.No.
BP.BC.2/21.04.048/2015-16 - Master Circular - Prudential norms on Income
Recognition, Asset Classification and Provisioning pertaining to Advances.
Income recognition
4.205
(i) Banks may recognise income on accrual basis in respect of the projects
under implementation, which are classified as `standard'.
(ii) Banks should not recognise income on accrual basis in respect of the
projects under implementation which are classified as a `substandard'
asset. Banks may recognise income in such accounts only on realisation on
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Asset Classification, Income Recognition and Provisioning
cash basis. Consequently, banks which have wrongly recognised income in
the past should reverse the interest if it was recognised as income during
the current year or make a provision for an equivalent amount if it was
recognised as income in the previous year(s). As regards the regulatory
treatment of `funded interest' recognised as income and `conversion into
equity, debentures or any other instrument' banks should adopt the
following:
a) Funded Interest: Income recognition in respect of the NPAs,
regardless of whether these are or are not subjected to restructuring/
rescheduling/ renegotiation of terms of the loan agreement, should be
done strictly on cash basis, only on realisation and not if the amount of
interest overdue has been funded. If, however, the amount of funded
interest is recognised as income, a provision for an equal amount
should also be made simultaneously. In other words, any funding of
interest in respect of NPAs, if recognised as income, should be fully
provided for.
b) Conversion into equity, debentures or any other instrument: The
amount outstanding converted into other instruments would normally
comprise principal and the interest components. If the amount of
interest dues is converted into equity or any other instrument, and
income is recognised in consequence, full provision should be made
for the amount of income so recognised to offset the effect of such
income recognition. Such provision would be in addition to the amount
of provision that may be necessary for the depreciation in the value of
the equity or other instruments, as per the investment valuation
norms. However, if the conversion of interest is into equity which is
quoted, interest income can be recognised at market value of equity,
as on the date of conversion, not exceeding the amount of interest
converted to equity. Such equity must thereafter be classified in the
"available for sale" category and valued at lower of cost or market
value. In case of conversion of principal and /or interest in respect of
NPAs into debentures, such debentures should be treated as NPA, ab
initio, in the same asset classification as was applicable to loan just
before conversion and provision made as per norms. This norm would
also apply to zero coupon bonds or other instruments which seek to
defer the liability of the issuer. On such debentures, income should be
recognised only on realization basis. The income in respect of
unrealised interest which is converted into debentures or any other
fixed maturity instrument should be recognized only on redemption of
such instrument. Subject to the above, the equity shares or other
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Guidance Note on Audit of Banks (Revised 2019)
instruments arising from conversion of the principal amount of loan
would also be subject to the usual prudential valuation norms as
applicable to such instruments.
Provisioning norms on restructured advances
Normal provisions
4.206
(i) Banks will hold provision against the restructured advances as per the extant
provisioning norms.
(ii) Restructured accounts classified as standard advances will attract a higher
provision (as prescribed from time to time) in the first two years from the
date of restructuring. In cases of moratorium on payment of interest/principal
after restructuring, such advances will attract the prescribed higher provision
for the period covering moratorium and two years thereafter.
(iii) Restructured accounts classified as non-performing advances, when
upgraded to standard category will attract a higher provision (as prescribed
from time to time) in the first year from the date of upgradation.
(iv) The above-mentioned higher provision on restructured standard advances
(2.75 per cent as prescribed vide circular dated November 26, 2012) would
increase to 5 per cent in respect of new restructured standard accounts
(flow) with effect from June 1, 2013 and increase to 5% by FY: 2015-16 in a
phased manner for the stock of restructured standard accounts as on May
31, 2013.
Provision for diminution in the fair value of restructured advances-
4.207
(i) Reduction in the rate of interest and/or reschedulement of the repayment of
principal amount, as part of the restructuring, will result in diminution in the
fair value of the advance. Such diminution in value is an economic loss for
the bank and will have impact on the bank's market value of equity. It is,
therefore, necessary for banks to measure such diminution in the fair value
of the advance and make provisions for it by debit to Profit & Loss Account.
Such provision should be held in addition to the provisions as per existing
provisioning norms and in an account distinct from that for normal
provisions.
For this purpose, the erosion in the fair value of the advance should be
computed as the difference between the fair value of the loan before and
after restructuring. Fair value of the loan before restructuring will be
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Asset Classification, Income Recognition and Provisioning
computed as the present value of cash flows representing the interest at the
existing rate charged on the advance before restructuring and the principal,
discounted at a rate equal to the bank's BPLR or Base Rate11 (whichever is
applicable to the borrower) as on the date of restructuring plus the
appropriate term premium and credit risk premium for the borrower
category on the date of restructuring. Fair value of the loan after
restructuring will be computed as the present value of cash flows
representing the interest at the rate charged on the advance on
restructuring and the principal, discounted at a rate equal to the bank's
BPLR or base rate (whichever is applicable to the borrower) as on the date
of restructuring plus the appropriate term premium and credit risk premium
for the borrower category on the date of restructuring.
The above formula moderates the swing in the diminution of present value
of loans with the interest rate cycle and will have to be followed consistently
by banks in future. Further, it is reiterated that the provisions required as
above arise due to the action of the banks resulting in change in contractual
terms of the loan upon restructuring which are in the nature of financial
concessions. These provisions are distinct from the provisions which are
linked to the asset classification of the account classified as NPA and reflect
the impairment due to deterioration in the credit quality of the loan. Thus,
the two types of the provisions are not substitute for each other.
ii) There could be divergences in the calculation of diminution of fair value of
accounts by banks. For example, divergences could occur if banks do not
appropriately factor in the term premium on account of elongation of
repayment period on restructuring. In such a case the term premium used
while calculating the present value of cash flows after restructuring would
be higher than the term premium used while calculating the present value of
cash flows before restructuring.
Further, the amount of principal converted into debt/equity instruments on
restructuring would need to be held under AFS and valued as per usual
valuation norms. Since these instruments are getting marked to market, the
erosion in fair value gets captured on such valuation. Therefore, for the
purpose of arriving at the erosion in the fair value, the NPV calculation of
the portion of principal not converted into debt/equity has to be carried out
separately. However, the total sacrifice involved for the bank would be NPV
of the above portion plus valuation loss on account of conversion into
debt/equity instruments.
11 This change has been introduced as a result of the introduction of Base Rate System w.e.f. July
1, 2010 vide circular DBOD.No.Dir.BC.88/13.03.00/2009-10 dated April 9, 2010 on `Guidelines on
the Base Rate'.
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Guidance Note on Audit of Banks (Revised 2019)
Auditor should therefore verify that Bank has correctly captured diminution
in fair value of restructured accounts as it will have a bearing not only on
the provisioning required to be made by them but also on the amount of
sacrifice required from the promoters.
Auditors should also verify that there is no any effort on the part of banks to
artificially reduce the net present value of cash flows by resorting to any sort
of financial engineering. Auditor should also verify that there is a proper
mechanism in place of checks and balances to ensure accurate calculation
of erosion in the fair value of restructured accounts.
4.208 In the case of working capital facilities, the diminution in the fair value of
the cash credit / overdraft component may be computed as indicated in para
4.207(i) above, reckoning the higher of the outstanding amount or the limit
sanctioned as the principal amount and taking the tenor of the advance as one
year. The term premium in the discount factor would be as applicable for one
year. The fair value of the term loan components (Working Capital Term Loan
and Funded Interest Term Loan) would be computed as per actual cash flows
and taking the term premium in the discount factor as applicable for the maturity
of the respective term loan components.
4.209 In the event any security is taken in lieu of the diminution in the fair
value of the advance, it should be valued at Re.1/- till maturity of the security.
This will ensure that the effect of charging off the economic sacrifice to the Profit
& Loss account is not negated.
4.210 The diminution in the fair value may be re-computed on each balance
sheet date till satisfactory completion of all repayment obligations and full
repayment of the outstanding in the account, so as to capture the changes in the
fair value on account of changes in BPLR or base rate (whichever is applicable to
the borrower), term premium and the credit category of the borrower.
Consequently, banks may provide for the shortfall in provision or reverse the
amount of excess provision held in the distinct account.
4.211 If due to lack of expertise / appropriate infrastructure, a bank finds it
difficult to ensure computation of diminution in the fair value of advances, as an
alternative to the methodology prescribed above for computing the amount of
diminution in the fair value, the banks has the option of notionally computing the
amount of diminution in the fair value and providing therefor, at five percent of the
total exposure, in respect of all restructured accounts where the total dues to
bank(s) are less than rupees one crore.
4.212 The total provisions required against an account (normal provisions plus
provisions in lieu of diminution in the fair value of the advance) are capped at
100% of the outstanding debt amount.
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Asset Classification, Income Recognition and Provisioning
Risk-Weights
4.213 The RBI circular also provides that:
a. Restructured housing loans should be risk weighted with an additional risk
weight of 25 percentage points.
b. With a view to reflecting a higher element of inherent risk which may be
latent in entities whose obligations have been subjected to restructuring /
rescheduling either by banks on their own or along with other bankers /
creditors, the unrated standard / performing claims on corporates should be
assigned a higher risk weight of 125% until satisfactory performance under
the revised payment schedule has been established for one year from the
date when the first payment of interest / principal falls due under the revised
schedule.
c. For details on risk weights, Master Circular RBI/2015-16/58
DBR.No.BP.BC.1/21.06.201/2015-16 dated July 1, 2015 on `Basel III Capital
Regulations' may be referred.
Prudential Norms for Conversion of Principal into Debt / Equity
Asset classification norms
4.214 A part of the outstanding, principal amount can be converted into debt
or equity instruments as part of restructuring. The debt / equity instruments so
created will be classified in the same asset classification category in which the
restructured advance has been classified. Further movement in the asset
classification of these instruments would also be determined based on the
subsequent asset classification of the restructured advance.
Income recognition norms
Standard Accounts
4.215 In the case of restructured accounts classified as 'standard', the income,
if any, generated by these instruments may be recognised on accrual basis.
Non- Performing Accounts
4.216 In the case of restructured accounts classified as non-performing
assets, the income, if any, generated by these instruments may be recognised
only on cash basis.
Valuation and provisioning norms
4.217 These instruments should be held under AFS and valued as per usual
valuation norms. Equity classified as standard asset should be valued either at
market value, if quoted, or at break-up value, if not quoted (without considering
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Guidance Note on Audit of Banks (Revised 2019)
the revaluation reserve, if any) which is to be ascertained from the company's
latest balance sheet. In case the latest balance sheet is not available, the shares
are to be valued at Re. 1. Equity instrument classified as NPA should be valued
at market value, if quoted, and in case where equity is not quoted, it should be
valued at Re. 1. Depreciation on these instruments should not be offset against
the appreciation in any other securities held under the AFS category.
Prudential Norms for Conversion of Unpaid Interest into 'Funded
Interest Term Loan' (FITL), Debt or Equity Instruments
Asset classification norms
4.218 The FITL / debt or equity instrument created by conversion of unpaid
interest will be classified in the same asset classification category in which the
restructured advance has been classified. Further movement in the asset
classification of FITL / debt or equity instruments would also be determined
based on the subsequent asset classification of the restructured advance.
Income recognition norms
4.219 The income, if any, generated by these instruments may be recognised
on accrual basis, if these instruments are classified as 'standard', and on cash
basis in the cases where these have been classified as a non-performing asset.
4.220 The unrealised income represented by FITL / Debt or equity instrument
should have a corresponding credit in an account styled as "Sundry Liabilities
Account (Interest Capitalization)".
4.221 In the case of conversion of unrealised interest income into equity,
which is quoted, interest income can be recognized after the account is upgraded
to standard category at market value of equity, on the date of such upgradation,
not exceeding the amount of interest converted into equity.
4.222 Only on repayment in case of FITL or sale / redemption proceeds of the
debt / equity instruments, the amount received will be recognized in the P&L
Account, while simultaneously reducing the balance in the "Sundry Liabilities
Account (Interest Capitalisation)".
Valuation & Provisioning norms
4.223 Valuation and provisioning norms would be as per para 4.217 above.
The depreciation, if any, on valuation may be charged to the Sundry Liabilities
(Interest Capitalisation) Account.
Special Regulatory Treatment for Asset Classification
4.224 The special regulatory treatment for asset classification, in modification
to the provisions in this regard stipulated in para 18 of the Master Circular No.
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Asset Classification, Income Recognition and Provisioning
RBI/2015-16/101 DBR.No.BP.BC.2/21.04.048/2015-16 on Prudential norms on
Income Recognition, Asset Classification and Provisioning pertaining to
Advances, dated July 1, 2015, will be available to the borrowers engaged in
important business activities, subject to compliance with certain conditions as
enumerated in para 20.2 of the above mentioned master circular. Such treatment
is not extended to the following categories of advances:
i. Consumer and personal advances;
ii. Advances classified as Capital market exposures;
iii. Advances classified as commercial real estate exposures.
The asset classification of these three categories accounts as well as that of
other accounts which do not comply with the conditions enumerated in para 20.2
of the aforesaid Master Circular, are governed by the prudential norms in this
regard described in para 17 of the Master Circular.
Elements of special regulatory framework
4.225 The special regulatory treatment has the following two components:
(i) Incentive for quick implementation of the restructuring package.
(ii) Retention of the asset classification of the restructured account in the pre-
restructuring asset classification category.
Incentive for quick implementation of the restructuring package
4.226 During the pendency of the application for restructuring of the advance
with the bank, the usual asset classification norms would continue to apply. The
process of reclassification of an asset should not stop merely because the
application is under consideration. However, as an incentive for quick
implementation of the package, if the approved package is implemented by the
bank as per the following time schedule, the asset classification status may be
restored to the position which existed when the reference was made to the CDR
Cell in respect of cases covered under the CDR Mechanism or when the
restructuring application was received by the bank in non-CDR cases:
(i) Within 120 days from the date of approval under the CDR Mechanism.
(ii) Within 120 days from the date of receipt of application by the bank in cases
other than those restructured under the CDR Mechanism.
Asset classification benefits
4.227 Subject to the compliance with the undernoted conditions in addition to
the adherence to the prudential framework laid down in para 17 of the Master
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Guidance Note on Audit of Banks (Revised 2019)
Circular DBR.No.BP.BC.2/21.04.048/2015-16 on Prudential norms on Income
Recognition, Asset Classification and Provisioning pertaining to Advances dated
July 1, 2015:
(i) In modification to para 17.2.1 of aforesaid Master Circular, an existing
'standard asset' will not be downgraded to the sub-standard category upon
restructuring.
(ii) In modification to para 17.2.2 of aforesaid Master Circular, during the
specified period, the asset classification of the sub-standard / doubtful
accounts will not deteriorate upon restructuring, if satisfactory performance
is demonstrated during the specified period.
4.228 However, these benefits will be available subject to compliance with the
following conditions:
i) The dues to the bank are 'fully secured' as defined in Annex 5 of the
Master Circular on Prudential Norms on Income Recognition, Asset
Classification and Provisioning pertaining to Advances dated July 1, 2015.
The condition of being fully secured by tangible security will not be
applicable in the following cases:
(a) MSE borrowers, where the outstanding is up to Rs. 25 lakh.
(b) Infrastructure projects, provided the cash flows generated from these
projects are adequate for repayment of the advance, the financing
bank(s) have in place an appropriate mechanism to escrow the cash
flows, and also have a clear and legal first claim on these cash flows.
ii) The unit becomes viable in 8 years, if it is engaged in infrastructure
activities, and in 5 years in the case of other units.
iii) The repayment period of the restructured advance including the moratorium,
if any, does not exceed 15 years in the case of infrastructure advances and
10 years in the case of other advances. The aforesaid ceiling of 10 years
would not be applicable for restructured home loans; in these cases the
Board of Directors of the banks should prescribe the maximum period for
restructured advance keeping in view the safety and soundness of the
advances.
iv) Promoters' sacrifice and additional funds brought by them should be a
minimum of 20 per cent of banks' sacrifice or 2 per cent of the restructured
debt, whichever is higher. This stipulation is the minimum and banks may
decide on a higher sacrifice by promoters depending on the riskiness of the
project and promoters' ability to bring in higher sacrifice amount. Further,
such higher sacrifice may invariably be insisted upon in larger accounts,
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Asset Classification, Income Recognition and Provisioning
especially CDR accounts. The promoters' sacrifice should invariably be
brought upfront while extending the restructuring benefits to the borrowers.
The term 'bank's sacrifice' means the amount of 'erosion in the fair value of
the advance'; or "total sacrifice", to be computed as per the methodology
enumerated in para 4.207(i) and (ii) above.
(Prior to May 30, 2013, if banks were convinced that the promoters face
genuine difficulty in bringing their share of the sacrifice immediately and
need some extension of time to fulfill their commitments, the promoters
could be allowed to bring in 50% of their sacrifice, i.e. 50% of 15%, upfront
and the balance within a period of one year. However, in such cases, if the
promoters fail to bring in their balance share of sacrifice within the extended
time limit of one year, the asset classification benefits derived by banks will
cease to accrue and the banks will have to revert to classifying such
accounts as per the asset classification norms as given in para 17.2 of
aforesaid Master Circular.
v) Promoter's contribution need not necessarily be brought in cash and can be
brought in the form of de-rating of equity, conversion of unsecured loan
brought by the promoter into equity and interest free loans.
vi) The restructuring under consideration is not a 'repeated restructuring' as
defined in para (v) of Annex - 5 of the Master Circular on Prudential Norms
on Income Recognition, Asset Classification and Provisioning pertaining to
Advances dated July 1, 2015.
4.229 As per para 20.2.3 of the Master Circular dated July 1, 2015 the extant
incentive for quick implementation of restructuring package and asset
classification benefits (paragraphs 4.226 to 4.228 (available on restructuring on
fulfilling the conditions will however be withdrawn for all restructurings effective
from April 1, 2015 with the exception of provisions related to changes in DCCO in
respect of infrastructure as well as non-infrastructure project loans. It implies that
with effect from April 1, 2015, a standard account on restructuring (for reasons
other than change in DCCO and) would be immediately classified as sub-
standard on restructuring as also the non-performing assets, upon restructuring,
would continue to have the same asset classification as prior to restructuring and
slip into further lower asset classification categories as per the extant asset
classification norms with reference to the pre-restructuring repayment schedule.
4.230 Accelerated Provisioning
In cases where banks fail to report SMA status to the accounts to CRILIC or
resort to methods with the intent to conceal the actual status of the accounts or
evergreen the accounts, banks will be subjected to accelerated provisioning for
these accounts as under:
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Guidance Note on Audit of Banks (Revised 2019)
Asset Period as NPA Current Revised
Classification Provisioning accelerated
provisioning (%)
Sub Standard Upto 6 months 15 15 (no change)
(Secured) 6 months to 1 year 15 25
Sub Standard Upto 6 months 25(other than 25
(unsecured ab infrastructure
initio) loans)
20 (infrastructure
loans)
6 months to 1 year Same as above 40
Doubtful I 2nd year 25(secured 40
portion)
100(unsecured 100
portion)
Doubtful II 3rd & 4th year 40(secured 100 for both
portion) secured and
100 (unsecured unsecured portion
portion)
Doubtful III 5 year onwards 100 100
The auditor should check bank's process to identify SMA accounts and reporting
of same. If report is generated from system, parameters considered for
identification of SMA accounts and system controls to be checked.
Integration of SMA identification system with Core banking system to be checked
and to ensure that there is no manual intervention which may result in intentional
concealment of data.
Relevant access controls and modification rights in system need to be checked.
4.231 The accelerated provisioning requirement as above is not only for non-
reporting or delayed reporting or wrong reporting of SMA status bit also for
delay/refusal in implementation of package already agreed by lender under CAP
by JLF.
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PART - IV
IV-1
Cash, Balances with RBI and
Other Banks, and Money at
Call and Short Notice
1.01 Cash, Balances with RBI and Other Banks, and Money at Call and
Short Notice constitutes one of the important items of balance sheet of a bank.
Of these items, only a few select branches in each bank handle the
transactions relating to money at call and short notice.
Balance Sheet Disclosure
1.02 The Third Schedule to the Banking Regulation Act, 1949, requires the
following disclosures to be made in the Schedule 6 & Schedule 7 of balance
sheet regarding cash, balances with RBI, balances with other banks, and
money at call and short notice.
Cash and Balances with Reserve Bank of India-Schedule 6
I. Cash in hand (including foreign currency notes)
II. Balance with Reserve Bank of India
(i) in Current Account
(ii) in Other Accounts
Balances with Banks and Money at Call and Short Notice-Schedule 7
I. In India
(i) Balances with other banks
(a) in Current Accounts
(b) in Other Deposit Accounts
(ii) Money at call and short notice
(a) with banks
(b) with other institutions
II. Outside India
(i) in Current Accounts
(ii) in Other Deposit Accounts
(iii) Money at call and short notice
Guidance Note on Audit of Banks (Revised 2019)
Balances with Reserve Bank of India, Balances with Other Banks
1.03 Banks maintain accounts with RBI and other Banks for Banking
Operations however only select branches maintain account with RBI. The
branches also maintain accounts with other banks for banking operations.
Money at Call and Short Notice
1.04 Money at call and short notice represents short-term investment of
surplus funds in the money market. Money lent for one day is money at `call' or
`call money' means deals in overnight funds, while money lent for a period of
more than one day and up to fourteen days is money at `short notice'. The lender
bank does not get any security for money lent at call or short notice. The
participants of call and notice money market are scheduled commercial banks
(excluding RRBs), co-operative banks (other than land development banks) and
primary dealers (PDs), both as borrowers and lenders. Non-bank institutions
(other than PDs) are not permitted to participate in call/notice money market.
Scheduled commercial banks usually borrow from this market to meet the
requirements relating to cash reserve ratio or statutory liquidity ratio. The
decisions to borrow from, or lend in, the market are taken usually at the head
office level and communicated to select branches for effecting the
borrowing/lending.
1.05 RBI vide its Master Direction no. RBI/FMRD/2016-17/32 FMRD. Master
Direction No. 2/2016-17 dated July 7, 2016 on "Money Market Instruments: Call/
Notice Money Market, Commercial Paper, Certificates of Deposit and Non-
Convertible Debentures (original maturity up to one year)" provides the detailed
guidelines on the prudential limits in respect of both outstanding and lending
transactions in call/notice money market for scheduled commercial banks, co-
operative banks and PDs. The eligible participants are free to decide the interest
rates in call/notice money market. Computation of interest payable would be
based on the methodology given in handbook of market practices brought out by
the Fixed Income Money Market and Derivates Association of India (FIMMDA)
and the eligible participants may adopt the documentation suggested by
FIMMDA from time to time. The Call/Notice Money transactions can be executed
either on NDS-Call, a screenbased, negotiated, quote-driven electronic trading
system managed by the Clearing Corporation of India (CCIL), or over the counter
(OTC) through bilateral communication. NDS-Call (a screenbased, negotiated,
quote-driven system), do not require separate reporting, however, it is mandatory
that all OTC deals should be reported within 15 minutes on NDS-Call reporting
platform irrespective of the size of the deal.
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Cash, Balances with Others, Money at Call and Short Notice
Audit Approach and Procedures
Cash
1.06 The auditor should carry out verification of the balance of cash on
hand. As far as possible, the auditor should visit the branch at the close of
business on the last working day of the year or before the commencement of
business on the next day for carrying out the physical verification of cash. If, for
any reason, the auditor is unable to do so, he should carry out the physical
verification of cash as close to the balance sheet date as possible, at the time
of audit and also reconcile with the cash register/balance in CBS. In few banks,
the branch deposits a large portion of its cash balance with the RBI or the State
Bank of India or any other bank on the closing day, in such cases, the auditor
must request the branch to provide sufficient appropriate evidence for the
same and also ensure that the same is effected in books of accounts and is not
appearing as a bank reconciliation item.
1.07 Care should be taken to ensure that if cash is kept separately in
different departments or at different locations (e.g., at extension counters,
onsite ATMs linked with the branch, all the balances are verified by the auditor
simultaneously. The auditor should also ensure that there is no movement of
cash till such cash is physically verified.
1.08 The auditor should evaluate the effectiveness of the system of internal
controls in branch regarding daily verification of cash, maintenance of cash
balance registers and vault register, custody of cash, custody of vault keys,
daily cash holding and retention limit of the branch, etc. The auditor should
examine/inquire whether there is a global (insurance) policy taken for safety of
cash from theft or burglary and such policy is effective as on reporting date.
This would be relevant for a bank as a whole and there would not be any
insurance policy available at the branch level, however, the branch auditor
should seek a Xerox copy of the same from the Head office or confirmation
from the head office seeking details of the insurance coverage of the branch.
The Statutory Auditor should also make an analysis of the quantum of cash
holding and whether the insurance cover is adequate. This will also be
important from the perspective of reporting in Long Form Audit Report (LFAR)
under (I) Assets-Cash.
1.09 For physically verifying the cash-on-hand, the auditor may proceed as
below:
(a) Physically verify the cash-on-hand available at the branch. The extent of
verification would depend upon the auditor's assessment of the efficacy of
internal control system including adherence to cash retention limits fixed
by the head office, mode of custody of cash (whether single or joint) and
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Guidance Note on Audit of Banks (Revised 2019)
frequency of cash verification by branch officials and/or by internal or
concurrent auditors. Normally, in a bank, 100 notes of each denomination
and thereafter 10 packets of 100 notes each are bundled together.
Wherever sample checking is conducted, it is advisable that number of
bundles of 100's is fully counted. Besides, the number of notes in samples
of bundles of old notes of different denominations may also be checked,
the sample size for larger denomination notes being higher than that in
the case of smaller denomination notes. The number of notes in a small
sample of bundle of new notes of larger denominations (say, Rs. 100 or
more) may also be counted. In any event, care should be taken to ensure
that all bundles produced for audit verification are properly sealed.
Loose/soiled notes should be counted in full. Coins may be counted, or
weighed and converted into monetary value as per RBI guidelines. The
processed and unprocessed notes should be separately kept and the
denomination of the same should be separately mentioned in the cash
balance register.
(b) Obtain a certificate from the bank indicating denomination-wise cash
balance as on the date of verification.
1.10 Notes/coins in sealed packets may be accepted based on a written
representation from the branch management and cross-checked with
subsequent entries in the books of account.
1.11 The cash balance as physically verified should be agreed with the
balance shown in the cash book and the books of account. When the physical
verification of cash is carried out by the auditor before or after the date of the
balance sheet, the auditor should perform the additional audit procedure to
reconcile the results of verification with the cash balance as at the balance
sheet date.
1.12 Foreign currency notes should also be verified at the time of physical
verification of cash. The auditor should also ensure that these notes are
converted at the market rate prevailing on the closing day as notified by the
Foreign Exchange Dealers' Association of India (FEDAI) in accordance with the
accounting policy followed by the bank.
1.13 Special care needs to be exercised in cases where the branch
operates currency chest and/or small coin deposits. In respect of currency
chest operations, the branch merely acts as an agent of the RBI to facilitate the
distribution of bank notes and rupee coins. The balance in currency chest at
any point of time is the property of the RBI and not of the bank. Therefore,
while the auditor may not physically count the balance in currency chest on
closing day, but should take sufficient safeguards to ensure that currency chest
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Cash, Balances with Others, Money at Call and Short Notice
balance is not mixed up in the cash balances produced for physical verification.
Also, it should be recognised that the bank may be contingently liable for any
shortfall in the currency chest balance. Accordingly, the branch auditor should
pay special attention to the system of operation of currency chest transactions,
recording of such transactions, method and frequency of counting of cash, and
reconciliation with the link office. The auditor should perform compliance tests
to evaluate the effectiveness of the system of operation of currency chest. The
auditor should also examine whether the system is such that the transactions
relating to deposits into and withdrawals from, currency chest are recorded
appropriately. In case the relevant transactions are required to be
communicated to a link office of the bank (which maintains the account of RBI)
for the purpose of reporting the same to the RBI, the auditor should evaluate
the effectiveness of the system of reporting in terms of timeliness and
accuracy.
1.14 In terms of the Master Direction No RBI/DCM/2018-19/62 Master
Direction DCM(CC) No.G - 5/03.35.01/2018-19 dated July 03, 2018 on "Levy of
Penal Interest for Delayed Reporting/Wrong Reporting/Non-Reporting of
Currency Chest Transactions and Inclusion of Ineligible Amounts in Currency
Chest Balances" the banks are required to report the minimum amount of
deposit into/withdrawal from currency chest of Rs.1,00,000/- and thereafter, in
multiples of Rs. 50,000/-. Further, the banks are obliged to follow the
instructions regarding timely reporting of currency chest transactions by the
banks for branches to which currency chests are attached; and non-compliance
of the RBI instructions invite levy of penal interest for delayed reporting/wrong
reporting/non-reporting of Currency Chest transactions and penal measures for
cases involving shortages/inclusion of counterfeit bank notes in chest
balances/ chest remittances.
1.15 All currency chest transactions (deposits into /withdrawals from
currency chest) at the respective branch must be reported through ICCOMS on
the same day by 9 PM [by uploading data through the Secured Website (SWS)]
to the link office to which the branch is attached for this purpose. Each link
office must, in turn, report to the RBI Issue Office concerned, latest by 11 PM
on the same day, the consolidated net position for all the linked branches;
except in certain exceptional circumstances, like during strike period and on
account of genuine difficulties faced by chests especially in hilly/remote areas
and other chests affected by natural calamities, etc., where the default may be
acceptable to the RBI, at its discretion. However, in case of wrong reporting
representations for waiver will not be considered.
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Guidance Note on Audit of Banks (Revised 2019)
1.16 The said directions cover:
(a) Levy of penal interest for delays.
(b) Wrong reporting and levy of penal interest.
(c) Maximum penal interest to be charged.
(d) Penal interest for inclusion of ineligible amounts in the currency chest
balances.
(e) Rate of penal interest (to be levied at the rate of 2% over the prevailing
bank rate for the period of delayed reporting/wrong reporting/non-reporting
/inclusion of ineligible amounts in chest balances).
(f) Levy of penal interest in respect of currency chests at treasuries.
1.17 The operation of currency chests attached to the various branches of
the bank, affects the balances in accounts of RBI maintained by the bank at the
designated branches; and it is imperative that the transactions on value date
basis are recorded (as it affects the cash balance and that with RBI, on the day
of the cash withdrawal from or deposit into the currency chest). Designated
branches that maintain the RBI account should pass the entries on the day of
the transaction for currency chest attached to it; and as the Link Office for other
branches operating currency chests, based on inward communication from
such other branches linked to it.
1.18 Due to any delays in communication by such branches to the Link
Office, the amount required to be debited or credited to RBI Account, remains
in a nominal account (Inter branch Adjustments) and affects the RBI account
balance in the books of the Link Office. On line communication system should
remedy this to ensure recording of entries at the designated Link Office,
simultaneously as they take place at all currency chest branches.
1.19 The auditor should examine whether the account of the RBI at the
designated branch maintaining the RBI Account has incorporated all the
currency chest transactions on a value date basis as at the year end. He
should also enquire as to whether the bank has received any communication
from RBI regarding any defaults in the operation of the currency chests, that
may have penal consequences and whether during the year, any penalties
have been levied on this account.
1.20 RBI Master Circular No. RBI/2018-19/3DCM (NE) No.G-
2/08.07.18/2018-19dated July 02, 2018 on "Facility for Exchange of Notes and
Coins" requires that all designated bank branches should display at their branch
premises, at a prominent place, a board indicating the availability of note
exchange facility with the legend, "Soiled/Mutilated notes are Accepted And
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Cash, Balances with Others, Money at Call and Short Notice
Exchanged Here". Banks should ensure that all their designated branches
provide facilities for exchange of notes and coins. The branches should ensure
that the note exchange facility is not cornered by private money changers /
professional dealers in defective notes. The auditor should also inquire about the
service charges levied by the bank on Exchange of soiled notes as per RBI
Notification No.RBI/2016-17/15 DCM (NE) No.120/08.07.18/2016-17 dated July
14, 2016 to identify the revenue leakage in the bank.
1.21 The auditor should verify that the banks have not stapled the notes.
Some banks in spite of RBI's instructions continue to follow the practice of
stapling of note packets. This practice, apart from damaging notes, reduces the
life span of notes and renders it difficult for customers to open note packets
easily. Banks should do away with stapling of any note packets and instead
secure them with paper bands. Further, RBI has issued, Master Circular No.
RBI/2018-19/04DCM(FNVD)G 1/16.01.05/2018-19 dated July 02, 2018 on
"Detection and Impounding of Counterfeit Notes" which provides operational
guidance on detection and impounding of Counterfeit notes. The Government of
India has framed Investigation of High Quality Counterfeit Indian Currency
Offences Rules, 2013 under Unlawful Activities (Prevention) Act (UAPA), 1967.
The Third Schedule of the Act defines High Quality Counterfeit Indian Currency
Note. Activity of production, smuggling distribution and circulation of High Quality
Counterfeit Notes has been brought under the ambit of UAPA, 1967.
1.22 Increasingly banks are entering into an agreement with third party
vendors for management of their ATM operations. These vendors collect amount
from banks and are responsible for loading amount in the ATM. They are also
responsible for collecting amount (deposited by customers) from ATM and
depositing it with bank. The auditor should verify an agreement entered with
these vendors. The auditors should also understand the process of providing,
collecting and reconciliation etc. with these vendors and test controls in the
process.
At each period end, the auditor should send independent balance confirmation to
these vendors about balance held by them and should verify reconciliation
statements.
1.23 Also in respect of ATM operations, banks are centralizing the process of
monitoring ATM balance. This division monitors balance as per the books and
balance as per ATM machine (commonly termed as Switch balance) and their
reconciliation and ensuring timely adjustment of reconciling entries. The auditor
should understand the process of monitoring of balance, reconciliation etc. and
based on the risk assessment should understand controls in the process and
strategy of testing these controls.
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Guidance Note on Audit of Banks (Revised 2019)
1.24 Where ATMs are operated by bank themselves, auditor should verify
the cash at ATMs also and tally the same with books of accounts. At each
reporting period end, the auditor should obtain the reconciliation statement and
should verify the reconciliation statement.
1.25 in case of RRB each branch should maintain a set of marked notes
consisting of new currency notes of various denominations. The numbers of such
notes along with their prefixes and suffixes, if any, should be recorded on the last
page of the Cash Summary Register under the initials of both the custodians of
cash. During business hours, the set of marked notes should remain permanently
in the cash at the counter. This will help the investigating agencies in the event of
thefts burglary, robbery and dacoity.
Balance With RBI
1.26 In a bank, only a few select branches are designated to have accounts
(Deposit/Current) with the RBI, the main account generally being with the
Treasury Branch. The procedures of confirmation/reconciliation are not
different as compared to accounts and balances with other banks.
1.27 It is relevant to point out that, amongst others, currency chest
operations involve entries in the accounts maintained with RBI. Where currency
chest is attached to the branch maintaining RBI account, all deposits into and
withdrawals from the currency chest trigger a debit /credit to the account
maintained at the Branch itself. Other branches of the bank having currency
chests but not maintaining the RBI Account would be linked to such Branch and
would be required to transmit information forthwith for all deposits into/withdrawal
from the attached currency chest through Inter branch mechanism. The effect of
such entries is required to be considered in the RBI account on a value date
basis.
1.28 The auditor of the Branch maintaining the RBI account should follow
direct confirmation procedures of the balances in the RBI account and examine
the reconciliation to ensure that all transactions originating in the account
statement of the RBI are duly responded on value date basis.
1.29 The auditor should enquire into the reasons/justification for the following
items appearing in the reconciliation statements:
(i) cash transactions remaining unresponded;
(ii) revenue items requiring adjustments/write-offs; and
(iii) old outstanding balances remaining unexplained/ unadjusted for significant
period.
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Cash, Balances with Others, Money at Call and Short Notice
Balance with Banks (Other than Reserve Bank of India)
1.30 The auditor should also apply the procedures described in paragraphs
above in examining the balances with banks other than RBI. While reviewing
the reconciliation statements, the auditor should pay particular attention to the
following:
(a) Examine that no debit for charges or credit for interest is outstanding and
all the items which ought to have been taken to books of accounts for the
year have been considered. This should be particularly observed when
the bills collected, etc., are credited with net amount and entries for
commission, etc., are not made separately in the statement of account.
(b) Examine that no cheque sent or received in clearing is outstanding. As
per the practice prevalent among banks, any cheques returned unpaid are
accounted for on the same day on which they were sent in clearing or on
the following day.
(c) Examine that all bills or outstanding cheques sent for collection and
outstanding as on the closing date have been credited subsequently.
1.31 The auditor should also examine the large transactions in inter-bank
accounts, particularly towards the year-end, to ensure that no transactions
have been put through for window-dressing.
1.32 In respect of balances in deposit accounts, original deposit receipts
should be examined in addition to confirmation certificates obtained from banks
in respect of outstanding deposits. Balances in deposit accounts are usually
(though not necessarily) in round figures. Where such balances are in odd
figures, the auditor should enquire whether the account concerned is actually
of the nature of a deposit account. The auditor should also ensure that interest
on such deposits have been recorded on time proportion basis and interest
have been recorded till the closing day.
1.33 The balances with banks outside India should also be verified in the
manner described above. These balances should be converted into the Indian
currency at the exchange rates prevailing on the balance sheet date.
1.34 Increasingly banks are automating the process of reconciliation with
other banks. In case of system process, the auditor should understand the
system, system controls and manual controls. The auditor should also assess
the system access control and program change controls of the reconciliation
system. (Also refer chapter 3, Special Considerations in a CIS Environment of
Part II of Guidance Note).
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Guidance Note on Audit of Banks (Revised 2019)
Money at Call and Short Notice
1.35 The auditor needs to enquire whether the bank has an approved risk
policy of lending money at call or short notice and the same has been adhered
before lending money at call or short notice. This would be more relevant at the
head office rather than at the branch level.
1.36 The auditor should examine whether there is proper authorisation,
general or specific, for lending of the money at call or short notice. Compliance
with the instructions or guidelines laid down in this behalf by the head office or
controlling office of the branch, including the limits on lending in inter-bank call
money market, should also be examined.
1.37 Call loans should be verified with the certificates of the borrowers and
the call loan receipts held by the bank. The auditor should examine whether
the aggregate balances comprising this item as shown in the relevant
register/account tally with the control accounts as per the general ledger. The
auditor should also examine subsequent repayments received from borrowing
banks to verify the amounts shown under this head as at the year-end. It may
be noted that call loans made by a bank cannot be netted-off against call loans
received.
1.38 Like deposits with banks, money at call and short notice are also
usually (though not necessarily) in round figures. Any odd balances should,
therefore, put the auditor to enquiry.
1.39 The auditor should also verify that borrowing or lending for more than
14 days are not classified under this head, but are classified as `deposits' or
`advances', depending on the nature of lending and the parties to whom the
moneys have been lent.
1.40 The auditor needs to verify monies at call to banks, whether they are
fresh or roll over of the old transactions and ascertain whether any provision or
write off is required.
1.41 It may be noted that as per the directions of the RBI, banks cannot
pay any brokerage on deposit and call loans, except to the extent specified in
paragraph 8(e) of the RBI circular dated July 22, 1971.
1.42 The auditor should examine whether interest has been properly
accrued and accounted for on year-end outstanding balances of money at call
and short notice by confirming the same from the opposite party.
268
IV-2
Fixed Assets and Other
Assets
Fixed Assets
2.01 Fixed assets comprise premises and other fixed assets such as
furniture and fixtures, motor vehicles, office equipment, computers, intangible
assets such as application software and other computer software, etc.
2.02 In the case of most banks, fixed assets can be purchased by the head
office, regional/zonal offices and branches up to the monetary ceiling specified
(though purchase of land and buildings is usually centralised) for themselves as
also for offices within their control. However, banks generally prefer to centralise
the function of obtaining insurance and obtain a comprehensive policy for assets
at numerous locations (to avail the benefit of rebate on bulk business). Fixed
assets, particularly furniture and fixture, consumer durables, etc. are provided by
banks to the staff and the account for the same is maintained at the office where
the employee is posted. For disposal of fixed assets, powers are delegated to
various levels in the bank.
2.03 As far as maintenance of records relating to fixed assets is concerned,
practices vary among banks. In some banks, the offices acquiring the fixed
assets have to maintain proper records including the provision of depreciation
thereon whereas in case of some banks, the same is being done at the Head
Office. In such a case, the acquisitions, disposals, etc. are advised by the
branch/other office concerned to the head office through the inter-branch
accounting mechanism. A variant of this practice involves the recording of
depreciation by branches and other offices based on the advice received from
the head office. In recent times, some of the banks have installed Fixed Asset
Management Software and the information relating to purchase, sale of fixed
assets and depreciation thereon (in some cases) is accounted for with the help of
such software. This is usually done at a centralized HO level and reports are
generated at branches and/or regional/zonal offices. In some cases, passing of
entries of certain types of IT assets, like computers, printers, ATMs etc., are
centralized at the HO. However, physical records need to be updated at
branches. Also branches need to update records/inform HO in case there has
been physical movement of assets from one branch/location to another including
in case of transfers at staff quarters or disposal. At the branch level, an auditor
Guidance Note on Audit of Banks (Revised 2019)
needs to conduct a physical verification of all assets particularly those acquired
during the year and match the same with fixed asset management system
(manual or electronic). At head office level SCAs should obtain reconciliation of
inter-branch/inter-office transfers made during the year. Discrepancies, noticed if
any, on such verification/transfer should have been properly dealt with in the
books.
Balance Sheet Disclosure
2.04 The Third Schedule to the Banking Regulation Act, 1949 requires fixed
assets to be classified into two categories in the balance sheet, viz., Premises
and Other Fixed Assets. Though not specifically mentioned under the Banking
Regulation Act, 1949, the assets taken on lease and intangible assets should be
shown separately for proper classification and disclosure and also to comply with
the requirements of the Accounting Standards (ASs) issued by the Institute of
Chartered Accountants of India(ICAI).
2.05 As per the Notes and Instructions for compilation of balance sheet,
issued by the RBI, premises wholly or partly owned by the banking company for
the purpose of business including residential premises should be shown under
the head, `Premises'. Furniture and fixtures, motor vehicles, office equipment,
computers and all other fixed assets except premises should be shown under the
head `Other Fixed Assets'.
2.06 The original cost of fixed assets as on 31st March of the preceding year,
additions thereto and deductions therefrom during the year, and total
depreciation written off to date are to be disclosed in the financial statements.
The Notes and Instructions for Compilation of Balance Sheet, issued by the RBI,
require that where sums have been written-off on reduction of capital or
revaluation of assets, every balance sheet after the first balance sheet
subsequent to the reduction or revaluation should show the revised figures for a
period of five years with the date and amount of revision made.
2.07 No rates of depreciation on fixed assets have been prescribed by the
Banking Regulation Act, 1949. The provisions of the Schedule II to the
Companies Act, 2013, should, therefore, be kept in mind in this respect
especially in so far as the banking companies are concerned. Disclosure is
mandatory in respect of the method adopted to compute the revalued amounts,
the nature of the indices used, the year of any appraisal made and whether an
external valuer was involved in case the assets are stated at revalued amounts.
The Banking Regulation Act, 1949 requires that the auditor should examine
whether the rates of depreciation are appropriate in the context of the expected
useful lives of the respective fixed assets. Depreciation rates must be
reconfirmed with the accounting policy of the bank. In respect of computers and
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data processing equipment, RBI has directed that depreciation should be
provided over three year period. With respect to fixed assets held at foreign
offices/branches, depreciation policy should be consistent with that followed by
the bank as a whole and to the extent not contradictory with the local laws and
regulations. Further, as per note 4 of Schedule II of the Companies Act, 2013,
useful life specified in Part C of the Schedule is for whole of the asset. Where
cost of a part of the asset is significant to total cost of the asset and useful life of
that part is different from the useful life of the remaining asset, useful life of that
significant part shall be determined separately, in other words component
accounting with respect to fixed assets would be mandatory effective from
financial year 2015-16 onwards.
2.08 An immovable property acquired by the bank in satisfaction of debts due
should be included under the head 'fixed assets', if it is held by the bank for its
own use.
2.09 The Third Schedule to the Banking Regulation Act, 1949, does not
specifically deal with disclosure of land. Land is generally shown under the
heading `Premises'.
Other Assets
2.10 The following items broadly are to be disclosed under the head 'Other
Assets':
Inter-office adjustments (net) Stationery and stamps
Interest accrued Non-banking assets acquired in
satisfaction of claims
Tax paid in advance/tax deducted
at source Others
2.11 As per RBI Circular no. DBOD.BP.BC.24/21.04.048 dated March 30,
1999, credit card outstanding is not to be included under `Other Assets'. Instead,
they have to be shown as part of advances.
2.12 As per RBI circular DBOD.BP.BC.83/21.01.002/2000-01 dated February
28, 2001, all loans and advances given to staff, which are non-interest bearing
should be included in item 'Others' under 'Other Assets' and should not be
reflected as `Advances'.
Audit Approach and Procedures
Fixed Assets
2.13 In carrying out the audit of fixed assets, the auditor is concerned,
primarily, with obtaining evidence about their ownership, existence and
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valuation. For this purpose, the auditor should review the system of internal
controls relating to fixed assets, particularly the following:
Control over expenditures incurred on fixed assets acquired or self-
constructed;
Accountability and utilisation controls; and
Information controls for ensuring availability of reliable information about
fixed assets.
2.14 The branch auditor should ascertain whether the accounts in respect
of fixed assets are maintained at the branch or centrally. Similarly, the auditor
should ascertain the location of documents of title or other documents
evidencing ownership of various items of fixed assets. The procedures
described in the following paragraphs would be relevant only to the extent the
accounts and documents of title, etc., relating to fixed assets are maintained at
the branch. Where the acquisition, disposal, etc., of fixed assets take place at
branches / other offices, but accounting of fixed assets is done at the head
office, the branch auditor should examine whether acquisitions, disposals, etc.
effected at the branch during the year have been properly communicated to the
head office. In cases where, for any reason acquisition of fixed asset is shown
in suspense account then the branch cannot classify the asset in the Balance
Sheet under this head unless the asset is put to use or ready for use, as the
case may be, and all internal formalities are completed. A long-standing
suspense entry of this type should be properly dealt with by the auditor and
may need to be escalated to the statutory central auditors if the amount
involved is material.
Premises
2.15 The auditor should verify the opening balance of premises with
reference to schedule of fixed assets, ledger or fixed assets register.
Acquisition of new premises should be verified with reference to authorisation,
title deeds, record of payment, etc. Self-constructed fixed assets should be
verified with reference to authorisation from appropriate authority and
documents such as, contractors' bills, work order records, record of payments
and completion certificate. The auditor should also examine whether the
balances as per the fixed assets register reconcile with those as per the ledger
and the final statements.
2.16 In the case of leasehold premises, capitalisation and amortisation of
lease premium, if any, should be examined. Any improvements to leasehold
premises should be amortised over their balance residual life. It would be
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appropriate to segregate the cost/value of the land from the
building/superstructures to ensure that depreciation/amortisation is
appropriately considered in case of leasehold premises.
2.17 In case the title deeds are held at the head office or some other
location, the branch auditor should obtain a written representation to this effect
from the branch management and should bring this fact to the notice of the
statutory central auditor through a suitable mention in his report. This fact
should also be brought in the Long Form Audit Report (LFAR).
2.18 Where premises are under construction, it should be seen that they
are shown under a separate heading, e.g., `premises under construction'.
Advances to contractors may be shown as a separate item under the head
`fixed assets' or under the head `Other Assets'. It should be verified that where
the branch has obtained the licence to commence business and is ready for
use then the same is not shown as "premises under construction". In such
cases even if all the bills/ documents from the contractors/suppliers are not
received, at the year end, an estimate of the expenditure thereon should be
made and capitalised on a provisional basis.
2.19 As per the AS-10 (Revised), Property, Plant & Equipment, the banks
can adopt the policy to follow Cost Model or Revaluation Model for Premises or
any other class of Property, Plant & Equipment(PPE). The auditor should
inquire about the policy followed by the bank and verify the accounting
treatment more specifically with reference to revaluation model. The auditor
should also check the impairment, if any, by applying the principles laid down
in Accounting Standard (AS) 28, "Impairment of Assets".
2.20 The auditor should specifically keep in mind the provisions of section 9
of the Banking Regulation Act, 1949, which prohibit a banking company from
holding any immovable property, howsoever acquired (i.e., whether acquired by
way of satisfaction of claims or otherwise), for a period exceeding seven years
from the date of acquisition, except such as is required for its own use. The
auditor should specifically examine that no immovable properties other than
those required for the own use of the bank have been included in fixed assets
(own use would cover use by employees of the bank, e.g., residential premises
provided to employees). The branch auditor should also obtain a written
representation to the above effect from the branch management.
Other Fixed Assets
2.21 The procedures discussed above regarding premises also apply, to
the extent relevant, to verification of other fixed assets. In respect of movable
fixed assets, the auditor should pay particular attention to the system of
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recording the movements as well as other controls over such fixed assets, e.g.,
their physical verification at periodic intervals by the branch management
and/or by inspection/internal/concurrent audit team. The auditor should also
examine whether discrepancies have been properly dealt in the books of
account and adequate provision in respect of any damaged assets has been
made as per the physical verification of fixed assets reports available on
record.
2.22 Banks incur substantial expenditure on computer hardware and
software. Computer hardware qualifies the definition of a property, plant and
equipment' as given in AS 10 (Revised), "Property, Plant and Equipment".
Computer software that is essential for the functioning of the hardware (e.g.,
operating system) can be considered an integral part of the related hardware.
The expenditure incurred on acquisition and installation of the hardware (as
also on any systems software considered to be an integral part of the related
hardware) should be capitalised in accordance with the principles laid down in
AS 10 (Revised) and depreciated over the remaining useful life of the
hardware. Hardware and software are susceptible to faster rate of technical
obsolescence; hence the auditor must take into consideration this fact while
verifying the provision for depreciation on these assets. The same, however,
should not be depreciated for a period of more than three years.
2.23 Application software is not an integral part of the related hardware and
is treated as an intangible asset. Accordingly, the same should be accounted
for as per Accounting Standard (AS 26), "Intangible Assets". The treatment of
expenditure on application software, whether acquired from outside or
developed in-house, would also be similar. However, in estimating the useful
life of application software, the rapid pace of changes in software as also the
need for periodic modification/ upgradation of software to cater to changes in
nature of transactions, information needs etc. need special consideration. As
far as expenditure during the stage of in-house development of software is
concerned, the same needs to be accounted for in accordance with AS 26,
according to which expenditure incurred during the research phase should not
be capitalised as part of cost of intangibles. While capitalising the development
phase expenditure, due consideration should be given to Paragraph 44 of the
said Standard. Further, due care should be taken in verifying the date of
capitalization and date on which asset was put to use/ ready for intended use,
particularly in case of implementation of application software and system.
While conducting the audit of intangible assets, the auditor should also
consider the guidelines issued by RBI by way of Circular
No.DBOD.No.BP.BC.82/21.04.018/2003-04, dated April 30, 2004.
2.24 In case of banking companies, the auditor needs to verify that the
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requirements of Schedule II to the Companies Act, 2013 are also complied with
including identification of components wherever applicable. Banks may acquire
software at considerable expenditure. The system of recording this expenditure
as part of the fixed assets (so that it may be depreciated) or to defer
expenditure (for amortisation over its useful life) may be reviewed. The Bank's
Accounting Policy in this regard must be enquired into, and a note kept on
record. Non-provision for this intangible asset will not attract the provisions of
Section 15 of the Banking Regulation Act, 1949 as per a notification specifically
issued by the Government of India.
2.25 At times, though depreciation has been fully provided on certain types
of assets, however, they continue to be in use. In such cases the auditor
should verify that the bank's policy in this regard has been followed.
2.26 Many a times, fixed assets like furniture, office equipments, etc., are
transferred from one branch to another. The auditor should examine whether
accumulated depreciation in respect of such assets is also transferred. It may
be noted that the consolidated accounts of the bank would not be affected by
such transfers. In recent times, the fixed asset management software are in
use. The auditor has to examine the reasonableness of the internal controls
with respect to recording such inter branch transfer of assets.
2.27 It should be examined whether fixed assets have been properly
classified. Fixed assets of similar nature only should be grouped together. For
example, items like safe deposit vaults should not be clubbed together with the
office equipment or the theft alarm system of the bank.
2.28 In respect of fixed assets sold during the year, a copy of the sale
deed, if any, and receipt of the sale value should be examined by the auditor.
In such a case, it should also be seen that the original cost and accumulated
depreciation on the assets sold have been correctly adjusted. Profit earned or
loss incurred on such sales should also be checked.
2.29 In case of sale/disposal/scrapping of fixed assets, the auditor should
examine whether there is an adequate control system in place and the same
has been adhered to. The auditor should also ensure that proper accounting
for the same has been done.
2.30 The auditor should examine whether any expenditure incurred on a
fixed asset after it has been brought to its working condition for its intended
use, has been dealt with properly. According to AS 10 (Revised), "Property,
Plant & Equipment", such expenditure should be added to the book value of the
fixed asset concerned only if it increases the future benefits from the asset
beyond its previously assessed standard of performance.
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2.31 The auditor at head office level should examine if the consolidated
fixed assets schedule matches in all respect and all the transfers' ins/outs, are
tallied. A broad check on the depreciation amount vis-a-vis the gross block of
assets must be reviewed with special emphasis on the computer
hardware/software.
Leased Assets
2.32 RBI's Circular No. DBOD No.FSC.BC.70/24.01.001/99 dated July 17,
1999 deals with accounting and provisioning norms to be followed by banks
undertaking leasing activity. The auditor, in respect of leased assets, should
also have regard to the requirements of AS 19, "Leases". Assets given on
Lease need to be separately shown in the same manner as other assets.
Impairment of Assets
2.33 AS 28, "Impairment of Assets" prescribes the procedures that an
enterprise should apply to ensure that its assets are carried at not more than
their recoverable amount. An asset is treated as carried at more than its
recoverable amount if its carrying amount exceeds the amount to be recovered
through use or sale of the asset. If this is the case, the asset is described as
impaired and this Standard requires the enterprise to recognise an impairment
loss. This Standard also prescribes when an enterprise should reverse an
impairment loss and it prescribes certain disclosures for impaired assets. This
Standard requires that an enterprise should assess at each balance sheet date
whether there is any indication that an asset may be impaired. The impairment
loss, if recognised, shall be debited to the profit and loss account provided no
revaluation reserve exists at that date in relation to the asset, and if it exists, the
loss should first be debited to revaluation reserve. After debiting the revaluation
reserve, if still there is impairment loss then the same should be debited to profit
and loss account. RBI's circular on compliance with Accounting Standards,
issued in April 2004 states as follows in respect of AS 28:
The Standard would not apply to investments, inventories and financial
assets such as loans and advances and may generally be applicable to
banks in so far as it relates to fixed assets.
Banks may also take into account the following specific factors while
complying with the Standard:
Paragraphs 7 and 8 of the Standard have clearly listed the triggers
which may indicate impairment of the value of assets. Hence, banks
may be guided by these in determining the circumstances when the
Standard is applicable to banks and how frequently the assets
covered by the Standard need to be reviewed to measure impairment.
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Fixed Assets and Other Assets
In addition to the assets of banks which are specifically identified
above, viz., financial assets, inventories, investment, loans and
advances etc., to which the Standard does not apply, the Standard
would apply to financial lease assets and non-banking assets acquired
in settlement of claims only when the indications of impairment of the
entity are evident.
Other Assets
2.34 The branch auditor may carry out the audit of various items appearing
under the head `Other Assets' in the following manner.
Inter-Office Adjustments
2.35 Inter Office Adjustments/Inter Branch Account is dealt separately in
Chapter 11 "Inter-office Transactions" of Part III of the Guidance Note on Audit of
Banks, 2019 edition (Section A Statutory Central Audit).
Interest Accrued
2.36 The main components of this item are interest accrued but not due on
investments and advances and interest due but not collected on investments.
As banks normally debit the borrower's account with interest due on the
borrower's repayment cycle date, there would usually be an amount of interest
accrued but not due on advances on balance sheet date. On the other hand,
interest on government securities, debentures, bonds, etc., which accrues from
day to day should be calculated and brought into account, in so far as it has
accrued on the date of the balance sheet. The auditor should examine whether
the interest has been accrued on the entire loans and advances portfolio of the
bank. Special consideration should be given to the overdue bills
purchased/discounted. Several times the interest accrued on such advances is
manually computed by the Branch and the auditors should check the workings
thoroughly so as to avoid any income leakages. As far as possible, the detailed
breakup of the loan portfolio and the interest accrual should be obtained and the
same should agree with the general ledger balance. This would ensure
completeness of the interest accrual of advances. The auditor should also
examine the interest accrued on advances by re-computing it on a test check
basis by referring to the loan parameters like frequency of payment of interest
amount, rate of interest, period elapsed till the date of balance sheet, etc., from
the loan agreements. This would ensure the completeness of the interest
accrual on advances. In the current banking scenario, the interest accrual
setup is automated system driven for most banks and the auditor should verify
the in built logic and controls of the system.
2.37 The auditor should examine whether only such interest as can be
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realised in the ordinary course of business should be shown under this head.
This is based on the principle, recognised in AS 9, "Revenue Recognition" that
revenue cannot be recognised if there is a significant uncertainty about its
collectability; as also with instructions given by RBI to the effect that interest be
not recorded as income in respect of Non-Performing Assets (NPAs). Interest
accrued in the current year in respect of accounts identified as NPAs must be
reversed to Income and derecognised and cannot be the subject matter of a
provision. Dividends recognised as income but not received may be included in
the residuary sub-head of `Others'. Dividends and interest on investments
would be recognised in the books of the branch only if it is handling the work
relating to investments or receipt of income on investments.
Tax Paid in Advance/Tax Deducted at Source
2.38 Generally, this item is dealt at the head office only and would,
therefore, not appear in the balance sheet of a branch, except that tax
deducted at source on fixed deposits and other products/services if handled at
the branch level. The procedures to be followed by the branch auditor for
verification of tax deducted at source by the branch would be similar to those in
an audit of other types of entities. The branch auditor needs to examine
whether the certificates for such tax deducted at source is collected by the
branch and the original copy is sent to the Head Office along with the transfer
of such Tax Deducted at Source (TDS) amount to Head Office on periodic
basis as defined.
2.39 At Head Office, the availability of all the TDS Certificates, submission
of the same with Income Tax Department/claim of the same in Income Tax
returns filed should be checked to verify the justification of the claim towards
such certificates. The auditor should also verify the online tax credit from the
Income Tax website with the TDS/advance tax recorded in the books and ask
for a reconciliation of the same. Income recognized in the books could also be
cross verified by this analysis. If there is any TDS, the auditor needs to enquire
as to the income to which it pertains so that the bank claims it in its
assessments.
Stationery and Stamps
2.40 Internal controls over stationery of security items (like term deposit
receipts, drafts, pay orders, cheque books, traveller's cheques, gift cheques,
etc.) assume special significance in the case of banks as their loss or misuse
could eventually lead to misappropriation of the most valuable physical asset of
a bank, viz., cash. The branch auditor should study and evaluate the existence,
effectiveness and continuity of internal controls over these items in the normal
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course of his audit. It may be noted that the branch auditor is required to
specifically comment on the adequacy of the relevant internal controls in his
LFAR.
2.41 As per RBI instructions, the item "Stationery and Stamps" should
include only exceptional items of expenditure on stationery like, bulk purchase
of security paper, loose leaf or other ledgers, etc., which are shown as quasi-
asset to be written off over a period of time. The valuation of such items is
suggested to be at cost without any element of escalation/appreciation. In other
words, the normal expenditure on stationery may be treated as an expense in
the profit and loss account, while unusually heavy expenditure may be treated
as an asset to be written off based on issue/consumption. At the branch level,
the expenditure on latter category may not appear since a considerable part of
the stationery is supplied to branches by the head office.
2.42 The auditor should physically verify the stationery and stamps on hand
as at the year-end, especially stationery of security items. Any shortage should
be inquired into as it could expose the bank to a potential loss from misuse.
The auditor should examine whether the cost of stationery and stamps
consumed during the year has been properly charged to the profit and loss
account for the year in the context of the accounting policy/instructions from the
head office regarding treatment of cost of stationery and stamps.
Non-Banking Assets Acquired in Satisfaction of Claims
2.43 Under this heading, will be included, those immovable properties/tangible
assets, which the bank has acquired in satisfaction of debts due or its other claims
and are being held with the intention of being disposed of.
2.44 While examining this item, the auditor should specifically keep in mind
the provisions of section 9 of the Banking Regulation Act, 1949, which prohibit a
banking company from holding any immovable property, however acquired (i.e.
whether acquired by way of satisfaction of claims or otherwise), except such as
required for its own use, for any period exceeding seven years from the date of
acquisition thereof. During this period, the bank may deal or trade in any such
property for the purpose of facilitating the disposal thereof. The RBI has the
power to extend the aforesaid period in a particular case up to another five years.
2.45 Except when held for its own use, AS 10 (Revised), "Property, Plant &
Equipment", would not be applicable on those fixed assets which are held with
the bank in satisfaction of claim. At the date of acquisition, the assets should be
recorded at amount lower of the net book value of the advance or net realisable
value of asset acquired. At each balance sheet date, net realisable value of such
assets may be re-assessed and necessary adjustments may be made.
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2.46 The auditor should verify such assets with reference to the relevant
documentary evidence, e.g., terms of settlement with the party, order of the Court
or the award of arbitration, etc. The auditor should verify that the ownership of
the property is legally vested in the bank's name. If there is any dispute or other
claim about the property, the auditor should examine whether the recording of
the asset is appropriate or not. In case the dispute arises subsequently, the
auditor should examine whether a provision for liability or disclosure of a
contingent liability is appropriate, keeping in view the requirements of AS 29
"Provisions, Contingent Liabilities and Contingent Assets".
Others
2.47 This is the residual heading, which will include items not specifically
covered under other sub-heads, e.g., claims which have not been received,
debit items representing additions to assets or reductions in liabilities which
have not been adjusted for technical reasons or want of particulars, etc.,
receivables on account of government business, prepaid expenses, Accrued
income other than interest (e.g., dividend declared but not received) may also
be included under this head. The audit procedures relating to some of the
major items included under this head are discussed below.
Non-Interest Bearing Staff Advances
2.48 The auditor should examine non-interest bearing staff advances with
reference to the relevant documentation and the bank's policy in this regard.
The availability, enforceability and valuation of security, if any, should also be
examined. It needs to be examined whether the same relates to employees on
the roll of the bank on the date of the preparation of financial statements.
2.49 Banks grant unsecured advances to staff like festival/drought
relief/housing advances etc. due to the employer- employee relationship where
normally lien is marked on the terminal benefits of the employee; but advances
against FDRs and other securities etc. are also given. While distinction needs
to be made between advances given by the bank as an "employer" and as
"banker", the RBI's latest applicable circular needs to be kept in view as
regards disclosure requirement of advances in the latter category i.e. as
banker.
Security Deposits
2.50 Security deposits with various authorities (e.g., on account of
telephone, electricity, etc.,) and with others (e.g., deposits in respect of
premises taken on rent) should be examined with reference to documents
containing relevant terms and conditions, and receipts obtained from the
parties concerned. The auditor should verify that the deposits have not become
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due as per the terms and conditions. If it is so, then the recoverability of the
same needs to be looked into in detail and appropriate provision should be
suggested against the amount where recovery is in doubt.
2.51 The auditor, based on the materiality, should send independent
balance confirmation for security deposit at period end and should document
the reason in the case of any differences. Verification of all security deposits
given during the year should be conducted and that of older deposits can be
done on a test check basis.
Suspense Account
2.52 'Suspense' account is another item included under 'other assets'.
Ideally, where accounts are maintained properly and on a timely basis, the
suspense account may not arise. However, in a practical situation, suspense
account is often used to temporarily record certain items such as the following:
(i) amounts temporarily recorded under this head till determination of the
precise nature thereof or pending transfer thereof to the appropriate head
of account;
(ii) debit balances arising from payment of interest warrants/ dividend
warrants pending reconciliation of amounts deposited by the company
concerned with the bank and the payment made by various branches on
this account;
(iii) amounts of losses on account of frauds awaiting adjustment.
2.53 RBI has also suggested a quick audit of entries in Suspense Account
and the status thereof to be reported in terms of its circulars dated
6.7.95/18.8.95 and reference may also to be made to the RBI Circular
DBOD.BP.BC.4/21.04.018/2003-04 dated 19.7.03.
2.54 The auditor should pay special attention to any unusual items in
suspense account since these are prone to fraud risk. The auditor should
obtain the management policy for provision/write off for old outstanding items.
He should obtain from the management, details of old outstanding entries/age-
wise balances along with narrations in suspense account. The auditor should
also verify the reasons for such delay in adjusting the entries. Where the
outstanding balances comprised in suspense account require a provision/write-
off, the auditor should examine whether the necessary provision has been
made/written off. All items of more than 6 months in suspense accounts need
special attention of the auditor. The auditor has to certify all the suspense
account entries through a separate certificate in the annual closing sets.
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Prepaid Expenses
2.55 The auditor should verify prepaid expenses in the same manner as in
the case of other entities. The auditor should examine whether the basis of
allocation of expenditure to different periods is reasonable. The auditor should
particularly examine whether the allocation of discounting and rediscounting
charges paid by the bank to different accounting periods is in consonance with
the accounting policy followed for the bank as a whole.
Miscellaneous Debit Balances on Government Account
2.56 Miscellaneous debit balances on government account in respect of
pension, public provident funds, compulsory deposit scheme payments, etc.,
for which the branch obtains reimbursement from the government through a
designated branch, are also included under the head 'others'. In many cases,
the accounting for this is outside the core banking solution and needs the
special attention of the auditor. The auditor should review the ageing
statements pertaining to these items. He should particularly examine the
recoverability of old outstanding items. The auditor should also examine
whether claims for reimbursement have been lodged by the branch in
accordance with the relevant guidelines, terms and conditions. The net
balances of the amount recoverable at the Head Office level should also be
taken along with the age-wise analysis of the same. In case of old outstanding
balances without any confirmation or proper justification of the same, should be
provided for /written off as the case may be in the accounts.
2.57 The residual item of "Others" in "Other Assets" generally constitutes a
significant amount in the Balance Sheet of the bank. The Head Office auditors
should obtain the head wise details of the same along with the previous year
figures. The age-wise details of the major outstanding should also be obtained.
Further, the major variance as compared to the previous year figures should
also be enquired into and reasons for the same should be recorded and
reviewed. In case any amount seems doubtful of recovery, appropriate
provisions against the same should be made.
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IV-3
Borrowings and Deposits
Borrowings
3.01 Borrowings usually take place only at head office of the bank. In case
of exception there is a borrowing at few designated branches authorised in this
behalf by the head office or other controlling authority either generally or
specifically in respect of a particular borrowing. As such, this item generally
does not figure in the balance sheets of most branches of the bank.
Balance Sheet Disclosure
3.02 Borrowings of a bank are required to be shown in balance sheet as
follows.
I. Borrowings in India
(i) Reserve Bank of India
(ii) Other Banks
(iii) Other Institutions and Agencies
II. Borrowings outside India
RBI vide its circular no. DBOD.BP.BC No.81/ 21.01.002/2009 -10 dated March
30, 2010 on "Classification in the Balance Sheet - Capital Instruments" advised
that the following classification may be adopted in the balance sheet from the
financial year ending March 31, 2010:
Under Schedule 1 Capital
1) Perpetual Non-Cumulative preference shares (PNCPS).
Under Schedule 4 Borrowings
1. Innovative Perpetual Debt Instruments (IPDI).
2. Hybrid debt capital instruments issued as bonds/debentures.
3. Perpetual Cumulative Preference Shares (PCPS).
4. Redeemable Non-Cumulative Preference Shares (RNCPS).
5. Redeemable Cumulative Preference Shares (RCPS).
6. Subordinated Debt.
3.03 The total amount of secured borrowings included under the above
Guidance Note on Audit of Banks (Revised 2019)
heads is to be shown by way of a note to the relevant schedule (Schedule 4).
Secured borrowings for this purpose include borrowings/refinance in India as
well as outside India. It may be noted that the inter-office transactions are not
borrowings and therefore, should not be presented as such.
3.04 RBI, Export-Import Bank of India (EXIM Bank), National Bank for
Agriculture and Rural Development (NABARD) and Small Industries
Development Bank of India (SIDBI) are the major agencies providing refinance
to banks, generally for loans extended to specified sectors. Borrowings from
RBI include refinance obtained by the bank from the RBI. Similarly, borrowings
from other banks include refinance obtained by the bank from commercial
banks, co-operative banks, etc. Refinance obtained by the bank from EXIM
Bank, NABARD, SIDBI and other similar institutions and agencies is to be
included under `Borrowings from other institutions and agencies'. This head will
also include the bank's liability against participation certificates on non-risk
sharing basis issued by it to participating banks.
3.05 VOSTRO Accounts which are akin to Current account balances and
do not constitute borrowings unless an overdraft/borrowing facility is obtained
and evidenced on record.
If NOSTRO Mirror Account as well as NOSTRO Account is having adverse
balance, the same represents borrowings from banks outside India.
If NOSTRO Mirror Account is representing an adverse balance but NOSTRO
Account is not having an adverse balance, the same indicates that there are
certain unresponded reconciliation entries resulting in NOSTRO Mirror adverse
balance. The auditor needs to review such reconciliation entries and ensure
that the same are effected appropriately to ensure that the NOSTRO Mirror
Account is not reflecting adverse balance in Financials (wherein NOSTRO
Account is not having an adverse balance).
3.06 `Borrowings outside India' include borrowings of Indian branches
abroad as well as borrowings of foreign branches. Funds raised by foreign
branches by way of certificates of deposit, notes, bonds, etc. have to be
classified as `deposits' or as `borrowings' depending upon documentation. The
Notes and Instructions for Compilation of balance sheet and profit and loss
account, issued by the RBI, clarify that since refinance obtained by a bank from
the RBI and various institutions is to be shown under the head `borrowings', the
related advances should be shown on the assets side at the gross amount.
3.07 Money at call or short notice taken by the bank is also shown under
this head. RBI through its "Master Circular no. RBI/FMRD/2016-17/32 FMRD.
Master Direction No. 2/2016-17 on "Money Market Instruments: Call/Notice
Money Market, Commercial Paper, Certificates of Deposit and Non-
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Convertible Debentures (original maturity up to one year)" dated July 07,
2016 has set down the prudential limit for transactions in call/notice money
market. In terms of the said circular, on a fortnightly average basis, the
borrowings should not exceed 100 percent of the capital funds (i.e., sum of Tier
I and Tier II capital) of latest audited balance sheet. However, banks are
allowed to borrow a maximum of 125 percent of their capital funds on any day,
during a fortnight.
Certificates of deposits are to be treated (at the discounted value at the year-
end), as deposits and not as borrowings.
Inter Bank Liabilities (IBL)
3.08 Liability side management has its own merits from the point of view of
financial stability. Controlling the concentration risk on the liability side of banks
is, therefore, as important as controlling the concentration risk on the asset
side. More particularly, uncontrolled IBL may have systemic implications, even
if, the individual counterparty banks are within the allocated exposure.
3.09 Further, uncontrolled liability of a larger bank may also have a domino
effect. In view of this, it has become important to put in place a comprehensive
framework of liability management so that banks are aware of the risks
inherent in following a business model based on large amount of IBL and the
systemic risks such a model may entail. In order to reduce the extent of
concentration on the liability side of banks, the following guidelines have been
prescribed by the RBI (applicable from April 1, 2007) vide its circular no.
DBOD.BP.BC.66/ 21.01.002/2006-07 dated March 6, 2007.
(a) The IBL of a bank should not exceed 200% of its net worth as on 31st
March of the previous year. However, individual banks may, with the
approval of their Boards of Directors, fix a lower limit for their inter-bank
liabilities, keeping in view their business model.
(b) The banks whose CRAR is at least 25% more than the minimum CRAR
as on March 31 of the previous year, are allowed to have a higher limit up
to 300% of the net worth for IBL.
(c) The limit prescribed above will include only fund based IBL within India
(including inter-bank liabilities in foreign currency to banks operating
within India). In other words, the IBL outside India are excluded.
(d) The above limits will not include collateralised borrowings under CBLO
and refinance from NABARD, SIDBI etc.
(e) The existing limit on the call money borrowings prescribed by RBI will
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operate as a sub-limit within the above limits.
(f) Banks having high concentration of wholesale deposits should be aware
of potential risk associated with such deposits and may frame suitable
policies to contain the liquidity risk arising out of excessive dependence
on such deposits.
Deposits
3.10 Deposits represent the most important source of funds for banks.
Deposits are received from a large number of constituents, generally in small
amounts.
Balance Sheet Disclosure
3.11 Deposits are required to be classified in the balance sheet under the
following heads.
A. I. Demand Deposits
(i) From Banks
(ii) From Others
II. Savings Bank Deposits
III. Term Deposits
(i) From Banks
(ii) From Others
B. I. Deposits of branches in India
II. Deposits of branches outside India
Types of Deposits
3.12 Deposits accepted by banks are primarily of two types those
repayable on demand (demand deposits) and those repayable after a fixed
term (term deposits), though in this case also, the deposits may be repaid
prematurely at the request of the depositor.
Demand Deposits
3.13 Current accounts are the most common form of demand deposits of
banks. Though savings bank deposits are also, in substance in the nature of
demand deposits, the Third Schedule to the Banking Regulation Act, 1949,
does not consider them demand deposits. This may, perhaps, be due to the
fact that withdrawals from savings bank accounts in excess of the limits
prescribed by the bank can be made only with prior notice to the bank.Further it
includes overdue/matured deposits, credit balance in overdraft account, deposits
payable at call, in operating current account, VOSTRO account, merchant
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bankers and similar deposits, Interest accrued and due on deposits and
excluding margins by way of book adjustments if any against bill purchased and
discounted.
3.14 Current accounts can be opened in the names of individuals,
associations of persons, corporate bodies, trusts, societies, etc., i.e., for all
kinds of customers. The operations on current accounts opened in joint names
may be joint, single, by either holder or by surviving holder, depending on the
mode of operation chosen by the account holders. The salient features of this
type of accounts are:
There is no restriction on the quantum of funds that can be withdrawn by
the account holder at any one time.
There is no restriction on the number of transactions in the account during
any period of time.
No interest is payable on this deposit except where it may be specifically
permitted by the bank / RBI.
Savings Bank Deposits
3.15 Savings accounts are generally in the names of individuals either
singly or jointly, and sometimes, in the names of institutions which are
specifically approved by the RBI for maintaining savings bank accounts with
banks. In terms of RBI's guidelines, no bank can open a savings bank account
for government departments, municipal corporations, municipal committees,
any political party, or any trade, business or professional concern, whether
such concern is a proprietary or a partnership firm or a company or an
association. As in the case of current accounts, savings bank accounts can
also be opened in joint names.
3.16 The salient features of this type of accounts are:
Banks place restrictions on the maintenance of minimum balance
(separate for accounts with cheque book facility and those without cheque
book facility), amount of funds that can be withdrawn by the account holder
at any point of time. Beyond this cut-off level, banks require the depositors
to give notice of a specified period for withdrawal of the amount.
Banks also place restrictions on the number of withdrawals from the
account during a stated period of time, usually one year. For the number of
withdrawals beyond this number, banks have the right to levy service
charges. The intention behind putting this restriction is to ensure that the
savings bank accounts (on which the account holder is entitled to payment
of interest) are used to promote genuine savings and are not used as
substitutes for current accounts (on which the account holder usually does
not get interest).
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Interest is payable as per the RBI guidelines in force. In the past, interest
was paid annually but now, banks pay interest at quarterly / half-yearly
intervals on daily outstanding balances. Depending on the practice
adopted by each bank provision for the balance period up to the year-end
may be made at branches/Head Office.
Interest on savings bank accounts is required to be calculated on a daily
product basis in terms of Para 3.2.1 of the RBI Master Circular
DBR.No.Dir.BC. 7/13.03.00/2015-16 dated 1-7-2015; and the banks have
been given freedom to fix the rate of interest on savings accounts.
3.17 In the case of both current and savings bank accounts, if there are no
operations on the account by the account holder during a prescribed period
(such period may vary from bank to bank), such accounts are identified as
`dormant' or `inoperative' accounts and may be transferred to a separate
ledger. Further, transactions in these accounts are allowed only with authority
of the official designated by the bank for this purpose. Removing of "Specimen
signature" cards from active cards can be one of the controls.
Term Deposits
3.18 Term deposits (known by different nomenclature in different banks)
are repayable after a specified period of time. The minimum period of these
deposits, at present, is 7 days. The salient features of this kind of deposits are
given below:
Interest is payable at periodic intervals to the depositors or as per their
instructions.
In case a depositor so desires, the periodic interest can be reinvested in
fresh term deposits. Such schemes are generally called `reinvestment
plans'. In this case, the interest payable is compounded at the specified
intervals and the resultant maturity value is indicated on the deposit receipt
at the time of issuing the receipt. The head offices of banks issue maturity
value charts for the guidance of their branches from time to time.
3.19 Recurring deposit accounts are an important variant of term deposit.
In a recurring deposit, a specified sum is deposited at regular intervals,
generally once a month, for a pre-determined period. On the expiry of this
period, the maturity proceeds, which are known at the time of opening the
account, are repaid to the depositors or as per their instructions. No recurring
deposit is accepted under FCNR(B) Scheme. Some of the banks are offering
fixed / flexible recurring deposit accounts in recent times where the customer
chooses amount of deposit each time based on their convenience.
3.20 Cash Certificates and Certificates of Deposit (CD), in demat form or
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otherwise, are two other variants of term deposits. Cash certificates are issued
at discounted value, e.g., a certificate with face value of Rs. 100 and term of 5
years may be issued at, say, Rs. 49. The certificates of deposit are short-term
negotiable money market instruments and are issued in only dematerialised
form or as a Usance Promissory Note. However, according to the Depositories
Act, 1996, investors have the option to seek certificate in physical form.
Further, issuance of CDs will attract stamp duty. In this regard, the RBI has
issued Master Direction No. RBI/FMRD/2016-17/32FMRD. Master Direction No.
2/2016-17 dated July 07, 2016 on Money Market Instruments (which include
Certificate of Deposit). CDs may be issued at a discount on face value. The
rate of interest thereon is negotiable with the depositor and may vary on a daily
basis. The maturity period of CDs issued by banks should not be less than 7
days and not more than one year. Banks are allowed to issue CDs on floating
rate basis provided the methodology of compiling the floating rate is objective,
transparent and market-based. The issuing bank/FI is free to determine the
discount / coupon rate. The interest rate on floating rate CDs would have to be
reset periodically in accordance with a pre-determined formula that indicates
the spread over a transparent benchmark. CDs can be issued in Demat or in
physical form, and in the latter case must be issued on security paper
stationery, in denomination of Rs. 1 lac(for a single subscriber) or in multiple of
Rs 1 lac and without the benefits of repatriation if issued to NRI. Other than for
NRIs, CDs are transferrable by endorsement and delivery.
3.21 There is no grace period for repayment of CDs. If maturity date
happens to be on holiday it should be paid on the immediately preceding
working day. Banks may, therefore, so fix the period of deposit that the maturity
date does not coincide with a holiday to avoid loss of discount / interest rate.
All OTC trades in CDs shall be reported within 15 minutes of the trade on the
FIMMDA reporting platform.
3.22 In respect of term deposits, banks issue Deposit Receipts. These
receipts are not negotiable, and therefore, deposits cannot be transferred
without the consent of the bank. Certificates of deposits are, however,
transferable. CDs held in physical form are transferable by endorsement and
delivery. CDs in dematerialised form can be transferred as per the procedure
applicable to other demat securities. There is no lock-in period for CDs. Banks /
FIs cannot grant loans against CDs. Furthermore, premature buyback is not
permitted and no loans can be taken against CDs. However, the Reserve Bank
may relax these restrictions for temporary periods through a separate
notification.
3.23 Banks should include the amount of CDs in the fortnightly return under
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Section 42 of the Reserve Bank of India Act, 1934 and also separately indicate
the amount so included by way of a footnote in the return. Further, banks / FIs
should report the data on issuance of CDs on the web-based module under the
Online Returns Filing System (ORFS) within 10 days from the end of the
fortnight to which it pertains.
3.24 Banks normally allow repayment of the deposits before the due date;
however, the rate of interest paid to the depositor in case of premature
repayment is lower than the rate contracted initially. Auditor has to verify the
scheme of fixed deposits thoroughly. If a depositor does not take repayment on
the date of expiry, the interest ceases to run from the date, though the bank
continues to be a debtor of the depositor. A matured deposit can be renewed
by the depositor for a further period. Where a deposit is renewed sometime
after its maturity, banks generally allow interest from the date of maturity rather
than from the date of renewal. In other words, the renewal is given a
retrospective effect. In case the deposit is matured and not renewed by the
customer, the rate of interest same as saving bank rate is provided on the
same as per RBI Guidelines.
3.25 Pro-rated expenditure by way of discounts up to the year end on each
certificate must be accrued / adjusted and included under the head "Other
Liabilities", as the terms of issue warrant that the proceeds be paid only on
maturity.
3.26 Rate of interest payable on fixed deposits as well as other deposits
depends on current economic conditions, decided by banks from time to time
Interest rates are regulated by an Inter-Bank Agreement which is revised from
time to time. The rate of interest on certificates of deposits is negotiable with
the depositor, especially in the case of bulk/wholesale deposits.
3.27 Following are important issues in respect of different category of
accounts which auditor must consider:
(a) FCNR Accounts
Maintenance of position viz. details of deposits tallying the position
with reference to branches periodically.
System of reporting to the position maintenance office by the
branches including "C" category branch.
Applicability of notional rate.
Revaluation is done every reporting Friday for CRR purposes.
Provisions/payment of interest on a regular basis to reflect the due
liability.
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Is it debited to the proper Head of accounts?
Random check of interest as interest is charged every month based
on LIBOR.
How the payment is effected-expeditiously?
On payment whether the liability is reversed.
Method of reconciliation of Nostro account with FCNR (B).
It should not be revalued and taken to profit and loss.
Many banks have a separate Nostro account for FCNR (B) balances
converted on a notional basis.
Further, RBI, vide its Master Circular No. RBI/2015-16/40
DBR.No.Dir.BC.8/13.03.00/2015-16 dated July 1, 2015 on "Interest rates
on deposits held in FCNR (B) Accounts", provides guidance on the
interest rates on deposits held in FCNR(B) accounts. The Circular further
prohibit banks to:
(i) accept or renew a deposit over five years;
(ii) discriminate in the matter of rate of interest paid on the deposits,
between one deposit and another accepted on the same date and for
the same maturity, whether such deposits are accepted at the same
office or at different offices of the bank, except on the size group
basis. The permission to offer varying rates of interest based on size
of the deposits will be subject to the following conditions:
a. Banks should, at their discretion, decide the currency-wise
minimum quantum on which differential rates of interest may be
offered. For term deposits below the prescribed quantum with the
same maturity, the same rate should apply.
b. The differential rates of interest so offered should be subject to
the overall ceiling prescribed.
c. Interest rates paid by the bank should be as per the schedule and
not subject to negotiation between the depositor and the bank.
(iii) pay brokerage, commission or incentives on deposits mobilized
under FCNR(B) Scheme in any form to any individual, firm, company,
association, institution or any other person.
(iv) employ/ engage any individual, firm, company, association, institution
or any other person for collection of deposit or for selling any other
deposit linked products on payment of remuneration or fees or
commission in any form or manner.
(v) accept interest-free deposit or pay compensation indirectly.
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(b) Resident Foreign Currency Accounts
Exporters having good track record to open foreign currency account
with banks.
RBI will permit.
Unit located in SEZ may hold an account in Foreign Currency.
Diamond Dollar Accounts may be opened with permission from RBI to
transact business in Foreign Currency.
The returning Indians can have their foreign currency accounts to be
covered into RFC same feature as of FCNR.
(c) EEFC accounts
Non-interest bearing No credit facilities against the security of the
balances.
100% of inward remittance for Status Holder Exports, professional
service rendered in personal capacity.
100% of EOU, STP and EHTP, 50% for other payments received from
a unit DTA for goods supplied to SEZ.
(d) Non-resident Bank Accounts
Name of such accounts and type of arrangement.
Funding of these accounts bonafide transactions freely convertible
balance.
System of monitoring overseas bank not to take a speculative view on
rupees.
Forward purchase/sale of foreign currencies against rupee for funding
is prohibited offer two ways quote is also prohibited.
Temporary overdrawals to overseas branch/ correspondent not to
exceed Rs. 500.00 lakh in aggregate in all overseas
branch/correspondent in the books of the bank.
Purpose is essential.
Period not to exceed 5 days.
Statement to be sent to Forex Market Division of RBI.
Further, RBI, vide its Master Direction No. RBI/DBR/2015-16/19DBR. Dir.
No.84/13.03.00/2015-16 dated March 03, 2016 on Reserve Bank of India
(Interest Rate on Deposits) Directions, 2016 provides guidance on the
interest rates on rupee deposits held in Domestic, Ordinary Non-Resident
(NRO) and Non-Resident (External) (NRE) Accounts.
Further, RBI Circular RBI/2009-10/408DBOD. No. Dir. BC.
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91/13.03.00/2009-2010 dated April 20, 2010, provides the guidelines with
respect to the conversion of a term deposit, a deposit in the form of daily
deposit or a recurring deposit for reinvestment in term deposit and states
that a bank, on a request from the depositor, should allow conversion of a
term deposit, a deposit in the form of daily deposit or recurring deposit, to
enable the depositor to immediately reinvest the amount lying in the
aforesaid deposits with the same bank in another term deposit. On a
review and in order to facilitate better asset-liability management (ALM),
with effect from April 20, 2010, banks are permitted to formulate their own
policies towards conversion of deposits.
(e) Rupee Accounts (Exchange House)
Accounts opening require approval from RBI.
Trade transaction per transaction upto Rs.2.00 lakh is permitted.
Reconciliation issues and concurrent auditor overseas report.
Debits/claims outstanding as the branches pending receipt of the
credit.
Method of value dating the transactions and overdraft arisen thereon.
Collection of overdue interest for such over drawn balances.
Accounting
3.28 Banks may account the CDs at issue price under the Head "CDs
issued" and show the same under "Deposits". Accounting entries towards
discount will be same as in case of `Cash Certificate'. Banks should maintain a
register of CDs issued with complete particulars. Banks will maintain "CD
Redemption Account" represented by specific ISIN.
Combinations of Demand and Term Deposits
3.29 Although the above are the basic types of deposits, these days, most
of the banks are also offering combinations of two or more of them. These
blended products are known by different names in different banks.
Unclaimed Deposits/ Inoperative Accounts
3.30 As per RBI Circular no. DBOD No. Leg.BC.34/ 09.07.005/2008-09
dated August 22, 2008 on "Unclaimed Deposits/inoperative accounts in Banks",
a bank is required to make an annual review of accounts in which there are no
operations (other than crediting of periodic interest or debiting of service
charges) for more than one year. A savings as well as current account should
be treated as inoperative/ dormant if there are no transactions in the account
for over a period of two years. In case any reply is given by the account holder
giving the reasons for not operating the account, banks should continue
classifying the same as an operative account for one more year within which
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period the account holder may be requested to operate the account. However,
in case the account holder still does not operate the same during the extended
period, banks should classify the same as inoperative account after the expiry
of the extended period. If a Fixed Deposit Receipt matures and proceeds are
unpaid, the amount left unclaimed with the bank will attract savings bank rate
of interest. In terms of Foreign Exchange Management (Crystallization of
Inoperative Foreign Currency Deposits) Regulations, 2014 and vide Notification
No. FEMA 10A/2014-RB dated March 21, 2014, issued under Foreign Exchange
Management Act (FEMA), 1999 relating to inoperative foreign currency deposits,
directions have been issued under Sections 10(4) and 11(1) of FEMA; and as per
Clause 2.7 of the RBI Master Circular DBOD.No.Dir.BC.14/13.03.00/2014-15
dated 1-7-2014, inoperative deposits having a fixed term and those with no fixed
term maturity, after the expiry of a three month notice upon completion of three
years, will get crystallized into Rupees.
Depositor Education and Awareness Fund (DEAF) Scheme 2014
3.31 Reserve Bank of India vide its circular no. DBOD.DEAF Cell. BC. No.
101/ 30.01.002/2013-14 dated March 21, 2014 namely "The Depositor
Education and Awareness Fund Scheme, 2014 - Section 26A of Banking
Regulation Act, 1949" has laid down certain guidelines with respect to the said
fund. Under the provisions of Section 26A of the Banking Regulation Act, 1949
the amount to the credit of any account in India with any bank which has not
been operated upon for a period of ten years or any deposit or any amount
remaining unclaimed for more than ten years shall be credited to the Fund, within
a period of three months from the expiry of the said period of ten years. The
Fund shall be utilised for promotion of depositors' interest and for such other
purposes which may be necessary for the promotion of depositors' interests as
specified by RBI from time to time. The depositor would, however, be entitled to
claim from the bank the deposit or any other unclaimed amount or operate the
account after the expiry of ten years, even after such amount has been
transferred to the Fund. The bank would be liable to pay the amount to the
depositor/claimant and claim refund of such amount from the Fund.
3.32 All such unclaimed liabilities (where amount due has been transferred to
DEAF) may be reflected as "Contingent Liability Others, items for which the
bank is contingently liable" under Schedule 12 of the annual financial statements.
Banks are also required to disclose the amounts transferred to DEAF under the
notes to accounts.
Reserve Bank of India (Gold Monetization Scheme) Direction, 2015
3.33 The RBI issued Master Direction No.DBR.IBD.No.45/23.67.003/2015-16
dated 22-10-2015 to all Scheduled Commercial Banks that decide to implement
the Scheme(excluding Regional Rural Banks), requiring such banks that decide
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to implement the Scheme (Designated Bank), to formulate a comprehensive
policy with approval of their respective boards.
3.34 The Gold Monetization Scheme, 2015 (GMS) which includes the
Revamped Gold Deposit Scheme (R-GDS) and Revamped Gold Metal Loan
Scheme (R-GML) was intended to mobilise gold held by households and
institutions to facilitate its use for productive purposes, and to reduce country's
reliance on the import of gold.
3.35 Designated Banks are authorised to accept deposits, the principal and
interest of which, under the scheme, shall be denominated in gold. Such deposits
can be accepted from eligible persons viz., Resident Indians (Individuals, HUFs,
Trusts including Mutual Funds/Exchange Traded Funds registered under SEBI
(Mutual Fund) Regulations and Companies. Joint deposits of two or more eligible
depositors can be made on the same basis as other joint deposit accounts and
with nomination facility. The Broad features of the Gold Monetization Scheme are
summarised in Appendix XI of the Guidance Note.
Procedural Aspects
3.36 Some banks use a single application form for opening various types of
accounts, viz., Savings, Current and Term Deposits while some others adopt
the system whereby, for each type of account, a different type of form is used.
The form essentially provides for particulars of the account holder(s), mode of
operation on the account, term of the deposit (if applicable), signatures of the
account holder(s), photograph of the account holder(s) etc. In the case of
partnership firms, a copy of the partnership deed and in the case of companies,
copies of the memorandum and articles of association, certificate of
incorporation and resolution passed by the board for opening the
account/making the deposit are obtained. Particulars of all new accounts
opened are recorded in a register.
Know Your Customer Requirements (KYC)
3.37 Reserve Bank of India vide its master direction no. RBI/DBR/2015-
16/18DBR.AML.BC.No.81/14.01.001/2015-16 updated as on April 20, 2018 on
"Know Your Customer (KYC) norms/Anti-Money Laundering (AML)
standards/Combating Financing of Terrorism (CFT)/Obligation of banks and
financial institutions under PMLA, 2002" has laid down certain guidelines to
prevent banks from being used, intentionally or unintentionally, by criminal
elements for money laundering or terrorist financing activities. The guidelines
prescribed in this circular, popularly known as KYC guidelines, also enable
banks to know/understand their customers and their financial dealings better
which in turn help them manage their risks prudently.
These guidelines contain detailed requirements for banks in respect of
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customer acceptance policy, customer identification procedures, monitoring of
transactions and risk management.
Audit Approach and Procedures
Borrowings
3.38 Where borrowings are shown by branch, the auditor must ensure that
the borrowings/refinance:
i) is separately disclosed as required by law;
ii) balance confirmation certificates are obtained in evidence of borrowings
from each lender; and
iii) the nature and extent of security is determined and disclosed.
3.39 The auditor should understand process of new borrowing, repayment
of borrowings and test controls around these processes.
3.40 Borrowings from RBI, other banks/financial institutions, etc., should be
verified by the auditor with reference to confirmation certificates and other
supporting documents such as, application form, sanction letter, agreements,
interest rate, security, correspondence, etc. Audit evidence in the form of
external confirmations received directly by the auditor from appropriate
confirming parties / lenders may assist the auditor in obtaining audit evidence
that the auditor requires to respond to significant risks of material
misstatement. The auditor is required to comply with the requirements of
Standard on Auditing (SA) 505, "External Confirmations" which contains
guidance on designing and performing external confirmation procedures to
obtain relevant and reliable audit evidence.
3.41 The auditor should also examine whether a clear distinction has been
made between `rediscount' and `refinance' for disclosure of the amount under
the above head since rediscount does not figure under this head.
3.42 The auditor should examine whether borrowings of money at call and
short notice are properly authorised. The rate of interest paid/payable on, as
well as duration of such borrowings should also be examined by the auditor.
3.43 The auditor should similarly examine the relevant correspondence or
other documents to verify whether the branch has been authorised by the head
office to borrow/retain other borrowings and that the terms on which borrowings
have been made are in accordance with the authorisation.
3.44 The auditor should examine whether the amount shown in the branch
accounts is properly classified based on security or otherwise.
3.45 In case of borrowing through bonds and debentures, generally banks
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appoint the registrar for maintenance of records of borrowing such as bond
holders etc. The auditor can obtain the balance confirmation from registrar of
the bonds including other parameters of borrowing at each period end.
Deposits
3.46 In carrying out audit of deposits and liabilities, the auditor is primarily
concerned with obtaining reasonable assurance that all known liabilities are
recorded and stated at appropriate amounts.
The auditor may verify various types of deposits in the following manner.
Current Accounts
3.47 The auditor should verify the balances in individual accounts on a test
check basis and should also examine whether the balances as per subsidiary
ledgers tally with the related control accounts in the General Ledger. In case of
any differences, the auditor should examine the reconciliation prepared by the
branch in this regard.
3.48 Some banks have a procedure for obtaining confirmation of balances
periodically. The auditor should examine whether the procedure laid down in
this behalf has been followed consistently throughout the year. He should also
examine, on a test check basis, the confirmations received.
3.49 The auditor should examine whether the debit balances in current
accounts are not netted out on the liabilities side but are appropriately included
under the head `Advances'.
3.50 Inoperative accounts are a high risk area of frauds in banks. While
examining current accounts, the auditor should specifically cover in his sample
some of the inoperative accounts revived / closed during the year. The auditor
should also ascertain whether inoperative accounts are `revived' only with
proper authority. For this purpose, the auditor should identify cases where
there has been a significant reduction in balances compared to the previous
year and examine the authorisation for withdrawals. Ratio analysis and
comparatives can be used to select / identify such variation.
Savings Bank Deposits
3.51 The auditor should verify the balances in individual accounts on a test
check basis and should also examine whether the balances as per subsidiary
ledgers tally with the related control accounts in the General Ledger. In case of
any differences, the auditor should examine the reconciliation prepared by the
branch in this regard.
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3.52 The auditor should also check the calculation of interest on a test
check basis. In case of branch under Core Banking Solution (CBS) the product
sheet for calculation of interest on saving bank accounts can be obtained in
selected sample and auditor can verify the calculation.
3.53 Similar to in-operative current accounts, the auditor should pay special
attention to inoperative savings bank accounts.
Term Deposits
3.54 While evaluating the internal controls over term deposits, the auditor
should specifically examine whether the deposit receipts and cash certificates
are issued serially and all of them are accounted for in the registers. The
auditor should also satisfy himself that there is a proper control over the
unused forms of deposit receipts and cash certificates to prevent their misuse.
3.55 As stated earlier, the rate of interest on Certificates of Deposits (CDs)
is negotiable with the depositor. This area is quite sensitive. The auditor should
bear this fact in mind while examining the efficacy of prescribed internal
controls with regard to rates of interest on CDs.
3.56 The auditor should verify the deposits with reference to the relevant
registers. The auditor should also examine, on a test check basis, the registers
with the counter-foils of the receipts issued and with the discharged receipts
returned to the bank. The reconciliation of subsidiary records for various types
of term deposits with the related control accounts in the General Ledger should
be examined. The auditor should also examine whether provision has been
made for interest accrued on the deposits up to the date of the balance sheet.
Auditor should also examine whether the proper provision for interest payable
on deposits is made.
3.57 In some cases, banks employ some persons as `collectors' to collect
the deposits from depositors, e.g., in case of recurring deposits. In such cases,
the auditor should specifically examine the efficacy of the internal control
procedures for reconciling the records of the bank with those of the collectors.
3.58 Term deposits from banks are usually (though not necessarily) in
round figures. Any odd balances in term deposits should therefore be selected
by the auditor for verification on a sample basis.
3.59 If a Fixed Deposit Receipt matures and proceeds are unpaid, the
amount left unclaimed with the bank will attract savings bank rate of interest as
given in Para 3.4 of the Master Circular on Interest Rates on Rupee Deposits
held in Domestic, Ordinary Non-Resident (NRO) and Non-Resident (External)
(NRE) Accounts.
Deposits Designated in Foreign Currencies
3.60 In the case of deposits designated in a foreign currency, e.g., foreign
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currency non-resident deposits, the auditor should examine whether they have
been converted into Indian rupees at the rate notified in this behalf by the head
office. The auditor should also examine whether any resultant increase or
decrease has been taken to the profit and loss account. It may also be seen
that interest on deposits has been paid on the basis of 360 days in a year:
i) For deposits up to one year, at the applicable rate without any
compounding effect.
ii) In respect of deposits for more than 1 year, the interest on FCNR (B)
deposits should be calculated at intervals of 180 days each and thereafter
for remaining actual number of days, till normal maturity.
Further, in case of conversion of FCNR (B) deposits into NRE deposits or vice
versa before maturity has been subjected to the provisions relating to
premature withdrawal.
Interest Accrued But Not Due
3.61 The auditor should examine that interest accrued but not due on
deposits is not included under the relevant deposits but is shown under the
head `other liabilities and provisions'.
Overall Reconciliation
3.62 The procedures of banks usually provide for periodic correlation of
outstanding deposits with the cost of deposits. The auditor should ascertain
from the management whether such an exercise has been carried out and if
so, he should review the same. The auditor should examine that interest
accrued but not due has also been considered for this purpose.
Inoperative Accounts
3.63 Internal controls over inoperative accounts, is imperative. A response to
the letter addressed to the Branch will assist the auditor to take a view on the
system of dealing with inoperative Accounts. Attention needs to be sharply
focused on debits/withdrawals to ascertain whether these are unauthorised. In
testing the debits, attention should be specially paid to large and repetitive debits
out of otherwise dormant accounts. Centralisation of these needs to be
encouraged and such a recommendation needs to be made through the LFAR.
3.64 While scrutinising deposit ledgers, it is appropriate to ensure whether
there are any stagnant/ inoperative accounts, which remain to be transferred.
Computer generated exception reports will also reveal the status of the
inoperative accounts.
Window-dressing
3.65 There are several ways in which the deposits of a bank may be
inflated for purposes of balance sheet presentation. For example, some of the
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constituents may be allowed overdraft on or around the date of the balance
sheet, the overdrawn amounts may be placed as deposits with the bank, and
further advances may be given on the security of the deposit receipts, thus
inflating deposits as well as advances. The transactions may be reversed
immediately after the close of the year. Where the auditor comes across
transactions, which indicate the possibility of window-dressing, he may report
the same in his long form audit report. In appropriate cases, the auditor should
consider making a suitable qualification in his main audit report also.
3.66 Unauthorised Deposits, particularly, during the period that deposits of
demonetized currency notes were allowed, comprise the bank's liability and can
be treated as Deposits, pending completion of any enquiry/investigation, with the
safeguards the bank may take to avoid any wrongful claim thereon. The auditor
may consider reporting the same in the LFAR by way of information.
Know Your Customers Norms
3.67 RBI has issued instructions to all banks to implement without fail
certain procedural norms on KYC. Failure would attract levy of penalty and if
penalty has been levied the same is to be disclosed in the notes to accounts. In
view of the nature of the directive the audit procedure may be suitably adopted
to enquire the system of implementation and review of other reports in respect
of this area. The auditor should examine that there exists proper procedure in
place to ensure that framework relating to `Know Your Customer' and Anti-
Money Laundering measures is formulated and put in place by the bank.
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IV-4
Other Liabilities and
Provisions
Balance Sheet Disclosure
4.01 The Third Schedule to the Banking Regulation Act, 1949, requires
disclosure of the following items under the head `Other Liabilities and
Provisions':
(a) Bills payable (c) Interest accrued
(b) Inter-office adjustments (net) (d) Others (including provisions)
Bills Payable
4.02 Bills payable represent instruments issued by the branch against
moneys received from customers, which are to be paid to the customer or as
per his order (usually at a different branch). These include demand drafts,
telegraphic transfers, mail transfers, traveller's cheques, pay-orders, banker's
cheques and similar instruments issued by the bank but not presented for
payment till the balance sheet date.
Inter-office Adjustments
4.03 The balance in inter-office adjustments account, if in credit, is to be
shown under this head. Chapter 11 "Inter-office Transactions" of Part III of the
Guidance Note on Audit of Banks, 2019 edition (Section A Statutory Central
Audit) provides the detailed guidelines on the aspects of Inter-office
Transactions. Further at branch SBA should take the confirmation from the
Head Office regarding the Inter-office adjustment account and its reconciliation
Interest Accrued
4.04 Interest due and payable and interest accrued but not due on deposits
and borrowings are to be shown under this head. The interest accrued in
accordance with the terms of the various types of deposits and borrowings are
considered under this head. Such interest is not to be clubbed with the figures
of deposits and borrowings shown under the head `Deposits and Borrowings'.
Further auditor should check provisioning of interest on Matured Term
Deposits.
Guidance Note on Audit of Banks (Revised 2019)
Others (Including Provisions)
4.05 According to the Notes and Instructions for compilation of balance
sheet and profit and loss account, issued by the RBI, the following items are to
be included under this head:
(a) Net provision for income tax and other taxes like interest tax, less
advance payment and tax deducted at source.
(b) Surplus in bad and doubtful debts provision account (such surplus is in
the nature of a reserve).
(c) Surplus in provisions for depreciation in securities (such surplus is in the
nature of a reserve).
(d) Contingency funds, which are actually in the nature of reserves but are
not disclosed as such.
(e) Proposed dividend/transfer to Government.
(f) Other liabilities, which are not disclosed under any of the major heads
such as unclaimed dividend, provisions and funds kept for specific
purposes, unexpired discount, outstanding charges like rent, conveyance,
etc. and tax deduction by bank payable on or before the due date.
(g) Certain types of deposits like staff security deposits, margin deposits,
etc., which are repayable only subject to compliance with certain
conditions. (The interest on such deposits would also be included under
this head).
(h) Blocked Account arising from transfer of credit entries in inter-branch
accounts outstanding for more than five years.
4.06 Besides the above items, the following are other important items
usually included under this head:
(a) Collections in respect of suit-filed accounts. These are not adjusted
against advances till final settlement. (However, for the purpose of
provisioning against non-performing advances, such credit balances are
taken into account for ascertaining net outstanding).
(b) Collection of income-tax on behalf of the Government.
(c) Collection from DICGC. These are carried till final realisation/write-off of
the concerned advance account.
(d) Provisions for frauds. These are ultimately adjusted by way of a write-off.
(e) Insurance claims received in respect of frauds. These are retained
separately till final write-off in respect of fraud.
(f) Provision for gratuity, pension and other staff benefits.
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Other Liabilities and Provisions
(g) Provision for bank's share in the expenses of the Banking Services
Recruitment Board.
(h) Provision for audit fees.
(i) Unamortized interest income on the bills purchased/ discounted.
4.07 It may be noted that many of the items to be disclosed under this head
are accounted for at the head office level and would not therefore form part of
balance sheet of a branch.
Audit Approach and Procedures
4.08 The auditor may verify the various items under the head `other
liabilities and provisions' in the following manner.
Bills Payable
4.09 The auditor should evaluate the existence, effectiveness and
continuity of internal controls over bills payable. Such controls should usually
include the following:
(a) Demand drafts, mail transfers, traveller's cheques, etc., should be made
out in standard printed forms.
(b) Unused forms relating to demand drafts, traveller's cheques, etc., should
be kept under the custody of a responsible officer.
(c) The bank should have a reliable private code known only to the
responsible officers of its branches coding and decoding of the
telegrams12 should be done only by such officers.
(d) The signatures on a demand draft should be checked by an officer with
the specimen signature book.
(e) All the telegraphic transfers and demand drafts issued by a branch should
be immediately confirmed by advices to the branches concerned. On
payment of these instruments, the paying branch should send a debit
advice to the originating branch.
(f) If the paying branch does not receive proper confirmation of any
telegraphic transfers or demand draft from the issuing branch, it should
take immediate steps to ascertain the reasons.
(g) In case an instrument prepared on a security paper, e.g., demand draft,
has to be cancelled (say, due to error in preparation), it should be
examined whether the manner of cancellation is such that the instrument
cannot be misused. (For example, in the case of demand drafts, banks
12Telegrams has been discontinued since 15th July, 2013 and this is now just for academic
purposes.
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generally cut the distinctive serial number printed on the form and paste it
in the book in which demand drafts issued are entered.) Cases of
frequent cancellation and re-issuance of demand drafts, pay orders, etc.,
should be carefully looked into by a responsible official.
4.10 Based on auditor's evaluation of the efficacy of the relevant internal
controls, the auditor should examine an appropriate sample of outstanding
items comprised in bills payable accounts with the relevant registers. Reasons
for old outstanding debits in respect of drafts or other similar instruments paid
without advice should be ascertained. Correspondence with other branches
after the year-end (e.g., responding advices received from other branches,
advices received from other branches in respect of drafts issued by the branch
and paid by the other branches without advice) should also be examined
specially in so far as large value items outstanding on the balance sheet date
are concerned.
Others (Including Provisions)
4.11 It may be noted that the figure of advances and investments in the
balance sheet of a bank excludes provisions in respect thereof made to the
satisfaction of auditors. The issue of determining the adequacy of provision for
doubtful advances is discussed in detail under Chapter on Assets
Classification, Income Recognition and Provisioning of the Guidance Note. The
auditor should examine other provisions and other items of liabilities in the
same manner as in the case of other entities. Specifically, in case of tax
deducted by the bank and payable to the government authorities on or before
the due date, this function may be centralized or de-centralized. While verifying
this, the auditor must check whether tax has been correctly deducted from
payments as per the provisions of the Income Tax Act, 1961 and paid on or
before the due date as specified under the Act or Rules thereunder. Many a
times in case of branch audit, reporting has to be done before the due date of
paying tax deducted at source for the month of March. In such cases the
auditor should report delays observed till the date of his verification and clearly
bring out the fact that he has not verified the payment of tax, due date of which
would be after the date of the audit report.
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IV-5
Contingent Liabilities and
Bills for Collection
Introduction
Contingent Liabilities
5.01 The term `contingent liabilities' can take two forms. On the one
hand, a contingent liability refers to possible obligations arising from past
transactions or other events or conditions, the existence of which will be
confirmed only by the occurrence or non-occurrence of one or more uncertain
future events not wholly within the control of the enterprise. On the other
hand, a contingent liability may also take form of a present obligation that
arises from past events or transactions but is not recognised due to the fact
that either it is not probable that an outflow of resources embodying
economic benefits will be required to settle the obligation, or a reliable
estimate of the amount of obligation cannot be made. Thus, contingent
liabilities may or may not crystallise into actual liabilities. If they do become
actual liabilities, they give rise to a loss or an expense. The uncertainty as to
whether there will be any obligation differentiates a contingent liability from a
liability that has crystallised. Contingent liabilities should also be
distinguished from those contingencies which are likely to result in an
obligation on the entity (i.e., the obligation is not merely possible but
probable) and which, therefore, require creation of a provision in the financial
statements. (Members may refer to Accounting Standard (AS) 29,
"Provisions, Contingent Liabilities and Contingent Assets")
Letter of Credit, Bank Guarantees and Letters of Comfort, Letter of
Undertaking13
5.02 The concepts of Letters of Credit, Bank Guarantees and Letters of
Comfort, Letter of Undertaking have been discussed in the Chapter 2 "Advances
- Other than Agriculture" of Part III of the Guidance Note.
Liability on Partly Paid Investments
13
The reserve bank of India has issued circular dated March 13, 2018, to discontinue the practice
of issuance of LoUs/ LoCs for Trade Credits for imports into India by AD Category I banks with
immediate effect.
Guidance Note on Audit of Banks (Revised 2019)
5.03 If the bank holds any partly paid shares, debentures, etc., the auditor
should examine whether the uncalled amounts thereof are shown as
contingent liability in the balance sheet.
Liability on Account of Outstanding Forward Exchange Contracts
and Derivatives Contract
5.04 All branches which undertake foreign exchange business (i.e., those
which are authorised foreign exchange dealers) usually enter into forward
exchange contracts. The amount of forward exchange contracts, which are
outstanding on the balance sheet date, is to be shown under this head. The
treasury of the bank enters into derivatives contracts like Interest Rate Swap,
Cross currency Swaps, etc. The notional amount of these contracts should
be disclosed either separately or under this head as separate sub head.
Guarantees Given on Behalf of Constituents
5.05 The amount of all guarantees outstanding on the balance sheet is to
be shown under the above head after deducting therefrom any cash margin.
Acceptances, Endorsements and Other Obligations
5.06 This item includes the following balances:
(a) letters of credit opened by the bank on behalf of its customers; and
(b) Bills drawn by the bank's customers and accepted or endorsed by the
bank (to provide security to the payees).
5.07 The total of all outstanding letters of credit as reduced by the cash
margin and after deducting the payments made for the bills negotiated under
them should be included in the balance sheet. In case of revolving credit, the
maximum permissible limit of letters of credit that may remain outstanding at
any point of time as reduced by the cash margin should be shown. If the
transactions against which the letter of credit was opened have been
completed and the liability has been marked off in the books of the bank, no
amount should be shown as contingent liability on this account.
Other Acceptances and Endorsements
5.08 Sometimes, a customer of the bank may issue a usance bill payable to
his creditor and drawn on the bank. The bank, on accepting such a bill, becomes
liable to pay it on maturity. In turn, it has to recover this amount from its
customer.
5.09 The total of all outstanding acceptances and endorsements at the end
of the year, as reduced by the cash margin, should be disclosed as contingent
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liability.
Other Items for Which the Bank is Contingently Liable
5.10 Under this head are to be included such items as arrears of unpaid
dividend on cumulative preference shares bills re-discounted, commitments
under underwriting contracts, estimated amounts of contracts remaining to be
executed on capital account, disputed tax liabilities, credit enhancement in
respect of securitised loans to which the assignee or the special purpose vehicle
has recourse, etc.
5.11 Underwriting involves an agreement by the bank to subscribe for the
shares or debentures which remain unsubscribed in a public issue, in
consideration of commission.
5.12 Rediscounting is generally done with the RBI, or other financial
institutions or, in the case of foreign bills, with foreign banks. If the drawer
dishonours the bill, the re-discounting bank has a right to proceed against the
bank as an endorser of the bill.
5.13 Tax demands, which has been disputed are in the nature of contingent
liability and should be disclosed. Where an application for rectification of mistake
has been made by the entity, the amount should be regarded as disputed. Where
the demand notice/intimation for the payment of tax is for a certain amount and
the dispute relates to only a part and not the whole of the amount, only such
amount should be treated as disputed. A disputed tax liability may require a
provision or suitable disclosure as per provisions of Accounting Standard (AS)
29, "Provisions, Contingent Liabilities and Contingent Assets".
5.14 Disputed tax liabilities in respect of income-tax and similar central taxes
would not form part of balance sheet of a branch as these items are dealt with at
the head office level.
5.15 The liability involved in cases lodged against the bank in various courts
including consumer dispute redressal forums, Banking Ombudsman as per
Reserve Bank of India and any other Authority are in the nature of contingent
liability and should be disclosed.
5.16 Depositor Education and Awareness Fund : As per RBI circular dated
RBI/2013-14/ 614 DBOD. No. DEAF Cell. BC. 114/ 30.01.002/ 2013-14 dated
May 27, 2014, all such unclaimed liabilities (where amount due has been
transferred to DEAF) may be reflected as "Contingent Liability Others, items for
which the bank is contingently liable" under Schedule 12 of the annual financial
statements.
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Bills for Collection
5.17 Bills held by a bank for collection on behalf of its customers are to be
shown as a footnote to the balance sheet.
5.18 These bills are generally hundies or bills of exchange accompanied by
documents of title to goods. Frequently, no bills of exchange are actually drawn;
the bank is asked to present invoices and documents of title with instructions to
collect the amount thereof from the party in whose name the invoice has been
made. The documents of title enclosed with the bills for collection are usually not
assigned to the bank.
5.19 A bank may get bills for collection from -
(a) its customers, drawn on outstation parties; or
(b) its other branches or other outstation banks or parties, drawn on local
parties.
5.20 On receipt of the bills drawn on outstation parties, the bank forwards
them to its branch or other correspondent at the place where they are to be
collected. Such bills are called Outward Bills for Collection.
5.21 Bills received by the bank from its outstation branches and agents, etc.
for collections are called Inward Bills for Collection.
5.22 It may be noted that if a bill is received by one branch of the bank from a
customer and sent by it to another branch of the bank for collection, the same bill
will be shown as an Outward Bill at the first branch and as an Inward Bill at the
other branch. In the consolidated balance sheet of the bank, however, all such
bills should be shown only once. Therefore, Inward Bills for Collection are
excluded from the balance sheet of each branch.
Co-acceptance of Bills
5.23 In its Master Circular No. RBI/2015-16/76 DBR. No. Dir.
BC.11/13.03.00/2015-16 dated July 1, 2015 on "Guarantees and Co-
acceptances", the RBI had reiterated the need for the banks to be cautious
while co-accepting bills of their customers and discounting the same so as to
avoid loss to banks arising on account of frauds perpetrated in the guise of
bills. The circular requires the banks, inter alia, not to extend their co-
acceptances to house bills/ accommodation bills drawn by group concerns on
one another. In the circular, the RBI had also listed a number of safeguards
to be undertaken by banks while co-accepting bills.
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Audit Approach and Procedures
Contingent Liabilities
5.24 In respect of contingent liabilities, the auditor is primarily concerned
with seeking reasonable assurance that all contingent liabilities are identified
and properly valued. To this end, the auditor should, generally follow the audit
procedures given below:
(a) The auditor should verify whether there exists a system whereby the non-
fund based facilities to parties are extended only to their regular
constituents, etc.
(b) Ascertain whether there are adequate internal controls to ensure that
transactions giving rise to contingent liabilities are executed only by
persons authorised to do so and in accordance with the laid down
procedures.
(c) The auditor should also examine whether in case of LCs for import of
goods, as required by the abovementioned Master Circular on
guarantees and co-acceptances, the payment to the overseas suppliers
is made on the basis of shipping documents and after ensuring that the
said documents are in strict conformity with the terms of LCs.
(d) Ascertain whether the accounting system of the bank provides for
maintenance of adequate records in respect of such obligations and
whether the internal controls ensure that contingent liabilities are properly
identified and recorded.
(e) Performs substantive audit tests to establish the completeness of the
recorded obligations. Such tests include confirmation procedures as well
as examination of relevant records in appropriate cases.
(f) Review the reasonableness of the year-end amount of contingent
liabilities in the light of previous experience and knowledge of the current
year's activities.
(g) Review whether comfort letters issued by the bank has been considered
for disclosure of contingent liabilities.
(h) The auditor should also examine whether the bank has given any
guarantees in respect of any trade credit (buyer's credit or seller's
credit)14. The period of guarantees is co-terminus with the period of credit
reckoned from the date of shipment.
14 In terms of the Circular No. A.P. (Dir. Series) 60 dated January 31, 2004, any trade credit
extended for a period of three years and above comes under the category of external commercial
borrowings.
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(i) Verify whether the bank has extended any non-fund facility or
additional/ad hoc credit facilities to persons other than its regular
customers. In such cases, auditor should examine the existence of
concurrence of existing bankers of such borrowers and enquire regarding
financial position of those customers.
(j) If the Bank is using separate application for communicating, transacting,
executing any coacceptance / guarantees, the auditor should verify the
interface controls in respect of these applications and CBS. If the system-
based interface is not available and manual intervention is involved then
Auditor should verify controls put in place by Bank for confirming
completeness and correctness of transactions.
(k) Obtain representation from the management that:
(i) all contingent liabilities have been disclosed;
(ii) the disclosed contingent liabilities do not include any
contingencies which are likely to result in a loss/ expense and
which, therefore, require creation of a provision in the financial
statements;
(iii) the estimated amounts of financial effect of the contingent
liabilities are based on the best estimates in terms of Accounting
Standard 29, including any possibility of any reimbursement;
(iv) in case of guarantees issued on behalf of the bank's directors, the
bank has taken appropriate steps to ensure that adequate and
effective arrangements have been made so that the commitments
would be met out of the party's own resources and that the bank
will not be called upon to grant any loan or advances to meet the
liability consequent upon the invocation of the said guarantee(s)
and that no violation of section 20 of the Banking Regulation Act,
1949 has arisen on account of such guarantee; and
(v) such contingent liabilities which have not been disclosed on
account of the fact that the possibility of their outcome is remote
include the management's justification for reaching such a
decision in respect of those contingent liabilities.
5.25 The specific procedures to be employed by the auditor to verify
various items of contingent liabilities are discussed in the following paragraphs.
It may be noted that many of the items discussed in the following paragraphs,
may be designated in foreign currencies.
Claims Against the Bank Not Acknowledged as Debts
5.26 The auditor should examine the relevant evidence, e.g.,
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Contingent Liabilities and Bills for Collection
correspondence with lawyers/others, claimants, workers/officers, and
workmen's/officers' unions. The auditor should also review the minutes of
meetings of board of directors/committees of board of directors, contracts,
agreements and arrangements, list of pending legal cases, and
correspondence relating to taxes, and duties, etc., to identify claims against the
bank. The auditor should ascertain from the management the status of claims
outstanding as at the end of the year. A review of subsequent events would
also provide evidence about completeness and valuation of claims. Based on
the circumstances of each case, the auditor should verify whether the item
would remain a claim against the bank not acknowledged as debt or it would be
a liability requiring provisioning. The auditor may ask for an opinion from
empanelled lawyer of the Bank in respect of crystalisation of claim against the
Bank. The auditor should use professional judgement to determine as to which
claims can be construed as a contingent liability and which needs to be
provided.
Liability on Account of Outstanding Forward Exchange Contracts &
Derivatives Contracts
5.27 Forward Exchange Contract: The auditor may verify the outstanding
forward exchange contracts with the register maintained by the branch and
with the broker's advice notes. In particular, the net "position" of the branch in
relation to each foreign currency should be examined to see that the position is
generally squared and not uncovered by a substantial amount. The net
"position" as reported in the financial statements may be verified with reference
to the foreign exchange position report prepared by the back office.
5.28 Derivatives Contract: The auditor may verify outstanding derivatives
contracts (options, cross currency swaps, interest rate swaps, etc.) with report
generated from treasury application. The `notional' amount of these derivatives
contracts should be shown as contingent liability in financial statements.
Guarantees Given on Behalf of Constituents
5.29 The auditor should ascertain whether there are adequate internal
controls over issuance of guarantees, e.g., whether guarantees are issued
under proper sanctions, whether adherence to limits sanctioned for guarantees
is ensured, whether margins are taken from customers before issuance of
guarantees as per the prescribed procedures, etc.
5.30 The auditor should ascertain whether there are adequate controls over
unused guarantee forms, e.g., whether these are kept under the custody of a
responsible official, whether a proper record is kept of forms issued, whether
stock of forms is periodically verified and reconciled with the book records, etc.
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5.31 The auditor should examine the guarantee register to seek evidence
whether the prescribed procedure of marking off the expired guarantees is
being followed or not.
5.32 The auditor should check the relevant guarantee registers with the list
of outstanding guarantees to obtain assurance that all outstanding guarantees
are included in the amount disclosed in this behalf. The auditor should also
examine that expired guarantees are not included in this head. He should verify
guarantees with the copies of the letters of guarantee issued by the bank and
with the counter-guarantees received from the customers. He should also
verify the securities held as margin. If a claim has arisen, the auditor should
consider whether a provision is required in terms of the requirements of AS 29,
"Provisions, Contingent Liabilities and Contingent Assets".
5.33 The auditor should obtain a written confirmation from the management
that all obligations in respect of guarantees have been duly recorded and that
there are no guarantees issued upto the year-end which are yet to be
recorded. Many a times it is observed that in certain cases, old and expired
bank guarantees are not cancelled from the records. This would result in
excess capital adequacy provisioning for the bank. Also, it should be confirmed
that the margins are recorded at their proper value including the interest
accrued. The auditor should verify the Bank Guarantee register for the
purpose.
Acceptances, Endorsements and Other Obligations
5.34 The auditor should evaluate the adequacy of internal controls over
issuance of letters of credit and over custody of unused LC forms in the same
manner as in the case of guarantees.
5.35 The auditor should verify the balance of letters of credit from the
register maintained by the bank. The register indicates the amount of the
letters of credits and payments made under them. The auditor may examine
the guarantees of the customers and copies of the letters of credit issued. The
security obtained for issuing letters of credit should also be verified.
Other Acceptances and Endorsements
5.36 The auditor should study the arrangements made by the bank with its
customers. He should test check the amounts of the bills with the register
maintained by the bank for such bills. The auditor should also examine whether
such bills are marked off in the register on payment at the time of maturity.
5.37 In respect of letters of comfort, the auditor should examine whether
the bank has incurred a potential financial obligation under such a letter. If a
comfort letter does not cast any such obligation on the bank, no disclosure
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Contingent Liabilities and Bills for Collection
under contingent liability is required on this account.
Common Procedures
5.38 The auditor should obtain a written confirmation from the management
that all obligations assumed by way of acceptances, endorsements and letters
of credit have been duly recorded and there are no such obligations assumed
upto the year-end, which are yet to be recorded.
5.39 The auditor should ascertain whether a contingent obligation assumed
by a bank either by way of acceptance, endorsement etc., has resulted in an
actual obligation owing to any act or default on the part of its constituent. In
such a case, a provision would have to be made in the accounts for the bank's
obligation. The amount of the provision should be determined taking into
account the probable recovery from the customer.
Other Items for Which the Bank is Contingently Liable
5.40 The auditor should examine whether commitments under all
outstanding underwriting contracts have been disclosed as contingent
liabilities. For this purpose, the auditor should examine the terms and
conditions of the relevant contracts.
5.41 Rediscounting is generally done with the RBI, Industrial Development
Bank of India or other financial institutions or, in the case of foreign bills, with
foreign banks. If the drawer dishonours the bill, the rediscounting bank has a
right to proceed against the bank as an endorser of the bill. The auditor may
check this item from the register of bills rediscounted maintained by the branch.
He should satisfy himself that all the bills are properly marked off on payment
at the time of maturity.
5.42 In respect of disputed tax demands, the auditor should examine
whether there is a positive evidence or action on the part of the bank to show
that it has not accepted the demand for payment of tax or duty. Where an
application for rectification of mistake has been made by the entity, the amount
should be regarded as disputed. Where the demand notice/intimation for the
payment of tax is for a certain amount and the dispute relates to only a part
and not the whole of the amount, only such amount should be treated as
disputed. A disputed tax liability may require a provision or suitable disclosure
as per provisions of AS 29, "Provisions, Contingent Liabilities and Contingent
Assets". In determining whether a provision is required, the auditor should,
among other procedures, make appropriate inquiries with management, review
minutes of the meetings of the board of directors and correspondence with the
entity's lawyers, judgments on similar matters of other banks and obtain
appropriate management representations.
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5.43 Disputed tax liabilities in respect of income-tax and similar central
taxes would not form part of balance sheet of a branch as these items are dealt
with at the head office level. However, the principles enunciated above should
be followed in dealing with taxes and duties (such as, local taxes) dealt with at
the branch level.
5.44 The auditor should check whether any liability is involved in cases
lodged against the bank.
5.45 The auditor may verify other items under this head in the same
manner as in case of other entities.
Bills for Collection
5.46 The auditor should examine whether the bills drawn on other branches
of the bank are not included in bills for collection.
5.47 Inward bills are generally available with the bank on the closing day
and the auditor may inspect them at that time. The bank dispatches outward
bills for collection soon after they are received. They are, therefore, not likely to
be in hand at the date of the balance sheet. The auditor may verify them with
reference to the register maintained for outward bills for collection.
5.48 The auditor should also examine collections made subsequent to the
date of the balance sheet to obtain further evidence about the existence and
completeness of bills for collection.
5.49 Regarding bills for collection, the auditor should also examine the
procedure for crediting the party on whose behalf the bill has been collected.
The procedure is usually such that the customer's account is credited only after
the bill has actually been collected from the drawee either by the bank itself or
through its agents, etc. This procedure is in consonance with the nature of
obligations of the bank in respect of bills for collection.
5.50 The commission of the branch becomes due only when the bill has
been collected. The auditor should, accordingly, examine that there exists
adequate internal control system that debits the customer's account with the
amount of bank's commission as soon as a bill collected is credited to the
customer's account. The auditor should also examine that no income has been
accrued in the accounts in respect of bills outstanding on the balance sheet
date.
Co-acceptance of Bills
5.51 The auditor should examine whether the bank has instituted an
adequate internal control system to comply with the safeguards as set out by
the RBI's Master Circular No. RBI/2015-16/76 DBR. No. Dir.
BC.11/13.03.00/2015-16 dated July 1, 2015 on "Guarantees and Co-
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acceptances" to ascertain whether such system, inter alia, captures all such
items, appropriately records the same and also determines all the material items
forming contingent liabilities, whether any item needs a provision in the books.
Disclosures
Balance Sheet Disclosure
5.52 The Third Schedule to the Banking Regulation Act, 1949, requires
the disclosure of the following as a footnote to the balance sheet.
(a) Contingent Liabilities
I. Claims against the bank not acknowledged as debts
II. Liability for partly paid investments
III. Liability on account of outstanding forward exchange contracts &
Derivatives Contracts
IV. Guarantees given on behalf of constituents
(a) In India
(b) Outside India
V. Acceptances, endorsements and other obligations
VI. Other items for which the bank is contingently liable
(b) Bills for Collection
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IV-6
Profit and Loss Account
6.01 Subsection (1) of section 29 of the Banking Regulation Act, 1949,
requires the preparation of Profit and Loss Account in Form B of Third Schedule
to the Act or as near thereto as the circumstances admit. This subsection is
applicable to Banking Companies, Nationalised Banks, State Bank of India and
its Subsidiaries, and Regional Rural Banks.
Disclosures
6.02 The Profit and Loss Account as set out in Form B has four broad heads:
Income
Expenditure
Profit/ Loss
Appropriations
The information to be provided under each of the above heads is also specified
in the Schedule. It would be pertinent to note that knowledge of the Bank's
accounting policies is of utmost importance before verifying the items within the
profit and loss account. The auditor must make enquiries with the management
to ascertain whether there have been any changes in the accounting policies and
also review the closing circulars issued by the controlling authorities of the Bank.
Applicability of AS 5 and Materiality
6.03 Accounting Standards are intended to apply only to items that are
material. Since materiality is not objectively defined, RBI, vide its Circular No.
DBOD. No.BP. BC. 89 /21.04.018/2002-03 dated March 29, 2003 on "Guidelines
on compliance with Accounting Standards (AS) by banks", has advised that all
banks should ensure compliance with the provisions of accounting standards in
respect of any item of prior period income or expenditure, which exceeds one per
cent of total income/ total expenditure of the bank if the income or expenditure is
reckoned on gross basis or one per cent of the net profit before taxes or net
losses as the case may be if the income is reckoned on net of costs.
6.04 Since the format of the profit and loss accounts of banks prescribed in
Form B under Third Schedule to the Banking Regulation Act, 1949 does not
specifically provide for disclosure of the impact of prior period items on the
Profit and Loss Account
current year's profit and loss, such disclosures, wherever warranted, may be
made in the Notes on Accounts to the balance sheet of banks.
Income
Interest Earned
6.05 The following items are included under this head:
(a) Interest/Discount on Advances/Bills: This includes interest and discount on
all types of loans and advances like cash credit, overdrafts, demand loans,
term loans, export loans, domestic and foreign bills purchased and
discounted (including those rediscounted), overdue and penal interest and
interest subsidy, if any, relating to such advances/bills. The amount to be
included under this head is net of the share of participating banks under
interbank participation schemes on risksharing basis. In modern day
banking, the entries for interest income on advances are automatically
generated through a batch process in the CBS system.
(b) Interest Income on Investments: This will be generally dealt by treasury so
branch will not have any income under such head.
(c) Interest on Balances with RBI and Other Interbank Funds: This will be
generally dealt by treasury so branch will not have any income under such
head.
(d) Others: This includes any other interest/discount income not included in the
above heads. Interest on advances given by the bank to staff member in its
capacity as employer rather than as banker should be included under this
head.
Income from Investments
6.06 Interest and dividend on investments is usually accounted for at the
Treasury Branch of the bank. Thus, a branch will not have any income under
such head.
Other Income
6.07 The following items are included under this head:
(i) Commission, Exchange and Brokerage: This item comprises of the
following:
(a) Commission on bills for collection.
(b) Commission/exchange on remittances and transfers, e.g. demand
drafts, NEFT, RTGS, etc.
(c) Commission on letters of credit and guarantees, letter of comforts.
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(d) Loan processing, arranger and syndication fees.
(e) Mobile banking fees.
(f) Credit/Debit card fee income including annual fee income, merchant
acquiring income, interchange fees, etc.
(g) Rent from letting out of lockers.15
(h) Commission on Government business.
(i) Commission on other permitted agency business including
consultancy and other services.
(j) Brokerage on securities.
(k) Fee on insurance referral.
(l) Commission on referral of mutual fund clients.
(m) Service/transaction banking charges including charges levied for
transaction at other branches.
(n) Income from rendering other services like custodian, demat,
investment advisory, cash management and other fee based services.
(ii) Profit on sale of Land, Buildings and Other Assets: This item includes
profit (net of any loss) on sale of land, buildings, furniture, motor vehicles,
gold, silver, etc.
(iii) Profit on exchange transactions: This includes revaluation gains/losses on
forward exchange contracts and other derivative contracts, premium
income/expenses on options, etc.
(iv) Income earned by way of dividends, etc., from subsidiaries and joint
ventures abroad/in India.
(v) Miscellaneous income.
Profit/Loss on Revaluation of Property, Plant & Equipment (PPE)
6.08 According to the Notes and Instructions for compilation of profit and
loss account, issued by the RBI, the net profit/loss on revaluation of the
aforesaid assets may also be shown under this item. In this regard, the
requirements of AS 10 (Revised), Property, Plant & Equipment, relating to
revaluation of fixed assets assume significance. According to the AS 10
(Revised), when a PPE is revalued in financial statements, the entire class of
assets should be revalued, or the selection of assets for revaluation should be
made on a systematic basis. It is also provided that an increase in net book
value arising on revaluation of fixed assets should be credited directly to
15 As per the Notes and Instructions for compilation of the profit and loss account, issued by the
Reserve Bank, this item should come under this head. There is, however, a contrary view in some
quarters that locker rent should be included in miscellaneous income. The latter view seems more
plausible.
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owners' interests under the head of revaluation reserve. However, if such
increase is related to and not greater than a decrease arising on revaluation
which was previously recorded as a charge to the profit and loss account, it
may be credited to the profit and loss account. On the other hand, any
decrease in net book value arising on revaluation of fixed assets should be
charged directly to the profit and loss account except that to the extent that
such a decrease is related to an increase which was previously recorded as a
credit to revaluation reserve and which has not been subsequently reversed or
utilised, it may be charged directly to revaluation reserve account.
6.09 From the above, it can be seen that as per AS 10 (Revised), surplus
on revaluation of a fixed asset cannot be credited to the profit and loss account
except to the extent that such surplus represents a reversal of a related
previous revaluation decrease that was charged to the profit and loss account.
Profit on Exchange Transactions
6.10 This item includes profit (net of loss) on dealings in foreign exchange
and will be applicable at treasury or selected foreign designated branches.
Income Earned by Way of Dividends, etc. from Subsidiaries and Joint
Ventures abroad/in India
6.11 As investments are usually dealt with at the head office level, this item may
not appear in the profit and loss account of a branch.
Miscellaneous Income
6.12 This head generally includes following items of income:
(a) Recovery in Written off Accounts;
(b) Rental income from bank's properties;
(c) Security charges;
(d) Insurance charges recoverable from customers;
(e) Other income from carrying out other services like selling of gold coins
etc.
6.13 The Notes and Instructions for compilation of profit and loss account,
issued by the Reserve Bank, require that in case any item under this head
exceeds one per cent of the total income, particulars thereof may be given in the
notes.
Expenses
6.14 Expenditure is to be shown under three broad heads: interest
expended; operating expenses; and provisions and contingencies.
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Interest Expended
6.15 The following items are included under this head:
(a) Interest on Deposits: This includes interest paid/ payable on all types of
deposits including deposits from banks and other institutions. Usually,
the rates of term deposits of banks are amended from time to time by the
ALCO or the Board.
(b) Interest on Reserve Bank of India/ InterBank Borrowings: This includes
interest/ discount on all borrowings and refinance from the RBI and other
banks.
(c) Others: This includes discount/ interest on all borrowings/ refinance from
financial institutions. All other payments like interest on participation
certificates, penal interest paid, etc. may also be included here.
6.16 The RBI has issued Interest Rate on Deposits Directions, 2016 on
March 03, 2016 which contains `Interest Rate Framework'.
The RBI has deregulated the savings bank deposit interest rate. In other
words, the banks are free to determine their savings bank deposit interest rate.
The auditor should verify that prior approval of the Board/Asset Liability
Management Committee (if powers are delegated by the Board) has been
obtained by a bank while fixing interest rates on such deposits.
6.17 The RBI has also deregulated the interest rates on Non Resident
(External) Rupee Deposits and Ordinary Non-Resident (NRO) Accounts as
follows:
Banks are free to determine their interest rates on both savings deposits
and term deposits of maturity of one year and above under Non-Resident
(External) Rupee (NRE) Deposit accounts and savings deposits under
Ordinary Non-Resident (NRO) Accounts. However, interest rates offered
by banks on NRE and NRO deposits cannot be higher than those offered
by them on comparable domestic rupee deposits.
Prior approval of the Board/Asset Liability Management Committee (if
powers are delegated by the Board) needs to be obtained by a bank while
fixing interest rates on such deposits. At any point of time, individual banks
need to offer uniform rates at all their branches.
The revised deposit rates apply only to fresh deposits and on renewal of
maturing deposits.
Banks also need to closely monitor their external liability arising on
account of such deregulation and ensure asset-liability compatibility from
systemic risk point of view.
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6.18 The RBI has consolidated instructions pertaining to FCNR(B) deposits
by Banks. Specific consideration should be given to the ceiling on interest
rates, 360 days to a year basis for interest payment, rounding off of interest
etc. Recurring Deposits should not be accepted under the FCNR (B) Scheme.
The interest on FCNR (B) deposits should be calculated and paid at intervals of
180 days each and thereafter for the remaining actual number of days. However,
the depositor will have the option to receive the interest on maturity with
compounding effect.
Auditor should verify concurrent or internal audit reports for revenue leakages
detected but not rectified till date. Appropriate entries if necessary could be
passed.
Operating Expenses
6.19 The following items are included under this head:
(i) Payments to and Provisions for Employees: This item includes salaries and
wages of staff, allowances, bonus, other staff benefits like provident fund,
pension, gratuity, leave fare concession, staff welfare, medical allowance to
staff, etc. It may be noted that provision for terminal benefits like pension
and gratuity is usually made only at the head office level. Salaries and
allowances payable to the bank's staff and officers are usually governed by
agreement with the employee unions or awards of a judicial tribunal. The
payroll process is generally centralized in all banks. Auditors should
ascertain the control available to branch level and test check sample
working.
(ii) Rent, Taxes and Lighting: This item includes rent paid by the bank on
buildings, municipal and other taxes, electricity charges and other similar
charges and levies. Auditor should specifically review cases where rental
increases are in dispute & unpaid. Necessary provisions / disclosures
should be appropriately made. It may be noted that income-tax and interest
on tax are not to be included under this head. Similarly, house rent
allowance and other similar payments to staff would not appear under this
head.
(iii) Printing and Stationery: This item includes books and forms and stationery
used by the bank and other printing charges except those incurred by way
of publicity expenditure. While some stationery may have been purchased
by the branch, other stationery (security paper like draft forms, cheque
books) would have been received by the branch from the head office.
Auditor should specifically note the bank policy in this regard whether the
same is expensed out on purchase or on usage. In any case any unusable
or outdated stationery should be expensed out. If any Stationery is shown
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as an asset, necessary physical verifications should be done.
(iv) Advertisement and Publicity: This item includes expenditure incurred by
the bank for advertisement and publicity, including printing charges of
publicity material. Auditor should specifically review such agreements to
find out commitments made for such expenses in future periods.
(v) Depreciation on Bank's Property: This item includes depreciation on
bank's own property, motor cars and other vehicles, furniture, electrical
fittings, vaults, lifts, leasehold properties, non-banking assets, etc.
Depending on the procedure followed in the bank, provision for
depreciation may be either centralised at the head office level through
fixed asset management software or decentralized and manual at
branches and other offices. Auditor should specifically review the useful
life at the year end and provide for additional depreciation in case there is
any downward revision in the useful life. Auditor should ensure that fixed
assets are accounted from the date the asset is put to use. Necessary
accounting of the asset to be done & depreciation calculated from this
date. Generally, banks account for fixed assets on date of final payment
irrespective of the asset being put to use much earlier.
Auditor should note the process for verifying assets booked by branch but
allotted to employees & located at Bank residential premises allotted to
these employees. Auditors should verify the calculation of depreciation by
exporting the relevant report from software.
(vi) Directors' Fees, Allowances and Expenses: Expenditure incurred in this
regard is recorded under this head. This item is dealt with at the head
office level and would not therefore be relevant at the branch level.
(vii) Auditors' Fees and Expenses: Remuneration payable to Statutory Auditors
and Branch auditors and expenses in connection with audit like
reimbursements are recorded under this head. This item is usually dealt
with at the head office level and would not therefore be relevant at the
branch level.
(viii) Law Charges: All legal expenses and reimbursement of expenses incurred
in connection with legal services are to be included here. Auditor should
specifically review the Legal agreements to note future commitments for
payables. Expenses paid to advocates recovered from Borrowers by direct
debit to that account should be specifically noted for consistency in
accounting. The auditor should also co-relate law charges with the
contingent liability appearing in financial statement or with the specific
annexure/report to be certified by the Branch Auditors'.
(ix) Postage, Telegrams, Telephones, etc.: This item includes all postal
charges like stamps, telegrams, telephones, teleprinters, etc. Issuance of
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Telegrams has been discontinued since 15th July 2013 and this head is
now just for academic purposes.
(x) Repairs and Maintenance: This item includes repairs to bank's property,
their maintenance charges, etc. Amortization of such expenses should be
specifically noted.
(xi) Insurance: This item is usually dealt with at the head office level and may
not therefore be relevant at the branch level. This includes Premium paid
to DICGC, Insurance of Cash on Hand, in ATM & in transit and also
Insurance of Fixed Assets, Employee Fidelity Insurance, Fraud Covers,
Coverage for Cyber Risks. Auditor should specifically ensure that all risks
are insured adequately. Decision not to insure specific risks / assets
should be approved at appropriate Management levels & Auditor should
obtain the relevant documents for record.
(xii) Direct Marketing Expenses: These are the expenses incurred majorly for
sourcing of retails loans/credit cards and collection of retail overdue loans.
RBI circular RBI/2006/167/DBOD.NO.BP.40/21.04.158/2006-07 dated 3rd
November 2006 clearly states that activities of internal audit, compliance
function and decision making functions like compliance with KYC norms
for opening deposit accounts, according sanction for loans (including retail
loans) and management of retail loans cannot be outsourced.
(xiii) Other Expenditure: This item includes all expenses other than those
included in any of the other heads, like, license fees, donations16,
subscriptions to papers, periodicals, entertainment expenses, travel
expenses, etc. The Notes and Instructions for compilation of profit and
loss account, issued by the Reserve Bank, require that in case any
16 The Reserve Bank of India, from time to time, prescribes the limits up to which banks can make
donations. As per the Reserve Bank of India's circular no. DBOD. No. Dir. BC. 50/ 13.01.01/ 2005
06 dated December 21, 2005, the policy relating to donations given by banks to various entities
may be formulated by the Board of Directors of the banks. While formulating any such policy, the
circular requires the directors to take into account inter alia, the following principles:
(i) profit making banks, during a financial year, may make donations upto one percent of the
published profits for the previous years. This limit of one percent would include contributions
made by the bank to any fund created for specific purposes such as encouraging research and
development. However, donations/ subscriptions to the Prime Minister's National Relief Fund
and to professional bodies related to banking industry, such as the Indian Banks Association,
Indian Institute of Banking etc., is excluded from such limit of one percent.
(ii) loss making banks can make donations upto Rs. 5 lakhs in a financial year including donations
to the Prime Minister's National Relief Fund and other professional organisations listed in (i)
above.
The circular has clarified that the unutilised portion of one percent cannot be carried forward to the
next year. The Circular also outlines the procedure for making contribution to the Prime Minister's
National Relief Fund.
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particular item under this head exceeds one per cent of the total income,
particulars thereof may be given in the notes. Auditor should check such
large value items reported under this head. Auditors should identify the
nature of items and if appropriate account head is available it should be
classified in that head.
Some banks follow the policy of providing for the promotional points earned by
the customers on the use of Debit/Credit cards on actuarial basis. These
provisions could be shown under this head.
Expenses should be accounted on accrual basis and not on cash basis. The
auditor may review payment vouchers of April month to ascertain the correctness
of provision made for expenses.
Provisions and Contingencies
6.20 This item represents the aggregate of the provisions made in respect of
the following:
(a) Non-performing assets.
(b) Taxation.
(c) Diminution in the value of investments.
(d) Provisions for contingencies.
Provisioning norms for NPA are given in circular RBI/2015-16/101
DBR.No.BP.BC.2/21.04.048/2015-16 dated 1st July 2015. Interest reversal in
case of advances which have become NPA to be specifically checked. The most
important item included in this head is the provision in respect of nonperforming
assets. The other provisions are usually made at the head office level.
Deferred Tax Liability on Special Reserve created under Section
36(1)(viii) of the Income Tax Act, 1961
6.21 RBI vide its Circular No. DBOD.No.BP.BC.77/21.04.018/2013-14 on
"Deferred Tax Liability on Special Reserve created under Section 36(1)(viii) of
the Income Tax Act, 1961" dated December 20, 2013 advised banks, that as a
matter of prudence, DTL should be created on Special Reserve.
6.22 For this purpose, banks may take the following course of action:
a) If the expenditure due to the creation of DTL on Special Reserve as at
March 31, 2013 has not been fully charged to the Profit and Loss account,
banks may adjust the same directly from Reserves. The amount so
adjusted may be appropriately disclosed in the Notes to Accounts of the
financial statements for the financial year 2013-14.
b) DTL for amounts transferred to Special Reserve from the year ending
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March 31, 2014 onwards should be charged to the Profit and Loss Account
of that year.
In view of the requirement to create DTL on Special Reserve, banks may reckon
the entire Special Reserve for the purpose of computing Tier-I Capital. Reference
in this regard is also drawn to the Announcement "Manner of Reporting by the
Auditors In Respect of RBI's Circular on Deferred Tax Liability on Special
Reserve created under Section 36(1) (viii) of the Income Tax Act, 1961" dated
April 30, 2014 issued by the Auditing and Assurance Standard Board of the
Institute of Chartered Accountants of India.
Appropriations
6.23 Under this head, the net profit/ loss for the year as well as profit/ loss
brought forward have to be shown. The appropriations of the aggregate thereof
are to be shown under the following heads:
(a) Transfer to Statutory Reserves.
(b) Transfer to Capital Reserves.
(c) Transfer to Investment Fluctuation Reserve.
(d) Transfer to Debenture Redemption Reserve.
(e) Transfer to Other Reserves.
(f) Transfer to Government/ Proposed Dividend.
(g) Transfer to Tax on Dividend.
6.24 The appropriations of profits are decided at the head office level. This
item would not therefore appear in the profit and loss account at the branch level.
The central statutory auditor should therefore verify compliance with the statutory
requirement regarding transfers to reserve accounts and the other appropriation
as applicable will have to be taken into consideration while verifying these.
According to RBI circular RBI/2006-07/132 DBOD.BP.BC No. 31 / 21.04.018/
2006-07 dated 20th September 2006 all expenses including provisions and write-
offs recognized in a period, whether mandatory or prudential, should be reflected
in the profit and loss account for the period as an `above the line' item (i.e. before
arriving at the net profit).
Audit Approach and Procedures
Income
6.25 In carrying out an audit of income, the auditor is primarily concerned
with obtaining reasonable assurance that the recorded income arose from
transactions, which took place during the relevant period and pertain to the bank,
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that there is no unrecorded income, and that income is recorded in proper
amounts and is allocated to the proper period. In view of the mandatory
requirement of recognition of income, the recognition of revenue will have to be
subjected to examination vis-à-vis the guidelines. Vide circular DBOD.No.BP.
BC. 89 /21.04.018/2002-03 dated 29th March 2003, RBI has advised that in
respect of any income which exceeds one percent of the total income of the bank
if the income is reckoned on a gross basis or one percent of the net profit before
taxes if the income is reckoned net of costs, should be considered on accrual as
per AS-9. If any item of income is not considered to be material as per the above
norms, it may be recognised when received and the auditors need not qualify the
statements in that situation. As per AS-9 Revenue Recognition, revenue arising
from the use by others of enterprise resources yielding interest, royalties and
dividends should only be recognised when no significant uncertainty as to
measurability or collectability exists. If revenue recognition is postponed, as per
AS 9, an enterprise should also disclose the circumstances in which the revenue
recognition has been postponed pending the resolution of significant
uncertainties.
6.26 Since the entire accounting in banks is done on the CBS, the auditor
should plan the audit procedures based on controls testing. If he is not
satisfied with the controls in place for accounting and recording of items of
income and expenses correctly, he should resort to more of substantive
checking of documents and records.
In case the auditor decides to adopt the control reliance strategy, the auditor
should perform test of controls which mitigate the risk of what could go wrong.
Interest Income
6.27 As a measure of control and also to ensure that the legal remedies
against defaulting borrowers are not adversely affected, banks commonly
follow the procedure of recording interest on non-performing advances in a
separate account styled as 'Interest Suspense' or other similar account.
Amounts lying in Interest Suspense Account do not represent income of the
bank and have also to be deducted from the relevant advances. The auditor
should also check whether, in terms of the income recognition guidelines
issued by the RBI, the bank has either reversed or made provision in respect
of interest accrued and credited to income account, in respect of an advance
(including bills purchased and discounted) that becomes NPA as at the close
of any year. Income in case of NPA account should be recognised only on
realisation on cash basis as per circular RBI/2015-
16/101DBR.No.BP.BC.2/21.04.048/ 2015-16 dated 01/07/2015. These norms are
also applicable to Government Guaranteed Advances.
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6.28 In case of accounts under Corporate Debt Restructuring (CDR)
scheme, the auditor should see whether the income on projects under
implementation which have been classified as standard has been accounted
for on accrual basis pursuant to the RBI's income recognition norms. Banks
are not permitted to recognize income on accrual basis from projects under
implementation which have been classified as `substandard' asset. Bank
may recognize income in such accounts only on realisation on cash basis.
Income in respect of Funded Interest and where loans are converted into
equity, debentures or any other instrument is to be recognized on the same
basis as in the case of restructuring and re-scheduling of loans.
6.29 The said norms also require that the banks should not recognise
income from those projects under implementation which have been classified
as sub-standard and it should be recognised only on cash basis. The auditor
should also, accordingly, see whether any interest on such projects which
has been recognised as income in the past is either reversed or a provision
for an equivalent amount is made in the accounts.
6.30 The auditor may assess the overall reasonableness of the figure of
interest earned by working out the ratio of interest earned on different types
of assets to the average quantum of the respective assets during the year.
The auditor should obtain an in-depth understanding as to how the bank's
management monitor their business, analyse its credit portfolio and the
interest income thereon.
6.31 For example, the auditor may obtain from the bank an analysis of
sector-wise and segment-wise deployment of credit, including the lending
rates of advances in various sectors and figures of advances outstanding at
the end of each month/quarter. From such information, the auditor may work
out a weighted average lending rate. This analysis can be done for corporate
and retail loan portfolio separately. In case of retail loans, the portfolio can be
further bifurcated into home loans, auto loans, personal loans, jewel loans,
etc. Further, the auditor should understand the process of computation of the
average balance and re-compute the average balance on sample basis.
6.32 The auditor should set the expectation for the movement in yield
based on the discussion and inquiries made with the management; rate
movement observed in the industry, etc., and should obtain explanations for
major variances in the yield on month basis or quarterly basis.
6.33 To ascertain completeness of interest income in the analysis, the
auditor should obtain general ledger break-up for the interest income earned
during the respective months/quarter and examine whether the aggregation of
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the same agrees with the interest income considered for the yield analysis. The
auditor should analyze monthly/quarterly yields and document the reasons for
the variances as per the expectation set. The auditor may also compare the
average yield on advances with the corresponding figures for the previous
years and analyse any material differences. The auditor may also compare
the reported market yield in percentage terms with market rates, RBI rates,
advertised rates and rates across various products of the bank. Interest Income
includes interest accrued but not due on investments.
6.34 The auditor should, on a test check basis, verify the rates of interest
as per terms of sanction in the CBS as well as the calculation of interest
through product rate sheets generated by CBS to satisfy himself that
(a) Interest has been charged on all the performing accounts upto the date
of the balance sheet;
(b) Interest rates charged are in accordance with the bank's internal
regulations, directives of the RBI and agreements with the respective
borrowers. The scrutiny of interest rates charged is particularly
important in the case of advances made on floating interest rate
basis;
(c) Discount on bills outstanding on the date of the balance sheet has
been properly apportioned between the current year and the following
year;
(d) Interest on interbranch balances has been provided at the rates
prescribed by the head office; and
(e) Any interest subsidy received (or receivable) from RBI in respect of
advances made at concessional rates of interest is correctly computed.
6.35 The auditor should also understand the process of accrual of interest
income on credit card portfolio. Credit card account will be treated as an NPA if
the minimum amount due as stated in statement is not fully paid within 90 days
from the date of next statement. The auditor should understand the assumption
taken for accrual of interest income such as revolving portfolio, standard assets
etc. and independently assess the reasonableness of these assumptions.
6.36 The auditor should also satisfy himself that interest on non
performing assets has not been recognised unless realised.
6.37 As per AS 9, "Revenue Recognition", dividends should be
recognised when the right to receive payment is established, i.e. dividend
has been declared by the corporate body at its Annual General Meeting and
the owner's right to receive payment is established. The auditor should test
certain samples of the dividend income booked during the period by obtaining the
counterfoils of dividend warrants and the amount credited in the bank account.
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6.38 In the case of bill discounting, interest income is received in advance
hence, the auditor should examine whether the interest income for the period
has been accounted for properly and the balance is treated as other liabilities.
In CBS, the interest on bill discounted is system driven and the auditor should
verify the in-built logic of the system. For the sample cases, the auditor should
verify the interest income on bill discounted by obtaining the underlying
documents like purchase order, letter of credit, etc.
6.39 The auditor should also understand the process of increase or
decrease in Marginal Cost of funds based Lending Rate (MCLR) and process
of updating in the system. The auditor should also ascertain compliance with
RBI guideline in respect of increase in tenor of retail loan due to increase in
MCLR. The auditor should also verify on sample basis as to whether the
increase/decrease in base rate are effected in the system on the effective date.
6.40 Interest income includes interest accrued but not due on assets.
However, as banks normally debit the borrower's account with interest due on
the month end, at balance sheet date there would not usually be any amount of
interest accrued but not due on advances on balance sheet date. Auditor
should verify the same.
6.41 The auditor should examine the completeness of accrual of the interest
by obtaining a detailed break-up of the loan portfolio (scheme wise or segment
wise) and the interest accrual on the same. The aggregation of loan portfolio
should be agreed to the general ledger.
6.42 The auditor should examine whether interest has been accrued on the
entire investment and money market lending portfolio by obtaining the detailed
break-up of the investment and money market lending portfolio along with the
interest accrued thereon and agree the same with the general ledger. The
auditor should re-compute the interest accrual on sample basis considering
parameters like frequency of payment of interest amount, rate of interest,
period elapsed till the date of balance sheet, etc., from the term sheet, deal
ticket, agreements, etc.
6.43 In determining the extent of sample checking, the auditor should take into
account, inter alia, the results of the analytical procedures and the reports, if any,
on income and expenditure/ revenue audit as well as other internal and RBI
inspection reports. The auditor's assessment of the effectiveness of concurrent
audit would also affect the extent of his detailed checking of interest earned. In
determining the extent of sample checking, the auditor may place greater emphasis
on examining interest on large advances.
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Commission Income
6.44 Auditor may check the items of commission, exchange and brokerage
on a test check basis. Such examination can be done for commission earned on
bills sent for collection, commission on letters of credit, guarantees and letter of
comforts. The auditor should examine whether the commission on nonfunded
business (e.g., letters of credit, guarantees and bills for collection) has been
properly apportioned between the current year and the following year.
6.45 The auditor should obtain details of loans sanctioned and disbursed
during the period as well as verify the policy of the bank for booking the
processing fee income on such loans. For corporate loans, the processing fee
income for the material loans sanctioned and disbursed should be re-computed
and verified on test check basis by obtaining the loan agreements, sanction
letter, etc. Further, for loans sanctioned but not disbursed wherein the processing
fee income has been booked on accrual basis, the auditor should verify the
subsequent receipt of the same and enquire for subsequent reversals. For retail
loans, the auditor should perform analytical procedures for computing the
processing fee percentage for different ticket size loans.
6.46 The auditor should obtain an understanding of the various types of fee
income earned on credit cards and debit cards. Further, the auditor should obtain
the rate matrix for various fees charged to the customer. On a sample basis, the
auditor should verify whether the fees charged and accounted is as per the rate
matrix. Interchange fees is earned from service providers namely Visa, Master
card, Amex proportionate to the transactions entered by the customer. On a
sample basis, the auditor should verify whether the interchange fees have been
received and accounted as per the agreement. Merchant acquiring income is
earned on the transactions entered by the customers of other banks on the
bank's terminal. The auditor should perform analytical procedures for such
income and obtain the explanation for the variances, if any.
6.47 The auditor should understand how management monitors non-funded
business and use their analysis for analytical procedures. The auditor should
understand the relation with fee income with the business. For example, month
on month /quarter loan processing fees with sanction value to arrive at average
processing fees on monthly/quarterly basis. The auditor should analyse
monthly/quarterly fee percentage and document the reasons for the variances as
per the expectation set. Similarly auditor can perform analysis of other fee
income by doing monthly/quarterly guarantee fees with average
monthly/quarterly guarantee amount, interchange credit card fees vis a vis inter
charge transactions etc.
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6.48 The auditor may also compare the average fee income with the
corresponding figures for the previous years and analyse any material
differences.
6.49 The auditor should also check whether any fees or commission
earned by the banks as a result of renegotiations or rescheduling of
outstanding debts has, in terms of the income recognition guidelines issued
by the RBI, have been recognised on an accrual basis over the period of time
covered by the renegotiated or rescheduled extension of credit.
6.50 According to the guidelines for income recognition, asset
classification, etc., issued by the RBI, if interest income from assets in
respect of a borrower becomes subject to non-accrual, fees, commission and
similar income with respect to same borrower that have been accrued should
cease to accrue for the current period and should be reversed or provided for
with respect to past periods, if uncollected. The auditor should examine
whether the bank has accordingly made suitable adjustments for de
recognition/ reversal of uncollected commission, etc.
6.51 Fee on insurance referral is fast emerging as a major source of
income for banks. In terms of the RBI Master Circular No. DBR.No.FSD.BC
19/24.01.001/2015-16 dated July 1, 2015 on "Para Banking Activities", banks
are permitted to undertake insurance business as agents of insurance
companies on fee basis or referral arrangement without any risk participation
subject to the conditions prescribed under the Master Circular. The auditor
should carefully examine the agreement entered into by the bank and the
concerned insurance company to see the basis for calculation of the said fee,
time when the referral fees becomes due to the bank. Normally, as an
industry practice, such agency arrangements also contain clauses known as
"claw back" of agency fee, whereby if the client referred to the insurance
company by the bank fails to pay the insurance premium for a stipulated
amount of time, the agency fees paid or due to the bank becomes
recoverable from the bank or is frozen. Such clauses have a direct impact on
the recognition of income from the agency fees in terms of Accounting
Standard 9, Revenue Recognition and may, therefore, require creation of a
corresponding provision in the accounts.
6.52 Profit on sale of Land, Buildings and Other Assets: This item includes
profit (net of any loss) on sale of land, buildings, furniture, motor vehicles, gold,
silver, etc.
6.53 The auditor can check authority for disposal of:
fixed assets, if any, sold during the year under audit; and
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non-banking assets acquired in satisfaction of claims.
The auditor should also vouch transactions in evidence of profit/ loss recorded by
the Branch in respect of assets, as aforesaid.
Profit/ Loss on Revaluation of PPE
6.54 The auditor should satisfy himself about the appropriateness and
proper application of the basis of revaluation of PPE adopted by the bank.
Where revaluation is based on an appraisal/report/certificate by approved
valuers, the auditor should examine the appraisals to the extent possible and
satisfy him about their adequacy for audit purposes.
6.55 The revaluation of PPE can be done on the basis of appraisals by
competent valuers such as engineers or architects, or on the basis of
indexation of historical cost, or with reference to current prices. The auditor
should satisfy himself about the appropriateness and proper application of
the basis of valuation adopted by the bank. Where revaluation is based on an
appraisal by valuers, the auditor should examine the appraisals to the extent
possible and satisfy himself about their adequacy for audit purposes.
6.56 The auditor should also examine that the bank has complied with the
provisions of AS 28, Impairment of Assets. In terms of paragraph 58 of AS 28, an
impairment loss should be immediately recognised as an expense in the Profit
and Loss Account, unless the asset is carried at revalued amount in accordance
with AS 10 (Revised). In such a case, any impairment loss of a revalued asset
should be treated as a revaluation decrease under AS 10 (Revised). The Notes
and Instructions for compilation of profit and loss account, issued by the Reserve
Bank, require that in case any item under this head exceeds one per cent of the
total income, particulars thereof may be given in the notes.
Interest on Deposits
6.57 The auditor may assess the overall reasonableness of the amount of
interest expense in accordance with Master Direction DBR.Dir.
No.84/13.03.00/2015-16 dated March 03, 2016 "Reserve Bank of India
(Interest Rate on Deposits) Directions, 2016" by analysing ratios of interest
paid on different types of deposits and borrowings to the average quantum of
the respective liabilities during the year. For example, the auditor may obtain
from the bank an analysis of various types of deposits outstanding at the end
of each quarter. From such information, the auditor may work out a weighted
average interest rate. The auditor may then compare this rate with the actual
average rate of interest paid on the relevant deposits as per the annual
accounts and enquire into the difference, if material. The auditor may also
compare the average rate of interest paid on the relevant deposits with the
corresponding figures for the previous years and analyse any material
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Profit and Loss Account
differences. The auditor should obtain general ledger break-up for the
interest expense incurred on deposits (savings and term deposits) and
borrowing each month/quarter. The auditor should analyse month on month
(or quarter) cost analysis and document the reasons for the variances as per
the benchmark stated. He should examine whether the interest expense
considered in the cost analysis agrees with the general ledger. The auditor
should understand the process of computation of the average balance and
re-compute the same on sample basis.
6.58 The auditor should, on a test check basis, verify the calculation of
interest. He should satisfy himself that:
(a) Interest has been provided on all deposits and borrowings upto the date
of the balance sheet; and verify whether there is any excess or short
credit of material amount.
(b) Interest rates are in accordance with the bank's internal regulations, the
RBI directives, and agreements with the respective depositors.
(c) In case of Fixed Deposits it should be examined whether the Interest
Rate (as applicable) in the accounting system are in accordance with the
Interest Rate mentioned in the Fixed Deposit Receipt/Certificate.
(d) Interest on Savings Accounts should be checked on a test check basis in
accordance with the rules framed by the bank in this behalf.
(e) Discount on bills outstanding on the date of the balance sheet has been
properly apportioned between the current year and the following year.
(f) Payment of brokerage is properly authorized.
(g) Interest on interbranch balances has been provided at the rates
prescribed by the head office.
(h) Interest on overdue/ matured term deposits should be estimated and
provided for.
6.59 The auditor should ascertain whether there are any changes in interest
rate on saving deposits and term deposits during the period. The auditor should
obtain the interest rate card for various types of term deposits and analyse the
interest cost for the period. The auditor should examine the completeness that
there has been interest accrued on the entire borrowing portfolio by obtaining the
detailed breakup of the money market borrowing portfolio and the interest
accrued and the same should agree with the GL code wise break up. The auditor
should re-compute the interest accrual on sample basis i.e., by referring to the
parameters like frequency of payment of interest amount, rate of interest,
period elapsed till the date of balance sheet, etc from the term sheet, deal
ticket, agreements, etc.
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Expenditure
Operating Expenses
6.60 Generally the audit procedures followed by auditors in any entity are
to be followed.
Payments to and Provisions for Employees
6.61 The auditor should ascertain the procedure followed by the bank in this
regard while verifying this item. The auditor should obtain the human resource
policy and identify the benefits available to employees. Auditor should
understand the compensation structure and process of payment of salary,
benefits like employee stock options, car assistance, leave encashment, asset
assistance, etc. to the various grades of employees. He should obtain the
standard compensation structure for each grade of employee. In case, where
payment is made on production of evidence or incurrence by employee, auditor
should ascertain whether provision for the same has been made in the books.
6.62 The auditor should perform an overall analytical review for the payments
and provisions for employees by month on month grade-wise analysis of the
employees cost and number of employee in that grade to identify per employee
cost month on month and enquire about the variances, if any. The auditor should
examine whether all the benefits for all the employees have been appropriately
accounted for.
6.63 The auditor should also check the calculation of salaries and
allowances, etc. on a test check basis with reference to appointment/awards/
offer letters. He may also assess the reasonableness of expenditure on
salaries, allowances, etc. by working out their ratio to total operating
expenses and comparing it with the corresponding figures for previous years.
6.64 Auditor should also obtain an understanding of the provision for
payment of bonus and other incentive and ascertain adequacy of the amount
recorded by the bank. Further, the auditor should verify whether the bank has
made adequate provisions for employee benefits and has complied with the
recognition, measurement and disclosure requirements of AS 15.
Rent, Taxes and Lighting
6.65 The auditor may check the following on a test check basis:
Rent paid and verify whether adjustments have been made for the full year
on account of rent at the rates as applicable and as per agreement in force.
Rent does not include House Rent Allowance to employees.
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Whether municipal rates/ taxes are duly paid/ adjusted for the year under
audit.
Enquire whether any disputed liability exists on this account upto the year-
end.
Further, the auditor should obtain the listing of the premises which have
been obtained on lease. If the lease agreements have escalation clause,
lease equalization should be done in accordance with AS-19 unless the
terms and conditions of the lease indicate otherwise.
In addition, the auditor should perform month on month rent analysis and
verify major variance in the average rent per month per branch. The auditor
should also verify the provision made for the expired lease rent
agreements.
Printing and Stationery
6.66 The auditor should verify this item with reference to documents
evidencing purchase/debit note received.
Advertisement and Publicity
6.67 Expenditure incurred by the bank for advertisement and publicity,
including printing charges of publicity material is verified with the documents.
Repair and Maintenance Expenses
6.68 The auditor should verify the Annual Maintenance Contract (AMC) at
the Branch and should verify the provisioning and prepaid accounting of these
contracts.
Depreciation on Bank's Property
6.69 The auditor should ascertain the procedure followed by the bank while
verifying this item. This item includes depreciation on bank's own property, motor
cars and other vehicles, furniture, electrical fittings, vaults, lifts, leasehold
properties, nonbanking assets, etc. Depending on the procedure followed in the
bank, provision for depreciation may either be centralised at the head office level
or decentralised.
6.70 The auditor should check head office instructions as regards
adjustments of depreciation on the fixed assets of the Branch. The auditor
should also check whether depreciation on fixed assets has been adjusted at
the rates and in the manner required by head office.
6.71 The auditor may also report unadjusted depreciation on assets
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Guidance Note on Audit of Banks (Revised 2019)
acquired but not capitalised. The auditor should re-compute the depreciation
for the period, perform depreciation rationalisation and agree the amount with
the general ledger. The auditor may also verify and obtain explanation for the
unadjusted depreciation on assets acquired but not capitalised.
Provisions and Contingencies
6.72 The auditor should ascertain compliance with the various regulatory
requirements for provisioning as contained in the various circulars.
6.73 The auditor should obtain an understanding as to how the Bank
computes provision on standard assets and non-performing assets. It will
primarily include the basis of the classification of loans and receivables into
standard, sub-standard, doubtful, loss and non-performing assets. For
verification of provision on standard assets, the auditor should verify the loan
classification on a sample basis. The auditor should obtain the detailed break up
of standard loans, non-performing loans and agree the outstanding balance with
the general ledger. The auditor should examine whether by performing re-
computation the provisions in respect of standard loans, NPA and NPI comply
with the regulatory requirements.
6.74 The auditor should obtain the tax provision computation from the bank's
management and verify the nature of items debited and credited to profit and loss
account to ascertain that the same are appropriately considered in the tax
provision computation. The auditor should re-compute the provision for tax by
applying the applicable tax rate after considering the allowances and
disallowances as per Income Tax Act, 1961 and as per Income Computation and
Disclosure Standards (ICDS). The other provisions for expenditure should be
examined vis a vis the circumstances warranting the provisioning and the
adequacy of the same by discussing and obtaining the explanations from the
bank's management.
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PART - V
V-1
Long Form Audit Report
in Case of Bank Branches
1.01 The audit of Bank Branches for a long time was advance centric and
covered mainly the Balance sheet Items. The audit report did not throw much
light on the internal controls and procedures of the Branch/ Banks, which are
key to efficient functioning of Bank /Branches. In order to serve this purpose
RBI contemplated a format which would throw light on internal controls and
Procedures encapsulating and encompassing all aspects of Banks/ Branches
including Advances and thus was born the Long Form Audit report, popularly
abbreviated as LFAR. It cannot be gainsaid that if LFAR reporting is done
scrupulously, all facets of Bank Audit except perhaps Tax Audit would be
covered. It is a tool which the statutory Central Auditors depend on to have
an idea of Branches under the Bank.
1.02 In the case of branches, the auditors have to answer a detailed
questionnaire formulated by the RBI. Such a report is usually termed as Long
Form Audit Report (LFAR).
1.03 In the year 1985, RBI advised the Public Sector Banks to obtain LFAR
from the auditors. The operations and audits of a bank are mainly based on the
effective internal controls and this report serves the purpose of bringing to the
notice of the Management the lacunae, shortcomings and failures in respect of
compliance or adherence to the internal control measures adopted by the Banks.
The main report is to be submitted as per the requirements of the Banking
Regulations Act, 1949. LFAR is a separate report to be submitted to the
Management, in the format prescribed by the RBI. The latest format of LFAR has
been revised in the year 2003 and was made effective from 31st March, 2003.
RBI vide its Circular No. RBI/2014-15/626 DBS.CO.ARS.BC 8/08.91.001/2014-
15 dated June 4, 2015 provides that the branches below the cut-off point, which
are subject to concurrent audit by chartered accountants, shall submit their
LFARs and other certifications audited by the concurrent auditors. They shall
submit their LFAR only to the Chairman of the bank. The banks in turn will
consolidate / compile all such LFARs submitted by the Concurrent Auditors and
submit to Statutory Central Auditor as an internal document of the bank.
Guidance Note on Audit of Banks (Revised 2019)
1.04 Following are the important aspects which requires special attention
while reporting in Long Form Audit Report:
a. The LFAR is not a substitute for the Branch statutory report and is not
deemed to be a part of the main audit report. Further the main report is a
self-contained document and should not make any reference to the
reporting made in LFAR. Hence mere comment in LFAR in lieu of comment
in main report and reporting about change in assets classification of
advances in lieu of Memorandum of change (which is form part of main
report) shall be considered inappropriate reporting. It is to be noted that at
Corporate office level the compilation of Branch LFAR takes place
subsequent to the finalisation of the Branch Auditors Report, therefore it to
be taken care that the important observation reported in LFAR, which has a
material impact on financial statement including internal control over
financial reporting, should also be appropriately reported in the Branch
auditor report.
b. Where any of the comments made by the auditor in his LFAR is adverse,
he should consider whether a qualification in his main report is necessary.
It should not, however, be assumed that every adverse comment in the
LFAR would necessarily result in a qualification in the main audit report. In
deciding whether a qualification in the main report is necessary, the auditor
should use his professional judgement having regard to the facts and
circumstances of each case. It should be noted here that mere comment in
LFAR may not be sufficient without corresponding comment in the main
audit report, should it be a matter of qualification
c. Where the auditors have any reservation or adverse remarks with regard to
any of the matters to be dealt with in their LFARs, they should give the
reasons for the same.
1.05 LFAR is a questionnaire, which asks specific questions for which
replies should be specific. Auditor should give specific comments and should
refrain from answering issues for which replies were never sought unless
relevant. The replies so prepared and supported by relevant documentation
would reveal some facts which may be required to be considered by the
Management for improving the working of the bank and on which action is
needed. It is advisable to discuss the contents of the LFAR with the branch
head and get his responses before finalising the same. The object is to
ensure correct presentation so as to state facts which have been verified
during the course of audit.
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1.06 It should be noted that specific disclosure, such as, in respect of
extent of checking, manner of sample selection, limitations of documents
verified, representations received, etc., should be made in the LFAR. The
reliance placed on the computer system, which the auditor has not tested in
depth for its reliability, should be clearly brought out in the LFAR. The auditor
should also seek written representation from the Management regarding any
changes in CIS (Computer Information System) that have taken place during
the year. In the preparation of the LFAR, the auditor should call for and
consider the previous reports to ascertain whether in respect of the accounts
for the year under audit, there are any matters, which deserve the attention
of the Management, particularly about adverse comments of a material
nature in which remedial action was warranted and the same is yet to be
carried out.
1.07 The main report is a self-contained document and should not make
any reference to the LFAR. However, matters in the main report may be
elaborated in the LFAR. Where any of the comments made by the auditor in
the LFAR is adverse, he should consider whether a qualification in the main
report is necessary. Situations where relevant instances are giving rise to
reservation / adverse remarks should be given along with reasons. It should
not, however, be assumed that every adverse comment in the LFAR would
necessarily result in a qualification in the main report. In deciding whether a
qualification in the main report is necessary, the auditor should use his
judgement in the facts and circumstances of each case. It should be noted
here that mere comment in LFAR may not be sufficient without corresponding
comment in the main audit report, should it be a matter of qualification.
Hence mere comment in LFAR in lieu of comment in main report will not be
considered to be appropriate reporting.
1.08 In designing his audit program the auditor should take into
consideration the requirement of the LFAR questionnaire and should,
accordingly, plan his audit work so as to cover the areas mentioned in the
LFAR simultaneously. This would enable the auditor to appreciate and
consider the effect of various matters to be reported in his LFAR and his
main audit report. As far as possible both the reports should be submitted
simultaneously. LFAR should not be finalised after the main audit report is
signed but should be completed simultaneously in the case of a branch.
However, the submission of the main report should not be delayed merely
because the LFAR is pending for completion.
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Guidance Note on Audit of Banks (Revised 2019)
1.09 LFAR in respect of bank branches is prepared in such a manner so
as to enable the expeditious completion and submission of the LFAR by the
Statutory Central Auditors. It would also be desirable that the branch auditors
also familiarise themselves with the questionnaire applicable to the Statutory
Central Auditors. In response to a question, the Statutory Central Auditor
should consider comments made by the branch auditors in their LFAR with
respect to such question. He should use his judgement to determine whether
comments / observations made in the branch LFAR is material enough to be
incorporated in his own report.
1.10 Some of the matters dealt with in the LFAR need compilation of
detailed information/statements. It should be recognised that the
responsibility for such compilation is that of the bank / branch concerned.
1.11 In the LFAR, replies are given only to questions enumerated in the
LFAR. The LFAR is only indicative in nature however adverse finding on any
additional areas like, KYC compliance / Demat accounts / Lockers / Security
arrangements / Risk based audits //GST/ATM's/TDS, Mobile Banking/Internet
Banking/ RTGS/NEFT transactions etc. may be reported in other matter.
1.12 Some important areas to be noted while preparing LFAR are as
follows:
(a) The auditor should be aware of the delegation of powers to sanction credit
facilities and various Instructions given by the Controlling Authorities of the
bank with respect to various aspects covered in the LFAR.
(b) The auditor should note that in certain questions he has to specifically give
an opinion.
(c) In certain questions replies are to be given specifically based on the cases
examined / test checks done.
(d) In certain cases the auditor has to study the system presently in operation
in the bank so as to give his reply.
(e) In certain questions the auditor has to specifically give suggestions,
especially, regarding improvement in computerised information system and
minimising possibility of frauds.
(f) LFAR should not be treated as mere information providing mechanism.
wherein auditor merely lists observations without drawing any conclusion
thereon. Doing this may not be construed to be proper audit reporting.
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An illustrative list /information which is to be collected /noted by the
Auditor from the Branch for the purpose of compiling LFAR
Branch closing instructions.
Instructions of Controlling Authorities w.r.t. various issues.
Organisation chart.
Authorisation level and powers of branch officials.
Previous years' audit report / LFAR / Tax audit report, inspection report
of the branch, concurrent audit report and compliance thereon.
Various policies (Credit, Investment, Recovery etc.)
Cash retention limit.
Insurance for cash / cash-in-transit.
Bank confirmations / bank reconciliations.
In case of advances of more than Rs. 2 crores sanctioned limit and
outstanding balance. (both funded and non-funded)
List of all advances party-wise and limit-wise.
List of outstanding facility-wise.
List of NPA's and provisioning thereon.
List of overdues / overdrawings.
Cases of sanctions not disbursed.
Cases of overdue proposals for review/renewal.
Cases wherein stock/ book debt statements and other periodic
operational data and financial statements etc. not received/ not received
timely.
Stock audit reports/ unit inspection reports.
List of borrowers wherein inspection/ physical verification of securities
charged to bank have been carried out by the branch.
List of non-corporate entities enjoying limit more than Rs.10 lakh.
Valuation reports of immovable properties of NPA accounts where
outstanding is more than Rs.5 crore and valuation has been done prior
to three years.
Status of claims lodged with ECGC/DICGC/CGST.
Details of cases of compromise / settlement and write off involving write
off / waivers in excess of Rs. 50 Lakhs.
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Report in desired format of advances of more than Rs. 2 crores.
List of accounts downgraded/ upgraded.)
Listing of expired guarantees.
Details of outstanding amount of guarantees invoked and funded by the
Branch.
Details of outstanding amount of letters of credit funded by the branch.
Stock register/ Insurance register/ Stationery draw power register/
Cheque book issuance register/ Cash book/ Sanction register/ Custody
register/ DD issued register/ Document register.
Break up of suspense accounts.
List of sundry deposits/ bills payables/suspense accounts.
List of provisions / prepaid expenses.
List of contingent liabilities.
List of frauds and follow-up action.
List of security items as at 31st March.
List of fixed assets.
Year-wise break-up of matured deposits.
Schedule of charges (for booking of Income).
System audit report, conducted, if any.
Financial statements of all the quarters of the year under audit.
List of computer system (configuration-wise) and accounting system in
operation.
List of MIS reports / returns submitted to various authorities.
Overdue locker rents / vacant lockers.
Cash withdrawals / deposits of more than Rs.10 lakhs.
ATM cards / pin cards not issued and lying in stock.
Cheque books not issued and lying in stock.
Status of PC anti-virus upgrades.
Number of inoperative accounts and the process of allowing operations
thereon.
Number of accounts maintaining balances below prescribed minimum.
Details of customers complaints.
System generated statement for documents time barred by limitation.
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1.13 Management Representation Letter should be demanded for matters
as considered appropriate by the auditor, and which may include matters as
enumerated below:
a) Use of fixed assets.
b) Effective operation of the internal control system throughout the year.
c) Maintenance of effective joint custody of cash at all times during the year.
d) Proper recording of all customer complaints.
e) Notice and reporting of frauds during the year.
f) Adherence to branch timings.
g) Non-sharing of passwords.
h) Nil window dressing of accounts.
i) Genuineness of credits, if any, in NPA accounts at the year end.
j) Physical verification of assets.
k) Amounts outstanding for substantial period in Suspense Account, Nominal
Accounts, Bills Payable, Sundry Deposits, etc.
l) Matters, that can not be adequately supported by any evidence, such as
cash retention limit, insurance cover for cash-in-transit, rotation of duties,
etc.
1.14 SA 580, "Written Representations" requires an auditor to seek written
representations from the auditee, which in the case of branch audit will be
furnished by the branch Management (generally the branch head).
1.15 As per Paragraph 18 of SA 580 when one or more requested written
representations are not provided, the auditor needs to discuss the matter with the
Management, re-evaluate the integrity or Management and evaluate the effect
that this may have on the reliability of representations (oral or written) and audit
evidence in general and take appropriate actions, including the possible effect on
the opinion in the auditor's report in accordance with SA 705(Revised),
"Modifications to the Opinion in the Independent Auditor's Report".
Long Form Audit Report of Bank Branches
1.16 The clauses in the LFAR questionnaire to be dealt with by the
branch auditors are discussed in the following paragraphs. The key word
used in these paragraphs is `Controlling Authority'. The auditor should refer
the relevant circulars issued by the relevant Controlling Authority, as in the
case of a branch any authority which is in a position to control its affairs can
be called as a Controlling Authority, e.g., head office/zonal office or regional
office.
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1.17 It should be noted that replies are sought specifically in conjunction
with the relevant bank instructions. A branch may be observing a system of
control which may be perfectly in order but if the same is contrary to the
instructions of the Controlling Authority on the same then it has to be
specifically stated as a violation in the report.
I. Assets
Cash
(a) Does the branch generally carry cash balances, which vary significantly
from the limits fixed by the Controlling Authorities of the bank?
A letter received from controlling office to be perused to ascertain the
cash retention limit allotted to the branch (including foreign currencies).
The limits as above to be verified with the daily closing cash balance
(including foreign currency) of the Branch.
Any exceptions may be reported as under:
i. We have been informed that Controlling Office had fixed Cash
Retention Limit of Rs. -----vide letter no.......dated---.
ii. During the year under audit the cash balance was in excess of
Retention Limit on many / few occasion. The instances are as
under:-
Date Balance in Rs.
The above data can be obtained from system generated report.
(b) Does the branch hold adequate insurance cover for cash-on-hand and
cash-in- transit?
Generally, the Branch cash balance has been covered under the
Bankers' Indemnity Policy.
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A copy of the policy to be obtained from Branch. In case the insurance
is taken by Head Office / Controlling Office, a copy of policy or any
correspondence from Head Office / Controlling Office in this regard to
be perused.
(c) Is cash maintained in effective joint custody of two or more officials, as per
the instructions of the Controlling Authorities of the bank?
Obtain the instructions in this regard and peruse the compliance thereof.
Generally, the Cash is held in the Joint Custody of Cashier and Officer
of the Branch.
Specify the name and designation of the concerned persons.
(d) Has the cash balances at the branch been checked at periodic intervals as
per the procedure prescribed by the Controlling Authorities of the bank?
Obtain the copy of the procedure prescribed by the Controlling
Authorities and examine the compliance thereof. In addition, ascertain,
whether the branch is under Concurrent Audit. Generally, the
Concurrent Auditors do the Cash verification every month.
In addition to above, officials who are not dealing with cash are also
doing verification on monthly basis.
Balances with Reserve Bank of India, State Bank of India and Other
Banks
(a) Were balance confirmation certificates obtained in respect of outstanding
balances as at the year-end and whether the aforesaid balances have
been reconciled? If not, the nature and extent of differences should be
reported.
Balance confirmation certificates obtained in respect of outstanding
balances as at the year end.
Obtain the Bank Reconciliation Statement.
If the reconciliation is not carried out or carried out incorrectly the same
to be reported.
If any difference is observed, then report the amount, nature of
difference and period since lying in the reconciliation statement
(b) Your observations on the reconciliation statements may be reported in the
following manner:
(i) Cash transactions remaining unresponded
Give full details.
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Guidance Note on Audit of Banks (Revised 2019)
(ii) Revenue items requiring adjustments/ write-off
Give full details.
(iii) Old outstanding balances remaining unexplained/ unadjusted. Give
details for:
Outstanding between six months and one year; (including
Receivable or payable)
One year and above. (including Receivable or payable)
(c) In case any item deserves special attention of the Management, the same
may be reported.
Give full details.
Money at Call and Short Notice
Has the Branch kept money-at-call and short notice during the year? If so,
whether instructions/ guidelines, if any, lay down by the Controlling Authorities
of the bank have been complied with?
Generally, this is looked after by Treasury Department, hence, such types of
transactions generally do not appear in Branch Books.
However, confirm that no such transactions are appearing in the Branch
Trial Balance.
If there are transactions, obtain the instructions / guidelines laid down by the
Controlling Authorities and examine the compliance thereof.
Investments
Generally, this is looked after by Treasury Department, hence, such types of
transactions do not appear in Branch Books.
However, confirm that no Investments are appearing in the Branch Trial
Balance.
If Investments are appearing in the Trial Balance physical verification should
be conducted and reported accordingly. Also verify investment balance
confirmation of counter party (Investee) with balance appearing in Branch
Books.
(A) For Branches in India
a) Are there any investments held by branches on behalf of Head Office/
other offices of the bank? If so, whether these have been made available
for physical verification or evidences have been produced with regard to
the same where these are not in possession of the branch?
If Investments are held on behalf of Head Office / Other Offices physical
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verification of the records should be conducted and reported
accordingly.
b) Whether any amounts received as income on such investments have been
reported to the Head Office?
Confirm from the Branch Trial balance whether any such income is
received. If yes, ascertain whether the instructions in this regard of the
head office / controlling office is complied with.
c) In respect of investments held by branches on behalf of Head Office/ other
offices of the bank whether any income is accrued / received and
recognised as income of the branch contrary to the instructions of the
Controlling Authorities of the bank?
Confirm from the Branch Trial balance whether any such income is
received. If yes, ascertain whether the instructions in this regard of the
head office / controlling office are complied with.
d) Whether there are any matured or overdue investments, which have not
been encashed? If so, give details?
Give full details including details about the investment, the date on
which the said investment has got matured or overdue, maturity value,
etc.
e) Whether the guidelines of the Reserve Bank of India regarding
Transactions in Securities have been complied with.
Refer guidelines of Reserve Bank of India together with Head Office
instruction.
f) Whether the guidelines of the Reserve Bank of India regarding valuation of
Investments have been complied with.
Refer guidelines of Reserve Bank of India together with Head Office
instruction (Valuation Policy of the Bank).
(B) For Branches outside India
The audit of Branches outside India is not allotted to Indian Chartered
Accountants Firms; hence not applicable.
a) In respect of purchase and sale of investments, has the branch acted
within its delegated authority, having regard to the instructions/
guidelines in this behalf issued by the Controlling Authorities of the
bank?
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Guidance Note on Audit of Banks (Revised 2019)
b) Have the investments held by the branch whether on its own account
or on behalf of the Head Office/ other branches been made available
for physical verification? Where the investments are not in the
possession of the branch, whether evidences with regard to their
physical verification have been produced?
c) Is the mode of valuation of investments in accordance with the RBI
guidelines or the norms prescribed by the relevant regulatory authority
of the country in which the branch is located, whichever are more
stringent?
d) Whether there are any matured or overdue investments, which have
not been encashed? If so, give details?
Advances
(a) Credit Appraisal
In your opinion, has the branch generally complied with the procedures/
instructions of the Controlling Authorities of the bank regarding loan
applications, preparation of proposals for grant/ renewal of advances,
enhancement of limits, etc., including adequate appraisal documentation in
respect thereof.
Refer circular issued by Head Office regarding Credit Appraisal.
Enquire whether specific facility wise loan application form is prescribed
by the Bank.
Confirm that the instructions are followed by the Branch while accepting
the loan application form.
Refer circular issued by Head Office regarding preparation of proposals
for grant / renewal of advances, enhancement of limits, etc., including
adequate appraisal documentation in respect thereof.
While reporting under this clause, auditor should consider the "Early
mortality cases" in the branch.
The auditor would also need to consider whether:
The branch is adhering to various guidelines issued by RBI regarding
lending against own shares, lending to directors or their relatives.
In respect of lending under consortium / multiple banking arrangement,
the branch is obtaining declaration from the borrowers about the credit
facilities already enjoyed by them from other banks in the format
prescribed in circulars DBOD.No.BP.BC.46/08.12.001/2008-09 dated
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September 19, 2008 and DBOD.No.BP.BC.94/08.12.001/2008-09 dated
December 08, 2008.
Bank is exchanging / sharing information of the credit facilities
sanctioned to the borrowers with other lending bankers as per
RBI/2012-13/304 DBOD.BP.BC.No. 62/21.04.103/2012-13 dated
21/11/2012 including compliance to any sanction of fresh loans/ad hoc
loans/renewal of loans to new/existing borrowers to be done only after
obtaining/sharing necessary information.
The branch is practicing due diligence to assess the credit worthiness of
the borrowers and not relying on margin and security as a substitute for
due diligence.
The branch is adhering to the prudential exposure limits prescribed by
RBI and Head Office.
In case of corporate borrower, it is necessary for branch auditor to
carefully go through the annual reports to ensure that there no adverse
comments in main auditor report or CARO report on annual accounts of
the borrower that affects sanction at the branch level.
Latest IT returns of Borrowers / Guarantors have been obtained and
verified with financial documents and other information available on
record.
Latest CIBIL or other Credit Information Company report has been
obtained and verified.
(b) Sanctioning/ Disbursement
(i) In the cases examined by you, have you come across instances of credit
facilities having been sanctioned beyond the delegated authority or limit
fixed for the branch? Are such cases promptly reported to higher
authorities?
Confirm sanctioning / disbursement discretionary power regarding
advances.
Report the cases where credit facilities having been sanctioned beyond
the delegated authority or limit fixed for the branch.
Whether such type of cases promptly reported to higher authorities.
Such type of cases may be reported in the following format.
Generally, cases are seen in the branch where the limits of existing
borrowers are allowed to be overdrawn for a period beyond permissible
time. Such cases should be reported.
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exceeding the delegated
Sanction date/ Authority
Balance outstanding on
ratification from Higher
Name of the borrower
Amount sanctioned
Date of sanction /
Account Number
Type of facility
Sanction limit
31.03.20XX
Authority
authority
Sr. No.
(ii) In the cases examined by you, have you come across instances where
advances have been disbursed without complying with the terms and
conditions of the sanction? If so, give details of such cases.
Obtain original Title deed, Execution of Documents. Vetting of
documents by legal dept./ legal resource.
Report the cases where advances have been disbursed without
complying with the terms and conditions of the sanction letter, such as:
o Non Execution of Loan Documents;
o Non Vetting of documents executed by legal dept./ legal resource;
o Non availability of original Title deed and not creation of security /
Equitable / Registered Mortgage on immovable property as per
terms of sanction;
o Non compliance of any other pre-disbursement stipulations.
Other aspects to be covered are:
- Registration of charges ROC/CERSAI.
- Resolutions guarantees.
- insurance of stock & immoveable property.
- Lien on deposits margins for BG and LC and loan on deposits.
All the instances where disbursement have been made without
compliance of the pre-disbursement conditions are required to be
reported along with the deviations.
(c) Documentation
(i) In the cases examined by you, have you come across instances of credit
facilities released by the branch without execution of all the necessary
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documents? If so, give details of such cases.
Report the cases where credit facilities released by the branch without
execution of all the necessary documents. Physical verification of
documents is critical. This is one of the important functions of the
branch audit and the reason why branch audit exists.
Verify Custody of Documents Whether document movement register
tracking changes is maintained. Whether scanning of important
documents is maintained.
The exact nature of irregularity / document not obtained may be
provided in the following format:
Nature of irregularity
Balance outstanding
Account Number
/ documents not
Sanction date /
Type of facility
Sanction limit
Name of the
31.03.20XX
Authority
borrower
obtained
Sr. No.
on
(ii) In respect of advances examined by you, have you come across cases of
deficiencies in documentation, non-registration of charges, non-obtaining
of guarantees, etc.? If so, give details of such cases.
Report cases of deficiencies in documentation, non-registration of
charges, non-obtaining of guarantees, etc.
Make sure that the documents are adequately stamped as per duty
structure of the respective State.
The instances should be reported in the following format:
Account Number
Sanction date /
Type of facility
Sanction limit
Name of the
outstanding
irregularity
& a/c no.
Authority
Nature of
borrower
Balance
Sr. No.
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Guidance Note on Audit of Banks (Revised 2019)
Time barred documents list to be furnished as under:
Sr. Name Account Outstanding Sanction limit / Date of
No. of the Number balance Authority document
borrower
The time barred accounts statement can be generated through system.
When the document becomes time barred, no legal action can be
initiated against the borrower.
(iii) Whether advances against lien of deposits have been properly granted by
marking a lien on the deposit in accordance with the guidelines of the
Controlling Authorities of the bank.
Refer the guidelines issued by Head Office in this regard.
Report the cases, where the deposits / NSCs, paper securities etc., are
matured, however not adjusted against the respective advances.
Instances should be given in the following format:
Sr. Name of Account Sanction Outstanding Date of Particulars
No. the Number limit / balance document of Security
borrower Authority
(d) Review/Monitoring/ Supervision
(i) Is the procedure laid down by the Controlling Authorities of the bank, for
periodic review of advances including periodic balance confirmation/
acknowledgement of debts, followed by the branch?
Provide analysis of the accounts overdue for review/ renewal
o between 6 months and 1 year, and
o over 1 year
Refer the guidelines issued by Head Office in this regard.
Date / month in which accounts were due for review and the date /
month on which the review was done may be obtained.
It may be noted that there would be cases that are seen performing at
the balance sheet date but evidently stressed. Comments on such
account with respect to branch efforts on monitoring and information
availability on same should be commented upon.
In view of changes in the reporting requirements in CARO for corporate
borrowers, it is necessary for branch auditor to carefully go through the
annual reports to ensure that there no adverse comments in the balance
sheet of a borrower that affects reporting at the branch level.
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Date / Month of review can be verified from the sanction documents /
terms
Instances should be given in the following format:
Sr. Name of the Type of Balance Review Ageing
No. Borrower Facility & outstanding overdue
Account as on since
Number 31.03.20XX
(ii) Are the stock / book debt statements and other periodic operational data
and financial statements, etc., received regularly from the borrowers and
duly scrutinised? Is suitable action taken on the basis of such scrutiny in
appropriate cases?
Borrower wise / month wise record showing receipt of security
statement be confirmed.
Confirm the working of drawing power based thereon.
Confirm whether these statements are obtained on time.
Compare movement shown in book debt & creditors with debit/credits in
the Bank.
Further, in respect of consortium advance, the drawing power should be
determined by the lead bank and circulated to the other member banks as
per Circular No. C&I/Circular/2014-15/689 dated 29 September 2014 issued
by the Indian Banks Association.
(iii) Whether there exists a system of obtaining reports on stock audits
periodically? If so, whether the branch has complied with such system?
Refer the guidelines issued by Head Office in this regard and confirm
the compliance thereof.
Examine the compliances obtained, action taken in cases wherein
deficiencies are reported by the stock auditors.
Obtaining written reverts from the Borrower.
Whether adverse issues in stock audit reports are duly factored in
review / renewal notes.
Compare with annual accounts for divergences and obtain satisfactory
explanations.
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(iv) Indicate the cases of advances to non-corporate entities with limits
beyond Rs.10 lakhs where the branch has not obtained the accounts of
borrowers, duly audited under the RBI guidelines with regard to
compulsory audit or under any other statute.
Obtain list of non corporate borrowers enjoying facilities in excess of
Rs.10.00 lakhs and report where audited statements are not on record.
A list of such cases is to be given in the following format:
Sr. Name of the Account Number Sanction Date of last audited
No. Borrower Limit accounts obtained
(v) Has the inspection or physical verification of securities charged to the
Bank been carried out by the branch as per the procedure laid down by
the Controlling Authorities of the bank?
Refer the guidelines issued by Head Office in this regard.
Reporting deviations if any reasons for the deviations.
A list of such cases is to be given in the following format.
Sr. Name of the Account Sanction Last date of inspection or
No. Borrower Number Limit physical verification
(vi) In respect of advances examined by you, have you come across cases of
deficiencies in value of securities and inspection thereof or any other
adverse features such as frequent/unauthorised overdrawing beyond
limits, inadequate insurance coverage, etc.?
Note down the remarks regarding deficiencies in value of securities and
inspection report submitted by the concerned officer.
Confirm whether Insurance is in favour of Bank.
Check whether Insurance covers risks the mortgaged securities are
subject to Check adequacy of Insured value and location wise.
The cases where frequent / unauthorized over drawings beyond limits
are granted is to be given in the following format:
Sr. Name of Account Sanction Balance Drawing Irregularity
No. the number Limit Outstanding power
Borrower
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Long Form Audit Report in Case of Bank Branches
For cases, wherein insurance details are not available is to be given in
the following format:
Sr. Name of Account Sanction Value of Security
No. the Number Limit
Borrower
For cases, wherein there is inadequate insurance may be given in the
following format:
Sr. Name of Account Sanction Value of Insured Inadequate
No. the Number Limit Security for Rs. Insurance
Borrower
(vii) In respect of leasing finance activities, has the branch complied with the
guidelines issued by the Controlling Authorities of the bank relating to
security creation, asset inspection, insurance, etc? Has the branch
complied with the accounting norms prescribed by the Controlling
Authorities of the bank relating to such leasing activities?
Refer the guidelines issued by Head Office in this regard.
(viii) Are credit card dues recovered promptly?
Refer the guidelines issued by Head Office in this regard.
Whether the branch maintains debit balances in the card dues
customers.
Confirm, whether such debit balances are included in advances
classification statements.
(ix) Has the branch identified and classified advances into standard/sub-
standard/ doubtful/ loss assets in line with the norms prescribed by the
Reserve Bank of India.
Refer the guidelines issued by Reserve Bank of India together with
Head Office in this regard.
Wherever, such guidelines are not followed, Memorandum of Changes
be given with reasons.
The branch auditor shall also verify compliance with the guidelines
issued by Head Office with regard to identification and classification of
loan accounts into special mention accounts and incremental
provisioning requirement on account of unhedged foreign current
exposures in line with the norms prescribed by the Reserve Bank of
India.
(x) Where the auditor disagrees with the branch classification of advances
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Guidance Note on Audit of Banks (Revised 2019)
into standard / sub-standard / doubtful / loss assets, the details of such
advances with reasons should be given. Also indicate whether suitable
changes have been incorporated / suggested in the Memorandum of
Changes.
Refer the guidelines issued by Reserve Bank of India together with
Head Office in this regard.
Wherever, such guidelines are not followed Memorandum of Changes
be given with reason.
(xi) Have you come across cases where the relevant Controlling Authority of
the bank has authorised legal action for recovery of advances or recalling
of advances but no such action was taken by the branch? If so, give
details of such cases.
Refer the guidelines issued by Head Office in this regard.
Wherever, such guidelines are not followed such cases be reported in
the following format.
Sr. Name of the Account Sanction Instructions to Present
No. Borrower Number Limit take legal action Status
on
(xii) Have all non-performing advances been promptly reported to the relevant
Controlling Authority of the bank? Also state whether any rehabilitation
programme in respect of such advances has been undertaken, and if so, the
status of such programme.
Refer the guidelines issued by Head Office in this regard.
Wherever, such guidelines are not followed such cases be reported:
Sr. Name of the Account Sanction Rehabilitation Present
No. Borrower Number Limit programme Status
sanctioned
(xiii) Have appropriate claims for DICGC/CGSTE and Export Credit Guarantee/
Insurance and subsidies, if any, been duly lodged and settled? The status
of pending claims giving year wise break-up of number and amounts
involved should be given in the following format:
DICGC not applicable, as most of the Banks have opted out of DICG.
Report here the claims if any outstanding on account of ECGC/CGST.
Report the cases not accepted / rejected by ECGC/CGST.
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Particulars Number Amount (Rs.)
Claims as at the beginning of the year
(Give year-wise details)
Further claims lodged during the year
____ _______
Total A ____ _______
Amounts representing:
(a) Claims accepted/ settled (give
year-wise details)
(b) Claims rejected (give year-wise
details)
____ _______
Total B ____ _______
Balance as at the year-end (give year-
wise details) ____ _______
A-B
=== ======
(xiv) In respect of non-performing assets, has the branch obtained valuation
reports from approved valuers for the fixed assets charged to the bank,
once in three years, unless the circumstances warrant a shorter duration?
Refer the guidelines issued by Head Office in this regard.
Wherever, such guidelines are not followed such cases be reported in
the following format.
Whether valuation is done on a consistent basis at fair Market value,
Realizable value, Distress value Whether Fall in Market value has
been factored in the valuation -
Outstanding
Name of the
Report date
Valuation
Borrower
Sanction
Account
Security
Security
Value of
Balance
Number
Sr. No.
Latest
Limit
(xv) In the cases examined by you has the branch complied with the Recovery
Policy prescribed by the Controlling Authorities of the bank with respect to
compromise/ settlement and write-off cases? Details of the cases of
compromise/ settlement and write-off cases involving write-offs/ waivers in
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Guidance Note on Audit of Banks (Revised 2019)
excess of Rs.50 lakhs may be given.
Refer the guidelines issued by Head Office in this regard.
Wherever, such guidelines are not followed such cases be reported in
the following format:
Account Number
Settlement Amt.
Compromised /
Outstanding
Name of the
Recovery
Recovery
Borrower
Sanction
Effected
Balance
effected
Sr. No.
To be
Limit
(e) Guarantees and Letters of Credit
Normally handled at Corporate or Head Office.
However, inquire whether such types of cases are handled at Branch
and reply accordingly.
(i) Details of outstanding amounts of guarantees invoked and funded by the
branch at the end of the year may be obtained from the Management and
reported in the following format:
(a) Guarantees invoked, paid but not adjusted:
Sr. Date of Name of Name of Amount Date of Remarks
No. invocation the party beneficiary Recovery
(b) Guarantees invoked but not paid:
Sr. Date of Name of Name of Amount Date of Remarks
No. invocation the party beneficiary Recovery
(ii) Details of the outstanding amounts of letters of credit and co-acceptances
funded by the Branch at the end of the year may be obtained from the
Management and reported in the following format:
Sr. Date of Name Nature (LC/ co- Amount Date of Remarks
No. funding of the acceptance, etc.) Recovery
party
Other Assets
(a) Stationery and Stamps
(i) Does the system of the Bank ensure adequate internal control over issue
and custody of stationery comprising security items (Term Deposit
Receipts, Drafts, Pay Orders, Cheque Books, Traveller's Cheques, Gift
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Cheques, etc.)? Whether the system is being followed by the branch?
The Head Office instructions to be seen and confirm whether internal
control is in existence.
Carry out the physical verification of security items including stamps.
Whether lost security items are reported to Controlling Authority.
Note down the accounting treatment given to Stationery items as every
Bank is having different policy in this regard.
Comment on the usage of security items during the year and the stock
of such items vis a vis usage.
Report lacunas observed in the system at the branch as this is a fraud
prone area.
(ii) Have you come across cases of missing/ lost items of such stationery?
Deficiencies in controls that lead to the missing stationery to be stated.
Sr. Description of Consecutive Date of Missing
No the security item No. of the item Loss Reported on
(b) Suspense Accounts/ Sundry Assets
(i) Does the system of the Bank ensure expeditious clearance of items debited
to Suspense Account? Details of old outstanding entries may be obtained
from the branch and the reasons for delay in adjusting the entries may be
ascertained. Does your scrutiny of the accounts under various sub-heads
reveal balances, which in your opinion are not recoverable and would
require a provision/ write-off? If so, give details in the following format:
Year Amount (Rs.) Remarks
Refer the guidelines issued by Head Office in this regard.
Whether, such guidelines are followed strictly.
The Debit entries in the opinion of the auditor, not recoverable should
be reported for making adequate provision.
Age wise analysis report through the system may be referred for the
same.
Reasons for such debits to be clarified.
(ii) Does your test check indicate any unusual items in these accounts? If so,
report their nature and the amounts involved.
Information to be given in the following format.
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Guidance Note on Audit of Banks (Revised 2019)
In case of long outstanding entries over a period of one year the details
to be seen with regard to its nature and possibility of recovery in case of
debit items, if you feel that items are not recoverable necessary
provision to be suggested in Memorandum of Changes (MOC).
Sr. Particulars of Outstanding Whether provision is
No. debit entry balance as on necessary, reasons
31.03.20XX there of
Follow the above said procedure in this regard.
II. Liabilities
Deposits
(i) Have the Controlling Authorities of the bank laid down any guidelines with
respect to conduct and operations of Inoperative Accounts? In the cases
examined by you, have you come across instances where the guidelines
laid down in this regard have not been followed? If yes, give details
thereof.
Refer the guidelines issued by Head Office in this regard.
Whether, such guidelines are followed strictly.
Wherever the guidelines are not followed report the same along with full
details.
Whether system identifies the inoperative accounts and converts the
status of such accounts to inactive.
Whether branches are transferring inoperative accounts and shown
under a separate DEAF Deposits accounts in the branch General
Ledger.
Whether unclaimed liabilities (whether amount due has been transferred
to DEAF) is reflected as Contingent Liability.
Note down the procedure for making such inoperative account,
operative.
(ii) After the balance sheet date and till the date of audit, whether there have
been any unusual large movements (whether increase or decrease) in the
aggregate deposits held at the year-end? If so, obtain the clarifications
from the Management and give your comments thereon.
Compare the aggregate deposits as on 15th March, 20XX, 31st March,
20XX and last day of audit.
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Ascertain the reason for large variation other than due to application of
interest / provision as on 31st March, 20XX.
Ensure there is no evergreening.
(iii) Are there any overdue/ matured term deposits at the end of the year? If so,
amounts thereof should be indicated.
Refer the guidelines issued by Head Office in this regard.
Whether, such guidelines are followed strictly.
Whether interest is provided on matured deposit as per RBI guidelines.
Follow up done with customers to renew such accounts.
Other Liabilities
Bills Payable, Sundry Deposits, etc.
(i) The number of items and the aggregate amount of old outstanding items
pending for three years or more may be obtained from the branch and
reported under appropriate heads. Does the scrutiny of the accounts under
various sub-heads reveal old balances? If so, give details in the following
format:
Year No. of items Amount (Rs.) Remarks
Refer the guidelines issued by Head Office in this regard.
Whether, such guidelines are followed strictly.
Obtain the listing of bills payable together with the due date.
(ii) Does your test check indicate any unusual items or material withdrawals or
debits in these accounts? If so, report their nature and the amounts
involved.
Refer the exceptional transaction report generated through system.
Movement in such accounts may be compared and reason may be
analysed.
Contingent Liabilities
List of major items of the contingent liabilities (other than constituents' liabilities
such as guarantees, letters of credit, acceptances, endorsements, etc.) not
acknowledged by the branch?
List of claims against the branch together with the status of claim may be
obtained.
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List of contingent liability to be verified and the same to be compared with
last year's list.
The items not appearing in the current year's list may be enquired with
reasons thereof.
Whether any provisioning is warranted against these Contingent Liabilities.
III. Profit and Loss Account
(a) Whether the branch has a system to compute discrepancies in interest /
discount and for timely adjustment thereof in accordance with the
guidelines laid down in this regard by the Controlling Authorities of the
bank? Has the test checking of interest revealed excess / short credit of a
material amount? If so, give details thereof.
Refer concurrent audit / internal inspection audit / income & expenditure
audit reports.
Test check interest / discount calculations. Whether changes in interest
rates are correctly captured.
Generate Exceptional Transactions report and verify interest is applied
to all applicable accounts.
Generally, interest application is a system-generated entry; hence test
check may be applied for confirming interest calculations.
Wherever excess / short credit of material amount is noticed, such
cases may be reported in the following format.
Test check cases of premature withdrawals for re-computing interest wrt
revised tenor.
Sr.No A/c No Interest calculated Interest Difference
by the system calculated by us
(b) Has the branch complied with the Income Recognition norms prescribed
by the RBI?
Refer RBI Master circular on IRAC norms together with other circulars
issued by RBI on IRAC norms from time to time.
Ensure asset classification is being done through system and no
manual intervention is in place.
In case, the income recognition in NPA accounts is done manually and
is not automated, then the auditor should also verify the system and
process being followed by the branch to ascertain whether their exist a
systematic manner of recognition of income and should also test
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whether the same complies with the Accounting Policy of the Bank
relating to appropriation of recoveries.
Confirm whether IRAC norms are followed strictly through system
(c) Whether the branch has a system to compute discrepancies in interest on
deposits and for timely adjustment of such discrepancies in accordance
with the guidelines laid down in this regard by the Controlling Authorities of
the bank? Has the test check of interest on deposits revealed any excess/
short debit of material amount? If so, give details thereof.
Refer the guidelines issued by Head Office/RBI in this regard.
Whether, such guidelines are followed strictly.
Check the correctness of interest rates fed in the system with the
sanction terms on test check basis. Also, updation of base rates in the
system, in case of changes may be verified.
Generally, interest application is a system-generated entry; hence test
check may be applied for confirming interest calculations.
Wherever excess / short credit of material amount is noticed, such
cases may be reported in the following format.
Sr. No A/c Interest Interest (Short) / Excess
No calculated by the calculated by Interest calculated by
system us the system
(d) Does the bank have a system of estimating and providing interest accrued
on overdue / matured term deposits?
Refer the guidelines issued by Head Office in this regard.
Whether, such guidelines are followed strictly.
In most of the Banks such exercise is carried out at Head Office through
system.
(e) Are there any divergent trends in major items of income and expenditure,
which are not satisfactorily explained by the branch? If so, the same may
be reported upon. For this purpose, an appropriate statement may be
obtained from the branch Management explaining the divergent trends in
major items of income and expenditure.
The divergent trends can be identified by way of comparison analysis on
the basis of previous quarters / half year / previous year figures, keeping
in mind the changes in business volumes and business mix.
Compare the aggregate figures as on 15th March, 20XX, 31st March,
20XX and last day of audit. Also compare some of the transfers on the
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last two days of the year end and identify whether there are any
transfers of undrawn portion from the loan accounts to current account
or deposit account.
IV. General
Books and Records
(a) In case any books of account are maintained manually, does general
scrutiny thereof indicate whether they have been properly maintained, with
balances duly inked out and authenticated by the authorised signatories?
Now a days CBS is followed hence question of maintaining manual
books of accounts does not arise.
Balancing is also done through system.
Balancing report may be generated to confirm that no difference is
appearing in the balancing report.
Exception Reports can be generated from the system to verify whether
there are differences. If there are differences, the same should be
reconciled / rectified by branch.
(b) In respect of computerised branches:
Whether hard copies of accounts are printed regularly?
Refer the guidelines issued by Head Office. On the basis of instructions,
documents to be stored in hard copies and the periodicity of printing
may be identified.
Indicate the extent of computerisation and the areas of operation
covered through manual intervention.
Are the access and data security measures and other internal controls
adequate?
Refer the guidelines issued by Head Office Awareness of Branch
officials with Security guidelines -
Password Policy, Anti viruses on systems, Access to pen drives etc.
may be checked as a part of access and data security controls.
Whether regular back-ups of accounts and off-site storage are
maintained as per the guidelines of the Controlling Authorities of the
bank?
Refer the guidelines issued by Head Office for compliance Whether
backups are periodically tested.
Whether adequate contingency and disaster recovery plans are in
place for loss/ encryption of data?
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Refer the guidelines issued by Head Office & compliance thereof. Note
if any fire drills or any other evacuation drills are conducted Whether
any Fire Safety Audits are conducted.
Do you have any suggestions for the improvement in the system with
regard to computerised operations of the branch?
Reconciliation of Control and Subsidiary Records
Enquire at branch the system of reconciliation followed.
Whether any long outstanding debit entries are appearing in the
reconciliation statement.
o If answer is positive, same should be reported.
Have the figures, as at the year-end, in the control and subsidiary records been
reconciled? If not, the last date upto which such figures have been reconciled
should be given under the respective heads, preferably in the following format:
Account Date General Ledger Subsidiary Last Date on
Balance (Rs.) Balance (Rs.) which
balanced
Inter-Branch Accounts
Check for any entries not responded -
Now a day's CBS is implemented hence question of reconciliation of
Inter Branch Accounts does not arise at Branch.
(i) Does the branch forward on a daily basis to a designated cell/ Head Office,
a statement of debit/ credit transactions in relation to other branches?
(ii) Does a check of the balance in the Head Office Account as shown in the
said statement during and as at the year-end reveal that the same is in
agreement with the Head Office Account in the general ledger?
(iii) Are there any outstanding debits in the Head Office Account in respect of
inter-branch transactions?
(iv) Does the branch expeditiously comply with/ respond to the
communications from the designated cell/ Head Office as regards
unmatched transactions? As at the year-end are there any unresponded/
uncomplied queries or communications? If so, give details?
(v) Have you come across items of double responses in the Head Office
Account? If so, give details.
(vi) Are there any old/ large outstanding transaction/ entries at debits as at
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year-end which remain unexplained in the accounts relatable to inter-
branch adjustments?
Audits/Inspections
(i) Is the branch covered by concurrent audit or any other audit/ inspection
during the year?
(ii) In framing your audit report, have you considered the major adverse
comments arising out of the latest reports of the previous auditors,
concurrent auditors, stock auditors or internal auditors, or in the special audit
report or in the inspection report of the Reserve Bank of India? State the
various adverse features persisting in the branch, though brought out in
these audit/ inspection reports.
Obtain a list of audit which the Branch was subjected to during the
previous year.
The scope of each audit may be reviewed to identify adequate coverage
of branch activities.
Obtain all the reports and peruse the reports for any adverse remarks.
Whether branch has been addressing all issues noted promptly
whether there are any repeat issues?
Whether the Gap or Process failure that lead to the transactional error
reported is addressed?
Frauds
Furnish particulars of frauds discovered during the year under audit at the
branch, together with your suggestions, if any, to minimise the possibilities of
their occurrence
Enquire about any fraud reported to Controlling Authority/vigilance dept.
Head Office during the financial year.
The auditor should also examine whether:
the branch is having an effective credit monitoring for its Advances
portfolio.
the branch has an adequate system in place to identify Early Warning
Signals(EWS) of incipient sickness / fraudulent activities in respect of
loans. Some of the Early Warning signals which should alert the bank
officials about some wrongdoings in the loan accounts which may turn
out to be fraudulent:
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o Default in payment to the banks/ sundry debtors and other statutory
bodies, etc., bouncing of the high value cheques.
o Raid by Income tax /sales tax/ central excise department.
o Frequent change in the scope of the project to be undertaken by
the borrower.
o Under insured or over insured inventory.
o Invoices devoid of TAN and other details.
o Dispute on title of the collateral securities.
o Costing of the project which is in wide variance with standard cost
of installation of the project.
o Funds coming from other banks to liquidate the outstanding loan
amount.
o Foreign bills remaining outstanding for a long time and tendency for
bills to remain overdue.
o Onerous clause in issue of BG/LC/standby letters of credit.
o In merchanting trade, import leg not revealed to the bank.
o Request received from the borrower to postpone the inspection of
the godown for flimsy reasons.
o Delay observed in payment of outstanding dues.
o Financing the unit far away from the branch.
o Claims not acknowledged as debt.
o Frequent invocation of BGs and devolvement of LCs.
o Funding of the interest by sanctioning additional facilities.
o Same collateral charged to a number of lenders.
o Concealment of certain vital documents like master agreement,
insurance coverage.
o Floating front/ associate companies by investing borrowed money.
o Reduction in the stake of promoter/ director.
o Resignation of the key personnel and frequent changes in the
Management.
o Substantial increase in unbilled revenue year after year.
o Large number of transactions with inter-connected companies and
large outstanding from such companies.
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o Significant movements in inventory, disproportionately higher than
the growth in turnover.
o Significant movements in receivables, disproportionately higher
than the growth in turnover and/or increase in ageing of the
receivables.
o Disproportionate increase in other current assets.
o Significant increase in working capital borrowing as percentage of
turnover.
o Critical issues highlighted in the stock audit report.
o Increase in Fixed Assets, without corresponding increase in
turnover (when project is implemented).
o Increase in borrowings, despite huge cash and cash equivalents in
the borrower's balance sheet.
o Liabilities appearing in ROC search report, not reported by the
borrower in its annual report.
o Substantial related party transactions.
o Material discrepancies in the annual report.
o Significant inconsistencies within the annual report (between
various sections).
o Poor disclosure of materially adverse information and no
qualification by the statutory auditors.
o Frequent change in accounting period and/or accounting policies.
o Frequent request for general purpose loans.
o Movement of an account from one bank to another.
o Frequent ad hoc sanctions.
o Not routing of sales proceeds through bank.
o LCs issued for local trade / related party transactions.
o High value RTGS payment to unrelated parties.
o Heavy cash withdrawal in loan accounts.
o Non submission of original bills.
o Whether there is a system to identify these EWS and take
appropriate remedial action.
o Whether an Anti-fraud policy is in place and communicated to all.
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o Whether Anti-fraud trainings are organized? Whether any fraud risk
scenarios are identified and any fraud control measures mapped to
such risks.
o Whether corporate borrower is a reported shell company, then
peruse the impact on loan account.
Miscellaneous
(i) Does the examination of the accounts indicate possible window dressing?
Compare the aggregate figures as on 15th March, 20XX, 31st March,
20XX and last day of audit.
(ii) Does the branch maintains records of all the fixed assets acquired and
held by it irrespective of whether the values thereof or depreciation thereon
have been centralised? Where documents of title in relation to branch or
other branches are available at the branch, whether the same have been
verified.
Refer the guidelines issued by Head Office in this regard.
Whether, such guidelines are followed strictly.
(iii) Are there any other matters, which you as a branch auditor would like to
bring to the notice of the Management or the Statutory Central Auditors?
Instances are given as under:
System related issues.
Issues relating to Statutory Payments and Accrual of Statutory
Liabilities.
Short / Excess Provisioning in NPA Accounts / Non Provisioning for
SMA2 Accounts.
Compliance with the requirements of RBI and Head Office instructions
for Unhedged Foreign Currency Exposure.
ATM related issues.
Whether AMC's terms are followed strictly.
Security related issues.
Issues which may impact other Branches and not just the branch under
audit.
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.
For XYZ and Co.
Chartered Accountants
Firm's Registration Number
Signature
(Name of the Member Signing the Audit Report)
(Designation)
Membership Number
Place of Signature:
Date:
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Questionnaire Applicable to Specialised Branches
A. For Branches dealing in Foreign Exchange Transactions
1.18 It should be noted that certain branches do not deal in foreign
exchange transactions but foreign currency accounts are maintained there
and all records of account opening documentation are held at these
branches. In such cases, checking and reporting should be done of the
account opening documentation and commented upon in this section of
LFAR.
1. Are there any material adverse features pointed out in the reports of
concurrent auditors, internal auditors and/ or the Reserve Bank of India's
inspection report which continue to persist in relation to NRE/ NRO/ NRNR/
FCNR-B/ EEFC/ RFC and other similar deposit accounts If so, furnish the
particulars of such adverse features.
The auditor should make a written request to the branch Management for
furnishing him the latest available reports of the statutory auditors and of the
concurrent auditor or stock auditor or internal auditors, as also of the RBI
where inspection or special audit has taken place for the branch. The auditor
should scrutinise the contents of such reports in relation to NRE/ NRO/
NRNR/ FCNR-B/ EEFC/ RFC and other similar deposit accounts and take a
note of relevant major adverse comments. In case adverse features are
observed to persist at the branch or where no remedial action has been
initiated or taken by the branch Management, he should report the same.
2. Whether the Branch has followed the instructions and guidelines of
the Controlling Authorities of the bank with regard to the following in relation to
the foreign exchange and, if not, state the irregularities.
(a) deposits
(b) advances
(c) export bills
(d) bills for collection
(e) any other area
The auditor also has to make himself familiar with the relevant aspects of the
Exchange Control Manual and its compliance. The auditor should verify
whether the instruction and guidelines of the Controlling Authorities of the
bank in relation to the foreign exchange have been followed by the branch in
respect of these areas. If any irregularity is observed the same should be
reported with details. Auditor to verify proper filing of BEF & XOS returns.
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3. Obtain a list of all NOSTRO Accounts maintained/ operated by the
Branch from the branch Management.
The auditor should obtain a list of all NOSTRO Accounts for the purpose of
verification from the branch Management.
(a) Are the NOSTRO Accounts regularly operated?
The auditor should verify whether the NOSTRO Accounts are being
regularly operated. If not give the list of NOSTRO Accounts with
balances outstanding, which are not operated regularly, the date of last
transaction, etc. The auditor should specifically comment on overdrafts
in NOSTRO accounts, if any.
(b) Are periodic balance confirmations obtained from all concerned overseas
branches/ correspondents?
The auditor should verify whether the balance confirmation from all
concerned overseas branches/ correspondents have been obtained on
a periodic basis. He should report the names of the bank and the period
wise outstanding balances, which remain unconfirmed.
(c) Are these accounts duly reconciled periodically? Your observations on the
reconciliation may be reported.
While examining the transaction in foreign exchange, the auditor should
also pay attention to reconciliation of NOSTRO Accounts with the
respective mirror account. The amount in the NOSTRO account is stock
of foreign currency in the form of bank accounts with the overseas
branches and correspondents. Un-reconciled NOSTRO Accounts, on an
examination, may reveal unauthorised payments from the foreign
currency account, unauthorised withdrawals, and unauthorised debit to
mirror account. The auditor should also evaluate the internal control
with regard to inward/ outward messages. The inward/outward
messages should be properly authenticated and discrepancies noticed
should be properly dealt with in the books of accounts. In case balance
confirmation certificate have been received but the same have not been
reconciled, the auditor should report, in respect of each bank, the
balances as per books maintained by the branch and the balance as per
the relevant balances confirmation certificate, stating in either case
whether the balance is debit or credit.
(d) Whether the branch is following HO guidelines for reporting requirements
under Foreign Account Tax Compliance Act (FATCA) and Common
Reporting Standards (CRS).
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4. Does the Branch follow the prescribed procedures in relation to
maintenance of VOSTRO Accounts?
The auditor should verify whether prescribed procedure in relation to inter-
bank confirmation in the VOSTRO account is followed or not. In case balance
confirmation certificate have been received but the same have not been
reconciled, or where confirmation has not been received the same should be
reported, in respect of each VOSTRO Account. The RBI has also issued the
Master Directions FED Master Direction No.2 /2015-16 dated January 01,
2016 (updated on August 31, 2018) on "Opening and Maintenance of
Rupee/Foreign Currency VOSTRO Accounts of Non-resident Exchange
Houses".
B. For branches dealing in very large advances, such as, Corporate
Banking Branches and Industrial Finance Branches or branches with
advances in excess of Rs. 100 crores
1. In respect of borrowers with outstanding of Rs. 2 crores and above,
the information in the enclosed format should be obtained from the Branch
Management. Comments of the Branch Auditor on advances with significant
adverse features and which might need the attention of the Management/
Statutory Central Auditors should be appended to the Long Form Audit Report.
The branch auditor should obtain details and other information, in respect of
all advances, which are in excess of Rs. 2 crores, which would be relevant to
complete the enclosed format from branch manager.
Any advances account with significant adverse features like, non-operative
for quite a long time, renewed without adequate credit appraisal, fresh
advances granted without obtaining necessary approval, etc., on which
branch auditor has commented and which is of such a nature that statutory
central auditor is required to consider it for qualifying and/or disclosing in
main report, should be attached as an annexure to LFAR. In cases where
limits are allocated to any branch, by a Main branch, the exchange of
information between branches has to be verified.
2. What, in your opinion, are the major shortcomings in credit appraisal,
monitoring, etc.?
Major shortcomings in credit appraisal will have to be disclosed in the LFAR
which could either be stated on the face of the report or could be reference to
an annexure. Examples of major shortcomings in credit appraisal are stated
below:
Loan application not on record at Branch.
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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 form.
Basic documents such as Memorandum and Articles of Association,
Partnership deed, etc., which are pre-requisite to determine the status of
the borrower have not been obtained.
Certain adverse features of the borrower not incorporated in the appraisal
note forwarded to the Management.
Industry/ group exposure and past experience of the Bank is not dealt in
the appraisal note sent to the Management for sanction.
The level for inventory/ book-debts/ creditors for finding out the working
capital is not properly assessed.
Techno-economic feasibility report, which is required to know the technical
aspects of the borrower's business, is not obtained from Technical Cell.
Credit report on principal borrowers and confidential report from their
banks are not insisted from the borrowers.
The opinion reports of the associate and/or sister concerns of the borrower
are not scrutinised/ called for/ not updated/ not satisfactory.
The procedure/ instructions of Head Office regarding preparation of
proposals for grant or proposals for renewal of advances or proposals for
enhancement of limits, etc., are not followed.
No exposure limits are fixed for forward contract for foreign exchange
sales/ purchase transactions.
No adequate security obtained/ charge created.
The director/borrower's names do not appear in RBI/CIBIL defaulters list.
3. List the accounts (with outstanding in excess of Rs.1 crore), which
have either been downgraded or upgraded with regard to their classification as
Non Performing Asset or Standard Asset during the year and the reasons
therefore.
For advance accounts where outstanding balance is in excess of Rs. 1 crore
and which have been re-classified from non-performing asset to standard
asset or vice-a-versa, the list will have to be attached to the report specifying
the reasons with brief explanations for such re-classification.
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C. For branches dealing in recovery of Non Performing Assets such
as Asset Recovery Management Branches
1. In respect of every advance account in excess of Rs. 2 crores, the
information in the enclosed format should be obtained from the Branch
Management. Comments of the Branch Auditor on advances with significant
adverse features and which might need the attention of the
Management/Central Statutory Auditors should be appended to the Long Form
Audit Report.
The Branch auditor should obtain details and other information, in respect of
all advances, which are in excess of Rs. 2 crores, which would be relevant to
complete the format (given in the Annexure) obtained from branch
Management.
Any advances account with significant adverse features like, non-operative
for quite a long time, renewed without adequate credit appraisal, fresh
advances granted without obtaining necessary approval, etc., on which
branch auditor has commented and which is of such a nature that attention of
central statutory auditor requires to consider it for qualifying and/ or
disclosing in main report, should be attached as an annexure to LFAR.
2. List the accounts (with outstanding in excess of Rs. 2 crores), which
have been upgraded from Non Performing to Standard Assets during the year
and the reasons therefor.
For advance accounts where outstanding balance are in excess of Rs. 2
crores which have been reclassified from Non Performing Assets to Standard
Assets, the list will have to be attached to the report specifying the reasons
with brief explanations for such re-classification.
3. Whether the Branch has a system of updating periodically, the information
relating to the valuation of security charged to the bank?
The branch auditor should enquire as to the existence of the system, if any,
pertaining to the valuation of security charged to the bank. If the system is in
existence, the auditor should examine whether the system periodically updates
the information pertaining to the value of such security and takes necessary
steps for increase/diminution in the value of such security.
4. Age-wise analysis of the recovery, suits-filed and pending may be
furnished.
Age-wise analysis of the recovery suits filed and pending should be given
along with the current status of each recovery suit.
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5. Is the Branch prompt in ensuring execution of decrees obtained for
recovery from the defaulting borrowers? Also list the time-barred decrees, if
any and reasons therefor.
In case decrees have been obtained for recovery from the defaulting
borrowers, the auditor should check whether the branch is prompt in
execution of decrees like, drawings from the account and payment from
these accounts have been stopped. If not, the same should be reported. The
list should be given in the case of time barred decrees with the reasons
therefor.
6. List the recoveries and their appropriation against the interest and the
principal and the accounts settled/ written off/ closed during the year.
A list will have to be annexed which will specify the non-performing advances
recovered and the amounts adjusted towards interest and principal. A list of
the accounts settled, written closed, if any, will also have to be attached. The
auditor should satisfy himself whether the recoveries appropriated against
interest are in accordance with the RBI guidelines and normal accounting
principles.
7. List the new borrower accounts transferred to the Branch during the year.
Have all the relevant documents and records relating to these borrower accounts
been transferred to the Branch? Has the Branch obtained confirmation that all the
accounts of the borrower (including non-fund based exposures and deposits pending
adjustment/ margin deposits) been transferred to the Branch?
A list of new borrower accounts transferred to the branch from the other
branches during the year should be annexed. The auditor should verify whether
the documents and records relating to the transferred accounts have been
obtained like, letter from the transferor branch, detail of the accounts, etc. The
branch should also obtain a confirmation that all the accounts of the borrower
(including non-fund based exposures and deposits pending adjustment/ margin
deposits) have been transferred to the branch. In case any adverse features
have been observed in such transfer, the same should be reported.
D. For branches dealing in Clearing House Operations, normally
referred to as Service Branches
1. Does the branch have a system of periodic review of the outstanding
entries in clearing adjustments accounts? In your view has the system
generally been complied with?
The auditor should verify whether the branch is having system of periodic
review of the outstanding entries in clearing adjustments accounts. On a test
check, auditor should verify whether the system, generally, has been
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complied with.
2. Whether review of the clearing adjustments accounts (inwards/
outwards) reveals any old/ large/ unusual outstanding entries, which remain
unexplained? Give year-wise break-up of outstanding in number and value:
If the review of clearing adjustments accounts (inwards/outwards) reveals
any old/large/unusual outstanding entries, which remain unexplained, the
auditor should report the same. Year-wise break up should be given of
outstanding clearing in number and value in the following format:
Inward Clearing
Number Value
Normal Clearings
High Value Clearings
Inter-Branch Clearings
National Clearings
Returned/ Dishonored Clearings
Outward Clearing
Number Value
Normal Clearings
High Value Clearings
Inter-Branch Clearings
National Clearings
Returned/ Dishonored Clearings
3. Has the Branch strictly followed the guidelines of the Controlling
Authority of the bank with respect to operations related to clearing
transactions? Comment on the systems and procedures followed by the
Branch in this regard.
Auditor should verify whether the guidelines of the Controlling Authority of the
bank with respect to operations related to clearing transactions has been
strictly followed. In case the same has not been followed, the auditor should
report the same. The auditor should report on the system and procedures
followed by the branch in this regard.
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Guidance Note on Audit of Banks (Revised 2019)
Annexure
LFAR (For Large/ Irregular/ Critical Advance Accounts)
(To be obtained from the branch Management by the Branch Auditors of
branches dealing in large advances/ asset recovery branches)
1. Name of the Borrower
2. Address
3. Constitution
4. Nature of business/ activity
5. Other units in the same group
6. Total exposure of the branch to the Group+
Fund Based (Rs. in lakhs)
Non-Fund Based (Rs. in lakhs)
7. Name of Proprietor/ Partners/ Directors
8. Name of the Chief Executive, if any
9. Asset Classification by the Branch
(a) during the current year
(b) during the previous year
10. Asset Classification by the Branch Auditor
(a) during the current year
(b) during the previous year
11. Are there any adverse features pointed out in relation to asset
classification by the Reserve Bank of India Inspection or any other
audit.
12. Date on which the asset was first Classified as NPA. (where
applicable)
Facilities sanctioned:
Date of Nature of Limit Prime Collateral Margin Balance
Sanc- facilities (Rs. in Security Security % outstanding at the
tion Lakhs) year-end
Current Previous
Year Year
Provision made: Rs.________ lakhs
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13. Whether the advance is a consortium advance or an advance made
on multiple-bank basis.
14. If Consortium,-
(a) names of participating banks with their respective shares.
(b) name of the Lead Bank in Consortium.
15. If on multiple banking basis, names of other banks and evidence
thereof.
16. Has the Branch classified the advance under the Credit Rating
norms in accordance with the guidelines of the Controlling
Authorities of the Bank.
17. (a) Details of verification of primary security and evidence
thereof;
(b) Details of valuation and evidence thereof.
Date verified Nature of Security Value Valued by
Insured for Rs. _______ lakhs (expiring on ________)
18. (a) Details of verification of collateral security and evidence
thereof;
(b) Details of valuation and evidence thereof.
Date Nature of Security Value Valued by
verified
Insured for Rs. _______ lakhs (expiring on ________)
19. Give details of the Guarantee in respect of the advance
(a) Central Government Guarantee;
(b) State Government Guarantee;
(c) Bank Guarantee or Financial Institution Guarantee;
(d) Other Guarantee.
Provide the date and value of the Guarantee in respect of the above.
20. Compliance with the terms and conditions of the sanction:
Terms and Conditions Compliance
(i) Primary Security
a) Charge on primary security
b) Mortgage of fixed assets
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Terms and Conditions Compliance
c) Registration of charges with Registrar of
Companies
d) Insurance with date of validity of Policy
(ii) Collateral Security
a) Charge on collateral security
b) Mortgage of fixed assets
c) Registration of charges with Registrar of
Companies
d) Insurance with date of validity of policy
(iii) Guarantees - Existence and execution of valid
guarantees
(iv) Asset coverage to the branch based upon the
arrangement (i.e., consortium or multiple-bank
basis)
(v) Others:
a) Submission of Stock Statements/ Quarterly
Information Statements and other
Information Statements
b) Last inspection of the unit by the Branch
officials: Give the date and details of errors/
omissions noticed
c) In case of consortium advances, whether
copies of documents executed by the
company favouring the consortium are
available.
d) Any other area of non compliance with the
terms and conditions of sanction
21. Key financial indicators for the last two years and projections for the
current year: (Rs. in lakhs)
Indicators Audited Audited Estimates for
year ended year ended year ended 31st
31st 31st March ___
March___ March___
Turnover
Increase in turnover % over
previous year
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Long Form Audit Report in Case of Bank Branches
Profit before depreciation,
interest and tax
Less: Interest
Net Cash Profit before tax
Less: Depreciation
Less: Tax
Net Profit after Depreciation
and Tax
Net Profit to Turnover Ratio
Capital (Paid-up)
Reserves
Net Worth
Turnover to Capital
Employed Ratio
(The term "Capital
Employed" means the sum
of Net Worth and Long
Term Liabilities)
Current Ratio
Stock Turnover Ratio
Total Outstanding
Liabilities/Total Net Worth
Ratio
In case of listed companies,
Market Value of Shares
(a) High;
(b) Low; and
(c) Closing
Earnings Per Share
Whether the accounts were
audited? If yes, upto what
date; and are there any
audit qualifications
22. Observations on the operations in the account:
Excess over Excess over limit
drawing power
1. No. of occasions on which
the Balance exceeded the drawing
power/ sanctioned limit (give details)
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Reasons for excess drawings, if any
Whether excess drawings were
reported to the Controlling Authority
and approved
Debit Summation Credit
(Rs. in Lakhs) Summation
(Rs. in Lakhs)
2. Total summation in the
account during the year
Less: Interest Balance
23. Adverse observations in other audit reports/ Inspection Reports/
Concurrent Auditor's Report/ Internal Audit Report/ Stock Audit
Report/ Special Audit Report or Reserve Bank of India Inspection
with regard to:
(i) Documentation; (ii) Operations;
(iii) Security/Guarantee; and (iv) Others.
24. Branch Manager's overview of the account and its operation.
25. (a) In case the borrower has been identified/ classified as Non-
performing Asset during the year, whether any unrealised
income including income accrued in the previous year has
been accounted as income, contrary to the Income
Recognition Norms.
(b) Whether any action has been initiated towards recovery in
respect of accounts identified/ classified as Non-performing
Assets.
Date: Signature and Seal of Branch-in-Charge
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PART - VI
VI-1
Basel III
Introduction
1.01 Basel capital adequacy norms are meant for the protection of depositors
and shareholders by prescriptive rules for measuring capital adequacy, thereby
evolving methods of determining regulatory capital and ensuring efficient use of
capital.
1.02 Basel III accord strengthens the regulation, supervision and risk
management of the banking sector. It is global regulatory standard on capital
adequacy of banks, stress testing as well as market liquidity risk.
1.03 The Basel III accord, aims at:
a. improving the banking sector's ability to absorb shocks arising from financial
and economic stress, whatever may be the source;
b. improving risk management and governance practices; and
c. strengthening banks' transparency and disclosure standards.
1.04 Basel II has been fully implemented in all commercial banks (except
RRBs and LABs) in India by March 31, 2009. In this regard, the RBI has also
issued a Master Circular no. DBR.No.BP.BC.4/21.06.001/2015-16 dated July 1,
2015 on "Prudential Guidelines on Capital Adequacy and Market Discipline - New
Capital Adequacy Framework (NCAF)".
1.05 The major changes made in Basel III over Basel II are as under:
(a) Quality of Capital: One of the key elements of Basel III is the introduction
of much stricter definition of capital, which means the higher loss-absorption
capacity, which in turn would lead to banks becoming stronger with
enhanced capacity to withstand periods of stress.
(b) Capital Conservation Buffer: Beginning 31st March, 2016, Banks are
required to hold capital conservation buffer of 0.625%, which will gradually
increase to 2.5% by 31st March, 2019. This is to ensure that banks maintain
a cushion of capital that can be used to absorb losses during periods of
financial and economic stress.
Guidance Note on Audit of Banks (Revised 2019)
(c) Counter cyclical Buffer: The counter cyclical buffer ensures increased
capital requirements in good times and decrease the same during bad
times.
(d) Minimum Common Equity and Tier 1 Capital Requirement: The
minimum requirement for common equity, the highest form of loss-
absorbing capital, has been increased to 5.50% of RWA. The Minimum Tier
1 capital has been increased to 7%, which means that Additional Tier I (AT
1) capital can be maximum of 1.50% of RWA. Though, the minimum total
capital (Tier I plus Tier II) requirement remains at 9%, which means that the
Tier 2 capital can be admitted maximum of 2% of RWA. With the
requirement of gradually maintaining 2.5% of RWA as Capital Conservation
Buffer in the form of CET 1, the minimum total capital requirement shall
increase to 11.50% of RWA by 31st March, 2019.
(e) Leverage Ratio: Analysis of 2008 financial crisis indicates that value of
assets went down much more than what was perceived based on their risk
rating, which leads to stipulation of Leverage Ratio. Therefore, under Basel
III, a simple, transparent, non-risk based leverage ratio has been
introduced. A Leverage Ratio is the relative amount of capital to total assets
(not risk-weighted). Basel III guidelines recommend leverage ratio of 3% but
RBI has Currently set the leverage ratio of more than 4.5% for Indian
Banks.
(f) Liquidity Ratios: Under Basel III, a framework for liquidity risk
management has been set up. Liquidity Coverage Ratio (LCR) has become
operational since 1st January, 2015.
1.06 Basel III capital regulation has been implemented from April 1, 2013 in
India in phases and it will be fully implemented as on March 31, 2019. In view of
the gradual phase-in of regulatory adjustments to the Common Equity
component of Tier 1 capital under Basel III, certain specific prescriptions of Basel
II capital adequacy framework (e.g. rules relating to deductions from regulatory
capital, risk weighting of investments in other financial entities etc.) will continue
to apply till March 31, 2018 on the remainder of regulatory adjustments not
treated in terms of Basel III rules. In this regard, the RBI has also issued a
Master Circular no. DBR.No.BP.BC.1/21.06.201/2015-16 dated July 1, 2015 on
"Basel III Capital Regulations".
Guidelines on BASEL III Capital Regulations
1.07 The RBI had issued a circular no. DBOD.No.BP.BC.98
/21.06.201/2011-12 dated May 2, 2012 on the subject "Guidelines on
Implementation of Basel III Capital Regulations in India". Vide this circular, the
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Basel III
RBI has prescribed the final guidelines on Basel III capital regulations. RBI
issued a master circular no. DBR.No.BP.BC.1/21.06.201/ 2015-16 dated July 1,
2015 on Basel III Capital Regulations. Following are main features of these
guidelines:
These guidelines became effective from April 1, 2013 in a phased manner.
The Basel III capital ratios will be fully implemented as on March 31, 2019.
The capital requirements for the implementation of Basel III guidelines may
be lower during the initial periods and higher during the later years. While
undertaking the capital planning exercise, banks should keep this in view.
Liquidity Coverage Ratio has been introduced in a phased manner starting
with a minimum requirement of 60% from January 01, 2015 and reaching
minimum 100% on January 01, 2019.
The banks are required to disclose capital ratios under Basel III from
quarter ending June 30, 2013.
Components of Capital
1.08 Total regulatory capital will consist of the sum of the following
categories:
(i) Tier 1 Capital (going-concern capital)
(a) Common Equity Tier 1
(b) Additional Tier 1
(ii) Tier 2 Capital (gone-concern capital)
Limits and Minima
Regulatory Capital As % to
RWAs
(i) Minimum Common Equity Tier 1 Ratio 5.5
(ii) Capital Conservation Buffer (comprised of Common Equity) 2.5
(iii) Minimum Common Equity Tier 1 Ratio plus Capital 8.0
Conservation Buffer [(i)+(ii)]
(iv) Additional Tier 1 Capital 1.5
(v) Minimum Tier 1 Capital Ratio [(i) +(iv)] 7.0
(vi) Tier 2 Capital 2.0
(vii) Minimum Total Capital Ratio (MTC) [(v)+(vi)] 9.0
(viii) Minimum Total Capital Ratio plus Capital Conservation 11.5
Buffer [(vii)+(ii)]
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Guidance Note on Audit of Banks (Revised 2019)
Capital What Constitutes Tier 1 and Tier 2 a Representative
Sample
1.09 The Master Circular on Basel III Capital Regulations discusses the
capital funds in two categories capital funds for Indian banks and capital
funds of foreign banks operating in India. The following table shows the
components of the capital funds for Indian vis a vis foreign banks operating in
India:
Indian Banks Foreign Banks operating in
India
Tier I Capital Paid up equity capital Interest free funds from Head
Common Equity (ordinary shares)17 Office18
Tier I (CET 1) Share premium on issue of
common shares
Statutory reserves Statutory reserves kept in Indian
books
Capital reserves representing Capital reserves representing
surplus arising out of sale surplus arising out of sale of
proceeds of assets assets in India held in a separate
account and which is not eligible
for repatriation so long as the
bank functions in India
Other disclosed free Remittable surplus retained in
reserves, if any Indian books which is not
repatriable so long as the bank
functions in India
Revaluation reserves with Revaluation reserves with
discount of 55% (with effect discount of 55% (till 29th February
from 1st March 2015), subject 2016), subject to meeting
to meeting conditions conditions prescribed in RBI
prescribed in RBI circular circular dated 1st March 2016
dated 1st March 2016
Foreign currency translation Foreign currency translation
reserve arising due to reserve arising due to translation
translation of financial of financial statements of their
statements of their foreign foreign operations in terms of
operations in terms of Accounting Standard (AS) 11 at a
Accounting Standard (AS) 11 discount of 25%, subject to
at a discount of 25%, subject meeting conditions prescribed in
to meeting conditions RBI circular dated 1st March 2016
17
Refer Annexure 1 to Master Circular on Basel III Capital Regulations for criteria.
18
Refer Annexure 2 to Master Circular on Basel III Capital Regulations for criteria.
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Basel III
prescribed in RBI circular
dated 1st March 2016
Balance in Profit & Loss
Account at the end of the
previous financial year
Profits of current financial
year on a quarterly basis
provided the incremental
provisions made for NPA at
the end of any of the four
quarters of the previous
financial year have not
deviated more than 25% from
the average of the four
quarters with certain
adjustments given in the
Master Circular
Interest free funds remitted from
abroad for the purpose of
acquisition of property and held in
a separate account in Indian
books provided they are non-
repatriable and have the ability to
absorb losses regardless of their
source
Less: Regulatory Less: Regulatory adjustments /
adjustments / deductions deductions applied in the
applied in the calculation of calculation of Common Equity
Common Equity Tier 1 capital Tier 1 capital
Additional Tier I Perpetual non-cumulative Head office borrowings in foreign
(AT 1) preference shares19 currency by foreign banks
operating in India as per criteria20
Share premium on
instruments included in AT 1
capital
Debt Capital instruments
including Perpetual Debt
instruments21
Any other instrument notified Any other instrument notified by
by RBI from time to time RBI from time to time
19
Refer Annexure 3 to Master Circular on Basel III Capital Regulations for criteria.
20
Refer Annexure 4 to Master Circular on Basel III Capital Regulations for criteria.
21
Refer Annexure 4 to Master Circular on Basel III Capital Regulations for criteria.
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Guidance Note on Audit of Banks (Revised 2019)
Less: Regulatory Less: Regulatory adjustments /
adjustments / deductions deductions applied in the
applied in the calculation of calculation of Additional Tier 1
Additional Tier 1 capital capital
Tier II Capital Revaluation reserves with Revaluation reserves with
discount of 55% (till 29th discount of 55% (till 29th February
February 2016) 2016)
General provisions and loss General provisions and loss
reserves reserves
Debt Capital instruments22 Head Office (HO) borrowings in
foreign currency received as part
of Tier 2 debt capital
Perpetual Cumulative Perpetual Cumulative Preference
Preference Shares (PCPS)/ Shares (PCPS)/ Redeemable
Redeemable Non- Non- Cumulative Preference
Cumulative Preference Shares (RNCPS)/ Redeemable
Shares (RNCPS) cumulative preference shares
/Redeemable cumulative (RCPS)24
preference shares(RCPS)23
Premium on instruments
included in Tier 2
Less: Regulatory Less: Regulatory adjustments /
adjustments / deductions deductions applied in the
applied in the calculation of calculation of Tier 2 capital
Tier 2 capital
1.10 In case of foreign banks operating in India, RBI's Master Circular on
Capital Adequacy also lays down certain additional provisions in respect of
capital to be followed by such banks.
1.11 Capital instruments which no longer qualify as AT 1 capital or Tier 2
capital (e.g. IPDI and Tier 2 debt instruments with step-ups) will be phased out
beginning January 1, 2013. Fixing the base at the nominal amount of such
instruments outstanding on January 1, 2013, their recognition will be capped at
90% from January 1, 2013, with the cap reducing by 10% in each subsequent
year. This cap will be applied to Additional Tier 1 and Tier 2 capital instruments
separately and refers to the total amount of instruments outstanding which no
longer meet the relevant entry criteria. The following chart graphically depicts the
provisions relating to such instruments:
22
Refer Annexure 5 to Master Circular on Basel III Capital Regulations for criteria.
23
Refer Annexure 6 to Master Circular on Basel III Capital Regulations for criteria.
24
Refer Annexure 6 to Master Circular on Basel III Capital Regulations for criteria.
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Basel III
TRANSITIONAL ARRANGEMENTS FOR NON-EQUITY REGULATORY
CAPITAL INSTRUMENTS
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Guidance Note on Audit of Banks (Revised 2019)
Deductions from CET I, AT I and Tier II
1.12 The deductions from CET I, AT I and Tier II are tabulated below:
Item Extent of Deduction
(in %)
CET I AT 1 Tier II
Intangible assets including Goodwill 100 ---
Losses in the current period 100 ---
Losses brought forward from previous 100 ---
periods
Deferred tax asset associated with 100 ----
accumulated losses
Cash Flow hedge reserve 100 ---
Shortfall of provisions to expected losses 100 ---
Gains on sale related to securitisation 100 ---
transactions
Cumulative Gains and losses due to 100 ---
changes in own credit risk on fair valued
liabilities
Defined benefit pension fund liabilities and 100 -
un-amortised employees' benefits
Investments in own shares (if not already 100 ---
netted off paid-up capital on reported
balance sheet) including indirect investments
DTAs which relate to timing differences Excess of ----
(other than those related to accumulated 10% of CET-
losses) 1
DTAs on timing difference along with limited Excess of
recognition of significant investments in the 15% of CET-
common shares of unconsolidated financial 1
(i.e. banking, financial and insurance) entities
taken together
Equity investments in insurance subsidiaries 100
Investments in equity instruments of other 100
subsidiaries and capital of other Banks,
insurance companies etc. which is more than
10% of Bank's CET1
Equity investments in non-financial 100
subsidiaries
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Basel III
Intra group transactions beyond permissible 100
limits
Reciprocal cross investments in capital of Full Full Full
other banks in the same component of capital
Securitization exposure 50 50
Investment in financial subsidiaries and 50 50
associates which is above 30 per cent in the
paid up equity of entity and not consolidated
for the capital adequacy purposes
Shortfall in the regulatory capital 50 50
requirements in the de-consolidated entity
Such amount of investment in the following 50 50
which is in excess of 10% of investing
bank's capital funds:
· Equity shares;
· Perpetual Non- Cumulative Preference
Shares;
· Innovative Perpetual Debt Instruments;
· Upper Tier II Bonds;
· Upper Tier II Preference Shares;
· Subordinated debt instruments; and
· Any other instrument approved as in the
nature of capital.
Investments made by a banking 50 50
subsidiary/associate in the equity or non-
equity regulatory-capital instruments
issued by its parent bank
If net overseas placements with Head 100 ---
Office/other overseas branches/other
group entities exceed 10% of the bank's
minimum CRAR requirement, the amount
in excess of this limit would be deducted
from Tier I capital
Capital to Risk-weighted Assets Ratio (CRAR)
1.13 The RBI requires banks to maintain a minimum CRAR of 9 per cent on
an ongoing basis. The Master Circular on Capital Adequacy contains detailed
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Guidance Note on Audit of Banks (Revised 2019)
guidelines on calculation of risk weighted assets and off-balance sheet items and
CRAR.
1.14 The CRAR is computed as follows:
Eligible Total Capital funds × 100
----------------------------------------------------------------------------------------
Credit Risk RWA + Market Risk RWA + Operational Risk RWA
1.15 The minimum CRAR is required to be maintained at consolidated level
also as per Basel III guidelines. The requirements mentioned above relates to
standalone Bank only. For the requirement for the consolidated capital, the
readers may refer the Master Circular on Basel III Capital Regulations.
Board Oversight
1.16 The board of directors and senior management of each
subsidiary/overseas branch should be responsible for conducting their own
assessment of the subsidiary's/overseas branch's operational risks and controls
and ensuring the subsidiary/overseas branch is adequately capitalised in respect
of those risks.
Disclosure (Pillar 3)
1.17 Pillar 3 aims primarily at disclosure of a bank's risk profile and capital
adequacy. It is recognised that the Pillar 3 disclosure framework does not conflict
with requirements under accounting standards, which are broader in scope. The
banks in India have to follow Pillar 3 disclosure over and above the RBI master
circular on "Disclosure in Financial Statements - Notes to Accounts". Information
would be regarded as material if its omission or misstatement could change or
influence the assessment or decision of a user relying on that information. Pillar 3
disclosures will be required to be made by the individual banks on a standalone
basis when they are not the top consolidated entity in the bank.
Role of Auditors of Banks
1.18 Based on RBI appointment letter, the external auditors of the bank are
required to provide a certification on the capital adequacy ratio computation. The
auditor needs to understand more comprehensively the approach and
mechanism adopted by the bank, and accordingly certify the computation.
Considering the intricacies involved in the computation itself further
supplemented by enhanced judgement factor, it would be prudent for the
certifying auditor to obtain an adequate understanding of the Basel III norms as
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Basel III
prescribed by RBI and also deploy more senior members of its staff to audit the
capital adequacy computations.
1.19 Further, some banks may also avail services of their external auditors to
review the quality of internal controls and systems, and assess the scope and
adequacy of the internal audit function.
1.20 In the concept of Basel III, the capital computation is primarily aimed
from central/head office perspective. Basel III is not only about capital adequacy
but is also about creating a robust risk management structure. Hence, apart from
the capital adequacy computation, the auditors should verify the robustness of
the risk management structure embedded in the bank, across its branches. This
risk management spreads across all the types of risk, i.e., credit risk, market risk
and operational risk. Hence, the auditors also play a critical role in ensuring that
the bank has adopted a consistent practice and as part of their attest function
report on its appropriateness of risk management practice as well on the RWA.
Role of Branch Auditors
1.21 In case of credit risk management, the underlying computation for Basel
III is based on credit ratings, which may be driven centrally and passed on to
branches such that branches follow head office instructions in its entirety. This
way the bank branch auditors check only the computation process and test check
the source rather than getting into the credit rating process. The branch auditors
can assess any issues relating to completeness and correctness of the data,
which is used to compute the underlying risks emanating from credit market and
operational risk. It is finally the pyramid approach whereby all the data from
branches will get consolidated at head office. The statutory central auditors may
choose to test check certain source data and also verify the basis considered at
the head office.
1.22 It will not be practical to expect the branch to comprehensively
understand the Basel III requirements in its entirety. The bank branch auditor
should assess the sufficiency of the instructions provided to the branch by the
head office and its adherence at the branch level. Any errors at bank branch level
can have a cascading effect at the head office, especially when a large number
of branches are involved.
1.23 The Statutory Central Auditors should primarily look into the
computation of components of various capital as part of their attest function. As
regards the overall capital adequacy computation, particularly with respect to
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Guidance Note on Audit of Banks (Revised 2019)
RWAs, while the granular data may have been audited by the Branch Statutory
Auditors, the Statutory Central Auditors, apart from verifying the consolidation of
data emanating from branches/regions/zones/circles etc. should perform the test
of reasonableness as well as completeness. As per requirements set by the RBI,
the Statutory Central Auditors are required to certify the capital adequacy
computation. The Statutory Central Auditors may review the work done by
internal auditors, as may be stipulated by the management or the regulators. The
Basel Accord does provide specific areas where internal auditors play a role. An
Illustrative Audit Checklist for Capital Adequacy is given in Appendix XII of the
Guidance Note.
394
VI-2
Special Purpose Reports and
Certificates
Introduction
2.01 The SBAs / SCAs have to issue various certificates at branch / Head
Office level. SBAs/SCAs should ensure the correctness of financial implication
caused due to such frauds and confirm that the adequate provision for the same
has been effected.
Regulatory Requirements
2.02 The Reserve Bank of India vide its Master Direction No:
DBS.CO.CFMC.BC.No.1/23.04.001/2016-17 Dated July 01, 2016 (updated July
03, 2017) on "Frauds- Classification and Reporting", issued guidelines for
classification of frauds and reporting of frauds to RBI, Central Office as well as
the concerned regional office of the Department of Banking Supervision /
Financial Conglomerate Monitoring Division (FCMD) at Central Office under
whose jurisdiction the bank's Head Office/branch is situated. The reporting
requirements for various categories of frauds based on financial exposure are
specified in the aforesaid Master Directions.
2.03 While issuing a special purpose report or certificate, the auditors
should bear in mind the recommendations made in the Guidance Note on
Reports or Certificates for Special Purposes (Revised 2016) issued by the
Institute of Chartered Accountants of India (ICAI).
Audit Approach
2.04 The SBAs may verify the contents of certificates to be issued at branch
level. All the Returns submitted by branch to various higher authorities of the
respective bank and also to various authorities of the regulators as per the
Master Directions dated July 03, 2017 shall be verified. Branch Auditors should
ensure the correctness of financial implication caused due to such frauds and
confirm that the adequate provision for the same has been effected.
Guidance Note on Audit of Banks (Revised 2019)
2.05 SCAs of the bank may verify the compilation of all such reports received
from SBAs regarding the frauds and check whether adequate provision for the
same is effected at Head Office. SCAs should also verify the returns submitted
by the bank to regulators regarding such frauds during the year under audit.
2.06 SCAs may verify the methodology used by the bank in reporting of such
frauds from branches to regional / zonal / circle offices and to head office. SCAs
shall verify the existence of internal control mechanism in place to ensure
completeness and correctness of such reporting and classification of frauds in
the bank.
2.07 SCAs may also check the reporting and classifications of frauds at the
Head Office level, where the cases other than those reported through reports
SBAs are considered.
2.08 SCAs may also check that the Board of Directors and Audit Committee
of bank are being regularly updated with reporting and classification on frauds
throughout the year under audit.
Certificates and Reports
2.09 In addition to their audit reports, the SBAs and SCAs may also be
required by their terms of engagement or statutory or regulatory requirements
to issue other reports or certificates. For example, presently, the branch
auditors are required to issue reports/certificates on the following matters
besides their main audit report:
Long Form Audit Report for Branch. (Discussed in Part V of the Guidance
Note)
Report on whether the income recognition, asset classification and
provisioning have been made as per the guidelines issued by the RBI from
time to time.
Report on audit of DICGC items, wherein auditors have to specifically
verify and certify the correctness of the data in various returns and the
insurance premiums paid to DICGC.
Report on status of the compliance by the bank with regard to the
implementation of recommendations of the Ghosh Committee relating to
frauds and malpractices and of the recommendations of the Jilani
Committee on internal control and inspection/credit system.
Certificate for Prime Minister Rozgar Yojna for Unemployed Youth.
396
Special Purpose Reports and Certificates
Certificate of cash and bank balances.
Certificate relating to MOC entries of the previous years being accounted
for.
Certificate relating to credit/ deposit ratio.
Certification of technology up gradation fund scheme (TUFS) non SSI
textile centre.
Certification for advances to infrastructure project and income generated
thereon.
Statement of accounts Re-structured/ Re-scheduled/ Re-negotiated related
to CDR and non-CDR accounts.
Certificate of advances exceeding Rs.10 Crores.
Certificate regarding Special Deposit Scheme, 1975.
Certificate regarding Compulsory Deposit (Income-tax Payers) Scheme,
1974.
Certificate relating to recoveries in claim paid accounts under Small Loans
Guarantee Scheme 1971/Small Loans (SSI) Guarantee Scheme, 1981.
Certification of Borrowal Companies by Chartered Accountants/Company
Secretaries (as per RBI circular on "Lending under Consortium
Arrangements/ Multiple banking Arrangements" dated December 08, 2008.
Certificate on Capital Adequacy
Certificate for Gold Stocks held for Sale of Gold/Metal Gold Loans.
Certificate for Gold Coins Held.
Certificate for Gold Deposit Scheme.
Certificate for IRAC Status of Credit Exposure in respect of Non-Performing
Investments.
Certificates for IRAC Status of Credit Exposure in respect of borrowers
having exposure with foreign offices.
Certificate for agricultural interest subvention claim @2% for residual period
of repayment of the loans disbursed during Financial Year.
Certificate for agricultural interest subvention claim @2% for disbursements
made during Financial Year.
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Guidance Note on Audit of Banks (Revised 2019)
Certificate for additional interest subvention (Incentive @3%) for prompt
repayment for short term production loans disbursed during Financial Year.
Certain other certificates as may be prescribed by the concerned bank in
their respective closing instructions or appointment letters.
Certificate on Unhedged Foreign Currency Exposure in case of Borrowal
having exposure of 1 crore or more.
Certificate on exposure to sensitive sectors, i.e. exposure to Capital
Market, Infrastructure & Real Estate Sector.
2.10 Besides this, SCAs are required to give following certificates/reports:
Certificate on Corporate Governance.
Report on whether the treasury operations of the bank have been
conducted in accordance with the instructions issued by the RBI from time
to time.
Certificate on reconciliation of securities by the bank. (Both on its own
investment account as well as PMS clients' account).
Certificate on compliance by the bank in key areas of prudential and other
guidelines relating to such transactions issued by the RBI.
Certificate in respect of custody of unused BR forms and their utilisation.
(as such banks do not use BR forms any more. Further it is difficult to
certify unused forms as they are not available for verification. This
certificate should be strictly based on and against the management
representation. The auditor is advised to bring out this fact clearly in the
certificate.)
Various ratios and statements in the "Notes on Accounts".
Report on instances of adverse credit- deposit ratio in the rural areas.
Certification on correctness of computation of DTL / NDTL
Report on compliance with CRR and SLR requirements.
Certification in respect of subsidy claimed by the bank under the PMRY
Scheme during the financial year.
Certificate on compliance by bank on recommendations of:
Ghosh Committee, regarding frauds and malpractices in banks.
Jilani Committee, regarding internal control system in banks.
Dr. N. L. Mitra Committee, regarding maintenance of legal compliance
certificate for credit sanction and other transactions of Rs. 1 crore and
above.
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Special Purpose Reports and Certificates
In line with the Master Directions on frauds, the SCAs to ensure that all the
branches have complied with the reporting as required by the said circular
and respective SBA certificates are being received. A separate Report
should be given on any matter susceptible to be a fraud or a fraudulent
activity or any foul play in any transaction. In cases where the amount of
fraud brought to the notice during audit and has remained to be reported,
the auditors are advised to report such instances directly to the CGM,
Central office of Department of Banking Supervision, RBI, Mumbai.
Certain other certificates as may be prescribed by the concerned bank in
their respective closing instructions or appointment letters.
399
VI-3
Compliance with Implementation
of Ghosh & Jilani Committee
Recommendations
Introduction
3.01 The RBI had set up a High Level Committee on Frauds and
Malpractices in Banks under the Chairmanship of Shri A. Ghosh, the then
Deputy Governor, RBI to enquire into various aspects of frauds and
malpractices in banks with a view to make recommendation to reduce such
incidence. The Committee submitted its Report in June, 1992. The
recommendations contained in the report are related to frauds and
malpractices in banks.
3.02 The RBI had set up a "Working Group to Review the Internal Control
and Inspection and Audit System in Banks" under the Chairmanship of Mr.
Rashid Jilani. The Working Group was constituted in February, 1995 to review
the efficiency and adequacy of internal control and inspection and audit system
in banks with a view to strengthening the supervision system, both on-site and
off-site, and ensuring reliability of data.
Regulatory Requirements
Ghosh Committee Recommendations
3.03 The RBI in its efforts towards ensuring a strong, efficient and resilient
banking system in the country, vide its Circular No. DBS.Co.PPP.BC.No.39/
ND-01.005/99-2000 dated November 1, 1996, issued instructions relating to
frauds and malpractice in banks. The Circular was issued for the
implementation of the 44th report of the Committee on Government Assurances
Ghosh and Jilani Committees' Recommendations.
3.04 The recommendations are divided into four groups as under:
(i) Group-A: Recommendations, which have to be implemented by the banks
immediately.
(ii) Group-B: Recommendations requiring RBI's approval.
(iii) Group-C: Recommendations requiring approval of Government of India.
Compliance with Implementation of Ghosh & Jilani Committee
(iv) Group-D: Recommendations requiring further examination in consultation
with IBA.
3.05 The RBI has summarised each of these recommendations for the
purpose of reporting of their implementation by the banks, in a `yes' or `no'
format. The RBI has also categorised these recommendations into
(i) applicable to branches
(ii) applicable to Controlling Offices like, Regional and Zonal Offices (some
banks may have some other name for controlling offices),
(iii) applicable to Head Office and
(iv) applicable to Treasury Operations.
3.06 The report of the Ghosh Committee deals, mainly with the issues
related to day-to-day administrative functions that take place in a bank. The
main objective behind the recommendations contained in the Ghosh
Committee Report is to ensure that there exists a proper system in banks to
ensure the safety of assets, compliance with the laid down policies and
procedures, accuracy and completeness of the accounting and other records,
proper segregation of duties and responsibilities of the staff and also timely
prevention and detection of frauds and malpractices.
Jilani Committee Recommendations
3.07 The 44th Report of the Committee on Government Assurances
expressed concern that despite reporting of the compliance with
recommendations of the Jilani Committee, by the controlling office/branches,
the same might have not been implemented. Accordingly, RBI laid down the
following procedure to ensure the implementation of recommendations:
A format containing 25 questions was issued to indicate the answer as
either "Implemented" or "Not Implemented".
Information received from all branches and ROs/ZOs to be consolidated at
Head Office level and submission of consolidated statement to RBI.
Implementation of recommendations to be verified during concurrent
audit/inspection of branches/controlling offices and comment on the same
to be included in their report.
3.08 The report of the Jilani Committee contains twenty five (25)
recommendations which can broadly be divided into three categories, (i)
dealing with the EDP environment in the banks,(ii) dealing with the
inspection/internal audit system in the bank and (iii) deal with other
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miscellaneous aspects of functioning of a bank. The RBI has summarised each
of these recommendations for the purpose of reporting of their implementation
by the banks, in a `Implemented' or `not implemented' format. Some of the
recommendations of Jilani Committee are to be implemented by the banks at
the branch office level, whereas some others are applicable to the
regional/zonal/head office level. However, some recommendations find
applicability at all levels.
Responsibility of the Management
3.09 The RBI, vide its subsequent Circular dated June 28, 2002, issued to
the banks has required the concurrent auditors and inspectors of the bank
branches/controlling offices to verify and comment in their reports as to the
status of implementation of the recommendations of the Ghosh and the Jilani
Committees in the banks.
3.10 In terms of the letters issued to the banks regarding appointment of
the statutory central auditors by the RBI, the auditors are also required to verify
and comment upon the compliance by the bank in regard to the status of the
implementation of the recommendations of the Ghosh and the Jilani
Committees.
3.11 From the above it is clear that the implementation of the
recommendations of the Ghosh and the Jilani Committees is the responsibility
of the management of the banks. The responsibility of the statutory auditors is
to verify and report on the status of implementation of these recommendations,
thus far and no further. The results of the verification carried out by the
statutory auditor and his comments thereon would be given in a separate
report.
3.12 RBI through its Master Circular No. DBR. No. Dir. BC.11/13.03.00
/2015-16 dated July 1, 2015 on "Guarantees and Co-acceptances" has required
that Banks should implement the following recommendations made by the
Ghosh Committee:
(i) In order to prevent unaccounted issue of guarantees, as well as fake
guarantees, as suggested by IBA, bank guarantees should be issued in
serially numbered security forms.
(ii) Banks should, while forwarding guarantees, caution the beneficiaries that
they should, in their own interest, verify the genuineness of the guarantee
with the issuing bank.
3.13 RBI through its Master Circular "Loans and Advances Statutory and
Other Restrictions" (DBR.No.Dir.BC.10/13.03.00/2015-16) dated July 1, 2015
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Compliance with Implementation of Ghosh & Jilani Committee
requires that banks should ensure compliance with the recommendations of the
Ghosh Committee and other internal requirements relating to issue of
guarantees to obviate the possibility of frauds in the areas of issuance of Bank
Guarantees in favour of Financial Institutions, credit facilities extending to bank
against the guarantees issued by other banks/FIs and advancement of Gold
(Metal) Loans.
3.14 In this regard, it may be noted that the RBI has also issued Master
Directions on Frauds Classification and Reporting by commercial banks and
select FIs (RBI/DBS/2016-17/28 DBS.CO.CFMC.BC.No.1/23.04.001/2016-17
dated July 1, 2016 updated July 03, 2017)). These directions deal with
Classification of Frauds, Reporting of Frauds to RBI, Quarterly Returns,
Reports to the Board, Fraud Monitoring Returns, etc. and the auditor should
verify the compliance of the same.
3.15 The RBI has issued a Master Circular on "Willful Defaulters"
(DBR.No.CID.BC.22/20.16.003/2015-16 dated July 01, 2015) which also
specifies the role of auditors including recommendations about action to be
taken against negligent / deficient auditors wherein falsification of accounts on
the part of borrower is observed. Further, it specifies that to monitor end-use of
funds, if the lenders desire a specific certification from the borrowers' auditors
regarding diversion / siphoning of funds by the borrower, the lender should
award a separate mandate to the auditors for the purpose. In addition to this,
banks are advised that with a view to ensuring proper end-use of funds and
preventing diversion/siphoning of funds by the borrowers, lenders could
consider engaging their own auditors for such specific certification purpose
without relying on certification given by borrower's auditors. However, this
cannot substitute bank's basic minimum own diligence.
3.16 In order to ensure that directors are correctly identified and in no case,
persons whose names appear to be similar to the names of directors appearing
in the list of willful defaulters, are wrongfully denied credit facilities on such
grounds, bank/FI have been advised to include the Director Identification
Number (DIN) as one of the fields in the data submitted by them to RBI/CIC.
3.17 In terms of Para 2.9 of Master Circular on Willful Defaulters as stated
above, Banks / FIs have already been advised to submit the list of suit-filed
accounts and non-suit filed accounts of willful defaulters of Rs. 25 lakh and
above on a monthly or more frequent basis to all the four Credit Information
Companies. This would enable such information to be available to the banks /
FIs on a near real time basis.
3.18 Further, in terms of RBI Circular RBI / 2016-17 / 284 Ref.
DBS.CO.PPD.BC.No.9/11.01.005/2016-17 dated April 20, 2017, compliance to
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Guidance Note on Audit of Banks (Revised 2019)
the Ghosh Committee recommendation also need not be reported to Audit
Committee of the Board of Directors (ACB). However, banks are advised to
ensure that:
i) Compliance to these recommendations is complete and sustained,
ii) These recommendations are appropriately factored in the internal
inspection/audit processes of banks and duly documented in their manual/
instructions, etc.
Audit Approach and Procedures
3.19 The RBI has prescribed separate formats to be filled in by the banks
for reporting on compliance with/ implementation of the recommendations of
the Ghosh and Jilani Committees. The responsibility of the statutory auditors is
to certify the status of compliance with/ implementation of the
recommendations of the Ghosh and Jilani Committees. Accordingly, the
following procedures may be adopted by the statutory auditors of branches as
well as the Statutory Central Auditors for certifying the compliance/
implementation status of the Ghosh and Jilani Committees recommendations.
In case of the branch, the SBA shall enquire from the management of the
branch whether it has prepared the prescribed report on the
implementation status of the recommendations of the Ghosh and Jilani
Committees. If yes, then whether the same has been forwarded to the
Head Office for necessary action. If no, then the auditor should obtain
necessary representation from the management as to why the report has
not been prepared and/ or submitted and should appropriately qualify his
report.
In case of the Head Office, the SCA shall obtain a confirmation from the
management whether it has received the report on the implementation
status of the recommendations of the Ghosh and Jilani Committees from
all the branches, regional/ zonal offices, etc. and also whether it has
prepared the status report as applicable to the Head Office level. The SCA
shall obtain a list of the branches, regional/ zonal offices which have not
submitted the prescribed report. Such a list would help the SCA to have a
broad idea as to the extent of implementation of the recommendations by
the bank as a whole.
The SCA should obtain and review a copy of the implementation status
report(s) so prepared and submitted. Such a review would help the
auditors identify areas which are susceptible to fraud/ malpractices. The
results of such a review may also require the auditor to re-consider the
nature, timing and extent of the procedures adopted by him for carrying out
the audit as well as his audit findings.
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Compliance with Implementation of Ghosh & Jilani Committee
In case of Branch audit, where the concerned branch has been subjected
to a concurrent audit, then the report of the concurrent auditor on the
status of implementation of the recommendations of the Ghosh and Jilani
Committees should also be obtained. In case, the branch is not subject to
a concurrent audit, the SBA should enquire whether it had been subjected
to any inspection either by the in-house inspection department or by the
inspectors of the RBI. The auditor should review the comments, if any, of
the concurrent auditor or such inspectors on the said implementation
status report.
The SCA may also request the management to provide a list of branches
which had been subject to a concurrent audit/ inspection by the in-house
inspection department or the inspectors from the RBI. SCA may, if
considered necessary, select some such branches and review the
comments of the concurrent auditors/ inspectors on the status of
implementation of the recommendations. This would help to identify any
common cause of concern among the bank branches.
Where the status report, as prepared by the management indicates that
any of the recommendations have not been implemented, the SCA/SBA
should request the concerned management to give a written
representation as to why the particular recommendation(s) has/have not
been implemented.
The SBA/SCA may also consider it necessary to carry out test checks to
ensure whether the recommendations which have been said to have been
implemented in the status report have indeed been implemented by the
management.
3.20 In case, SBA/SCA examination reveals that any of the
recommendations indicated as having been implemented have in fact not been
implemented by the management, or where there is a failure to comply with
any of the recommendations of the two Committees, would not only indicate a
weakness in the internal control system in the bank but also raise doubts as to
the integrity of the management. The auditor may, accordingly, also need to re-
consider the nature, timing and extent of other audit procedures as also the
truth and accuracy of any other management re-presentations obtained by the
auditor.
Certificate / Report
3.21 Based on the work done, the auditor should assess whether any
information obtained during the verification indicates that any of the
recommendations of the Ghosh and Jilani Committees have not been
implemented, either in full or in part. The auditor may consider expressing
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Guidance Note on Audit of Banks (Revised 2019)
either disclaimer or appropriate comments in respect of certain clauses such as
Item Nos. 1.1 and 1.11 of Part II of Group A of Ghosh Committee.
3.22 The above-mentioned Certificate should describe the scope of the
verification undertaken to enable the readers to understand the nature of work
performed and make it clear that a full-fledged investigation had not been
undertaken. The Certificate of the auditor should also draw attention to the
following facts:
That the responsibility for the implementation of the recommendations of
the Ghosh and the Jilani Committees is solely that of the management of
the bank.
That the auditor has also considered the reports of all or certain, as the
case may be, concurrent auditors/inspectors of the bank branches on the
status of implementation of the recommendations of the Ghosh and Jilani
Committees at the branch office and controlling offices.
That the verification was limited primarily to enquiries and obtaining
confirmations from the management and other appropriate persons.
That the auditor has carried out test checks to assess the status of
implementation of the recommendations of the Ghosh and Jilani
Committees.
3.23 The Annexure A to this Chapter provides an illustrative format of the
auditor's certificate w.r.t. compliance with/ implementation of the
recommendations of the Ghosh and Jilani Committees.
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Compliance with Implementation of Ghosh & Jilani Committee
Annexure A
Illustrative Format of Certificate w.r.t. Compliance/
Implementation Status of the Recommendations of the
Ghosh and Jilani Committees
We have examined the attached Format of compliance/ implementation by
_____________ (name of bank/ bank branch/Department/Zonal Office) with
the recommendations of the Ghosh Committee relating to Frauds and
Malpractices in Banks and Format of Progress in Implementation of Jilani
Committee recommendations, as prepared by the management. The
responsibility for compliance with/ implementation of the recommendations of
the Ghosh and the Jilani Committees is that of the management of the
___________ (name of the bank/ bank branch/Department/Zonal Office). Our
responsibility is to examine the report on the status of compliance therewith as
contained in the attached Formats, as prepared by the management, thus far
and no further.
We have not carried out an investigation into the status of compliance by/
implementation of the management with the recommendations of the Ghosh
and Jilani Committees. Our examination is limited to inquiries and obtaining
confirmations from the management and other appropriate persons and test
checks of the attached status of recommendations.
Based on our above examination, subject to the matter highlighted below, we
certify that to the best of our knowledge and belief and according to the
information and explanation given to us and as shown by the records examined
by us, the attached Formats of compliance with the recommendations of the
Ghosh and Jilani Committees, as prepared by the management is correct.
1. ...........................
2. ............................
Date: For and on behalf of
Chartered Accountants
Place:
(Firm Registration No.)
......................................
(Name and Designation)
(Membership Number)
407
VI-4
Other Aspects
Introduction
Regulatory Requirements
Head Office
4.01 Apart from examination of consolidation of branch returns, verification
of capital and reserves, and verification of investments and provisioning in
respect thereof, the Statutory Central Auditors also usually deal with the
following items:
depreciation on assets like, premises, etc. where the recording of the
relevant fixed assets is centralised at the head office;
provisions for certain employee costs, such as, bonus/ex-gratia in lieu of
bonus, gratuity, leave encashment, pension and other retirement benefits;
provision for taxation;
provision for audit fee;
provisions to meet any other specific liabilities or contingencies the amount
of which is material, for example, provision for revision in pay-scales of
employees, provision for foreign exchange fluctuations, etc; and
dividends.
Provisioning for Non-performing Assets
4.02 The prudential norms issued by the RBI prescribe the percentage of
provision to be made in respect of advances classified under different
categories, viz., standard, sub-standard, doubtful and loss assets. In this
context, the RBI has issued "Master Circular Prudential Norms on Income
Recognition, Asset Classification and Provisioning pertaining to Advances"
(DBOD.No.BP.BC.2/21.04.048/2015-16) dated July 1, 2015. The primary
responsibility for making adequate provisions for any diminution in the value of
loan assets, investment or other assets is that of the bank management and
the statutory auditors. The assessment made by the inspecting officer of the
RBI is furnished to the bank to assist the bank management and the statutory
auditors in taking a decision in regard to making adequate and necessary
provisions in terms of prudential guidelines. It may be emphasised that the
percentages prescribed by the RBI reflect the minimum proportion of an
Other Aspects
advance that a bank ought to provide for to comply with the guidelines. A bank
can, at its discretion, make a higher provision than that required under the
prudential guidelines. Further, the bank needs to ensure that the bank complies
with the PCR (Provision Coverage Ratio) as prescribed by RBI.
4.03 As per RBI Circular RBI/2016-17/283 DBR.BP.BC.No.63/21.04.018/
2016-17 dated April 18, 2017 issued under the provisions of Section 35A of the
Banking Regulation Act, 1949, Banks are required to make disclosures as per
Annexure to the said circular, wherever either (a) the additional provisioning
requirements assessed by RBI exceed 15 percent of the published net profits
after tax for the reference period or (b) the additional Gross NPAs identified by
RBI exceed 15 percent of the published incremental Gross NPAs1 for the
reference period, or both. The disclosures, as above, shall be made in the Notes
to Accounts in the ensuing Annual Financial Statements published immediately
following communication of such divergence by RBI to the bank. The disclosures
in the Notes to Accounts to the Annual Financial Statements may be included
under the sub-head Asset Quality (Non-Performing Assets) as referred to in
paragraph 3.4 of Master Circular - Disclosure in Financial Statements - Notes to
Accounts Ref. DBR.BP.BC No.23 /21.04.018/2015-16 dated July 1, 2015. RBI
has further stated that any contravention / non-compliance of the above
instructions shall attract penalties under the Act. While the requirement is to
make disclosures in the annual financial statements, auditors of listed banks may
consider including such disclosures in the quarterly financial results in the quarter
in which the RBI inspection report is received.
4.04 It has also been mentioned earlier that provisions in respect of non-
performing assets are usually not made at the branch level but at the head
office level. The amount of provision (or minimum amount) to be made at the
head office level is based on classification of assets into standard, sub-
standard, doubtful and loss assets. Branch returns contain analysis of the
advances into these categories. The central auditor examines prima facie the
correctness of the classification as a part of his examination of consolidation of
branch returns. The branch auditors' reports may also point out cases where in
their opinion, there are threats to recovery that warrant a higher amount of
provision than that arrived at on the basis of the percentages specified by the
RBI.
4.05 The auditor should examine whether the provision made by the
management at the head office level meets the minimum provisioning
requirements prescribed by the RBI and also takes into account the threats to
recovery in specific cases. With regard to the latter, the auditor should ensure
that the provision made by the management is not less than that recommended
by the respective branch auditors unless, based on the information and
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Guidance Note on Audit of Banks (Revised 2019)
explanations, which were not available to the branch auditors, he holds a
contrary view, or unless he otherwise believes that the branch auditors'
objections have been met or are not of such nature and significance as to
warrant a provision in the overall context of the bank as a whole.
4.06 The Third Schedule to the Banking Regulation Act, 1949 lays down
the requirements of disclosure concerning advances. Accordingly, advances
are required to be classified under various heads (Notes and Instructions for
Compilation of Balance Sheet and Profit and Loss Account, issued by the RBI
require that provisions made to the satisfaction of the auditors should be
excluded from advances under each head). The concern of the auditor is with
the overall adequacy of provisions in respect of each of the heads under which
advances are required to be shown in the balance sheet of a bank. Thus, for
example, the auditor has to examine the adequacy of the overall provisions
recommended by the bank separately in respect of (a) bills purchased and
discounted, (b) cash credits, overdrafts and loans repayable on demand, and
(c) term loans. Similarly, the auditor should examine the overall adequacy of
the provisions recommended under each of the other heads of advances in the
balance sheet. If, in his opinion, the overall provision recommended by the
bank in respect of any of the heads is inadequate, `the auditor should consider
if his report needs to be modified with reference to the requirements of
Standard on Auditing (SA) 705 (Revised), Modifications to the Opinion in the
Independent Auditor's Report.
4.07 The RBI has specified that advances against book debts
may be included under the head `secured by tangible assets'
Recognition of Certain Expenses
4.08 Certain expenses, such as the following, are usually recognised at the
head office level (or at zonal or regional level):
(a) Directors' fees, allowances and expenses;
(b) Insurance;
(c) Auditors' fees and expenses; and
(d) GST, etc.
Audit Approach and Procedures
Directors' Fees, Allowances and Expenses
4.09 This item includes sitting fees and all other items of expenditure
incurred in relation to directors. The daily allowance, hotel charges,
conveyance charges, etc., though in the nature of reimbursement of expenses
incurred, may be included under this head. Similar expenses of local
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Other Aspects
Committee members may also be included under this head. Under the
Companies Act, 2013 a director may receive remuneration by way of a fee for
each meeting of the Board or a Committee attended by him. Local Committees
are appointed by banks as advisory bodies in respect of the areas allotted to
them. Their members are also paid fees or allowances.
4.10 The auditor may check the sitting fees and allowances with reference
to the articles of the banking company, agreements, minutes of the Board and
Local Committees, etc. It may be noted that in the case of nationalised banks,
the fees and the basis of reimbursement of travelling expenses are fixed by the
Central Government in consultation with the RBI. Copies of the relevant orders
may be examined in this behalf.
Insurance
4.11 This item includes insurance charges on bank's property. It also
includes insurance premium paid to DICGC, etc., to the extent they are not
recovered from the parties concerned.
4.12 Banks submit a Return on Total Insurable Deposits to RBI on a
periodic basis. Insurance premium is payable on such deposits. The auditor
should check the basis of computation of insurable deposits and the insurance
premium paid on same.
4.13 The DICGC guarantee fees payable by banks are based on the
outstanding amount of priority sector advances covered by DICGC as on 31st
March every year. The auditor should check the basis of payment/provision for
such guarantee fees.
Auditors' Fees and Expenses
4.14 This item includes the fees paid to the statutory auditors and auditors
for professional services rendered and all expenses for performing their duties,
even though they may be in the nature of reimbursement of expenses. If
external auditors have been appointed by banks themselves for internal
inspections and audits and other services, the expenses incurred in that
context including fees incurred for such assignments may not be included
under this head but shown under 'other expenditure'.
Provision for Depreciation
4.15 As mentioned earlier, practices differ amongst banks with regard to
accounting for fixed assets and provision for depreciation thereon. In case
these accounting aspects in respect of all or certain categories of fixed assets
are centralised at the head office level, the central auditor should examine the
same. The procedures to be followed by the auditor in this respect would be
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Guidance Note on Audit of Banks (Revised 2019)
similar to those discussed in Chapter 2 "Fixed Assets and Other Assets" of Part
IV on at the branch level, except that the central auditor may request the
respective branch auditors to examine the evidence of physical existence of
fixed assets that, as per the records, are located at the branch or have been
provided to employees for use (such as residential premises).
Provisions for Certain Employee Costs
4.16 Provisions for certain employee costs such as bonus/ex-gratia in lieu
of bonus, and gratuity, leave encashment, pension and other retirement
benefits are usually made at the head office level.
4.17 The auditor should examine whether the liability for bonus is provided
for in accordance with the Payment of Bonus Act, 1965 and/or agreement with
the employees or award of competent authority.
4.18 The auditor should examine whether provisions in respect of
employee benefits are made in accordance with the requirements of
Accounting Standard (AS) 15, "Employee Benefits". The auditor should
particularly examine whether provision for leave encashment has been made
by the bank. As per AS 15, employee benefits include all forms of
consideration given by an enterprise in exchange for services rendered by
employees. It includes short-term employee benefits such as wages, salaries
and social security contributions and non-monetary benefits, post-employment
benefits, other long-term employee benefits and termination benefits. The
auditor should examine the adequacy of the provisions made with reference to
such documentary evidence such as reports of actuaries or certificates from
the Life Insurance Companies, as appropriate under the facts and
circumstances of the case.
4.19 In the case of employee benefits, the Master Circular on "Disclosure in
Financial Statements Notes to Accounts" (DBR.BP.BC No. 23
/21.04.018/2015-16) dated July 1, 2015 issued by the RBI with reference to
Accounting Standard 15, specifies that Banks may follow the disclosure
requirements prescribed under AS 15 (revised), `Employees Benefits' issued by
ICAI.
Provision for Taxation
4.20 Provision for taxation relates to income-tax, (including corporate
dividend tax). The auditor must ensure compliance with AS 22, "Accounting for
Taxes on Income".
Income-tax
4.21 Some of the items which have an effect on the liability of a bank for
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Other Aspects
income-tax and therefore, need to be specifically considered by the auditor are
discussed in the following paragraphs.
The Statutory Auditor should consider impact of Income Computation and
Disclosure Standards (ICDS) issued vide notification dated 31 March 2015 by
CBDT while calculating provision of Tax. The notification requires income
computation and disclosure standards to be followed by all assessees, following
the mercantile system of accounting, for the purposes of computation of income
chargeable to income-tax under the head "Profit and gains of business or
profession" or "Income from other sources".
ICDS No. Name
I Accounting Policies
II Valuation of Inventories
III Construction Contracts
IV Revenue Recognition
V Tangible Fixed Assets
VI Effects of Changes in Foreign Exchange Rates
VII Government Grants
VIII Securities
IX Borrowing Costs
X Provisions, Contingent Liabilities & Contingent Assets
Vide Notification dated 29th September 2016, the Central Government notified
amended ICDS which are applicable with effect from the assessment year
2017-18.
Bad Debts and Provision for Bad and Doubtful Debts
4.22 Section 36(1)(vii) of the Income-tax Act, 1961 deals with the
allowability of bad debts and section 36(1)(viia) deals with the allowability of
provision for bad and doubtful debts. According to section 36(1)(vii), bad debts
written off are admissible deduction subject to the conditions prescribed under
section 36(2), i.e.,
(i) no such deduction shall be allowed unless such debt or part thereof has
been taken into account in computing the income of the assessee of the
previous year in which the amount of such debt or part thereof is written off
or of an earlier previous year, or represents money lent in the ordinary
course of the business of banking or money-lending which is carried on by
the assessee;
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Guidance Note on Audit of Banks (Revised 2019)
(ii) if the amount ultimately recovered on any such debt or part of debt is less
than the difference between the debt or part and the amount so deducted,
the deficiency shall be deductible in the previous year in which the ultimate
recovery is made;
(iii) any such debt or part of debt may be deducted if it has already been written
off as irrecoverable in the accounts of an earlier previous year, but the
Assessing Officer had not allowed it to be deducted on the ground that it
had not been established to have become a bad debt in that year;
(iv) where any such debt or part of debt is written off as irrecoverable in the
accounts of the previous year and the Assessing Officer is satisfied that
such debt or part became a bad debt in any earlier previous year nor falling
beyond a period of four previous years immediately preceding the previous
year in which such debt or part is written off, the provisions of sub-section
(6) of section 155 shall apply;
(v) where such debt or part of debt relates to advances made by an assessee
to which clause (viia) of sub-section (1) applies, no such deduction shall be
allowed unless the assessee has debited the amount of such debt or part of
debt in that previous year to the provision for bad and doubtful debts
account made under that clause.
4.23 The said deduction is limited to the amount by which the bad debts
exceed the credit balance in the provision for bad and doubtful debts account
made under section 36(1)(viia). According to section 36(1)(viia), a specified
percentage of the total income and a specified percentage of the aggregate
average advances made by the rural branches of the bank, both computed in
the prescribed manner, is allowable as a deduction in respect of provision for
bad and doubtful debts made by banks other than foreign banks.
4.24 A scheduled bank/non-scheduled bank has the option to claim a
further deduction for an amount not exceeding the income derived from
redemption of securities in accordance with a scheme framed by the Central
Government. This is in addition to the deduction specified in paragraphs above
with respect to section 36(i)(viia). However, for the purpose of claiming this
deduction, it is necessary that such income should be disclosed in the return of
income under the head `Profit and gains of business or profession".
4.25 Section 36(1)(vii) requires the amount of any bad debt or part thereof
to be written off as irrecoverable in the accounts of the assessee for the
previous year. It is sufficient compliance of the section if the write off is done at
Head Office level.
414
Other Aspects
Special Reserve
4.26 Deduction in respect of a special reserve created and maintained by a
banking company
(a) Section 36(1)(viii) provides deduction in respect of any special reserve
created and maintained by a specified entity, which includes a banking
company.
(b) The quantum of deduction, however, should not exceed 20% of the profits
derived from eligible business computed under the head "Profits and
gains of business or profession" (before making any deduction under this
clause) carried to such reserve account.
(c) The eligible business, in case of a banking company, means the business
of providing long-term finance for
(i) industrial or agricultural development or development of
infrastructure facility in India; or
(ii) development of housing in India.
(d) However, where the aggregate amount carried to such reserve account
exceeds twice the amount of paid up share capital and general reserve,
no deduction shall be allowed in respect of such excess.
(e) The Reserve Bank of India has issued circular No.: DBOD.
No.BP.BC.77/21.04.018/2013-14 dated December 20, 2013 for creation of
deferred tax liability on special reserves created under section 36(1)(viii)
and entire Special Reserves may be reckoned for the purpose computation
of Tier-I Capital.
Interest on Non-Performing Accounts (NPAs)
4.27 According to section 43D, read with Rule 6EA of the Income-tax
Rules, 1962, the income of a scheduled bank by way of interest in relation to
such categories of bad or doubtful debts as may be prescribed having regard
to the guidelines issued by the RBI in relation to such debts, shall be
chargeable to tax only in the previous year in which it is credited to the Profit
and Loss Account or in the year of actual receipt, whichever is earlier.
Transactions with Foreign Banks/Foreign branches of Indian banks
4.28 The applicability of any Double Taxation Avoidance Agreement is to
be taken into account for the purpose of computation of tax in respect of
transactions with foreign banks or foreign branches of Indian banks.
4.29 Similarly the applicability of Transfer Pricing Regulations is to be taken
into account for the purpose of computation of tax in respect of international
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Guidance Note on Audit of Banks (Revised 2019)
transactions with Associated Enterprises covered under section 92E of the
Income-tax Act, 1961. Reference may also be made to the "Guidance Note on
Report on International Transactions under section 92E of the Income-tax Act,
1961 (Transfer Pricing)" issued by ICAI.
4.30 In respect of any provision for bad and doubtful debts made by a
foreign bank, an amount not exceeding 5% of the total income (computed
before making any deduction under Chapter VI-A) is allowable as deduction.
Corporate Dividend Tax
4.31 A holding company receiving dividend from its subsidiary company
can reduce the same from dividends declared, distributed or paid by it. For this
purpose, a holding company is one which holds more than 50% of the nominal
value of equity shares of the subsidiary.
4.32 There are certain conditions to be fulfilled to avail this benefit. They
are -
the subsidiary company should have actually paid the dividend distribution
tax;
the holding company should be a domestic company; and
It should not be a subsidiary of any other company.
4.33 It may be noted that the matching principle does not apply, i.e.,
dividend received from the subsidiary company during the year can be reduced
from the dividend distributed by the holding company during the same year,
irrespective of the period to which the dividends relate to. Even if the dividend
received and dividend distributed relate to different periods, the same can be
adjusted and tax can be paid by the holding company on the net figure.
However, the dividend shall not be taken into account for reduction more than
once.
4.34 According to the "Guidance Note on Accounting for Corporate
Dividend Tax", issued by the Institute of Chartered Accountants of India (ICAI),
the liability for such tax should be recognised in the accounts of the same
financial year as appropriation of profit and not as a charge against profit in
which the dividend concerned is recognised.
Tax Refunds/Demands
4.35 Where an assessment order is received during the year, the auditor
should examine the assessment order and if any interest is determined on the
amount of refund, the same should be considered as income. In case where
the assessment results in fresh demand, the auditor should consider the need
for additional provisioning. Where an assessment order is received during the
416
Other Aspects
course of audit, the auditor should examine the same and consider its impact, if
any, on the accounts under audit.
4.36 It is not prudent to recognise interest on possible refund which is not
determined by any order from tax authorities.
Pending Proceedings
4.37 The auditor should review the appellate orders received during the
year and consider the need for any additional provision/reversal.
Method of Accounting
4.38 Many banks account for commission, exchange, brokerage, interest
on bills, locker rent and other fees as income upon realisation. Section 145 of
the Income-tax Act, 1961 provides, inter alia, that income chargeable under the
head "Profits and Gains of Business and Profession" shall be computed in
accordance with either cash or mercantile system of accounting regularly
employed by the assessee. Auditors of banks to whom the Companies Act
applies are required to follow accrual basis of accounting. Further, accrual
being a fundamental accounting assumption, the auditor would need to
consider modification/ reference to/ in the auditor's report wherever cash basis
of accounting is followed.
Reversal of Earlier Year's Provision
4.39 It is possible that subsequent judicial pronouncements/ appellate
orders may make the provisions of earlier years excessive. As per Accounting
Standard (AS) 29, "Provisions, Contingent liabilities and Contingent Assets", a
provision should be recognised only when (a) an enterprise has a present
obligation as a result of a past event, (b) it is possible that an outflow of
resources embodying economic benefits will be required to settle the
obligation, and (c) a reliable estimate can be made of the amount of the
obligation. If these conditions are not met, no provision should be recognised.
4.40 Only in rare cases, e.g., a law suit, it may not be clear whether an
enterprise has a present obligation. In such a case, an enterprise determines
whether a present obligation exists at the balance sheet date by taking into
account all available evidence. On the basis of such evidence, if it is more
likely than not that a present obligation exists at the balance sheet date a
provision is recognised (if other recognition criteria are also met). However,
where it is more likely that no obligation exists at the balance sheet date, a
contingent liability is disclosed unless the possibility of an outflow of resources
embodying economic benefits is remote.
4.41 On the above considerations, if there is no requirement to retain a
provision, it can be reversed and the amount of liability is included in
417
Guidance Note on Audit of Banks (Revised 2019)
contingent liability. A suitable note on the following lines is recommended:
(a) Provision for Income Tax is arrived at after due consideration of decisions
of the Appellate authorities and advice of counsels; and
(b) No provision is made for the disputed demands of Income tax keeping in
view the judicial pronouncements and/or legal counsels' opinion.
Items Requiring Special Consideration
Tax Implications of Valuation of Investments
4.42 The RBI has issued various circulars on valuation of investments,
according to which the difference between the market value/value as per yield
to maturity method (YTM) will have to be provided in the books of accounts for
certain types of investments. The various judicial decisions on the allowability
of depreciation in valuation of investments, including implication of ICDS VIII,
should be considered while provisioning.
Notional Gain/Loss on Foreign Exchange Translations
4.43 Banks are required to translate their foreign exchange balances /
obligations in foreign currency as per FEDAI Guidelines. While recognising
gains or loss for tax purposes the following decisions may be considered by the
auditor along with FEDAI Guidelines:
The Madras High Court in the case of Indian Overseas Bank Vs.
Commissioner of Income-tax (1990) 183 ITR 200 has held that notional
profits on translation of foreign exchange forward contracts is not taxable.
The Madras High Court in the case of Commissioner of Income-tax Vs.
Indian Overseas Bank (1985) 151 ITR 446 has held that notional loss on
translations of foreign exchange contracts is not tax deductible.
Carry forward of unabsorbed business loss and depreciation on
amalgamation of a banking company with a banking institution
4.44 Section 72AA of the Income Tax Act, 1961 deals with Provisions
relating to carry forward and set-off of accumulated loss and unabsorbed
depreciation allowance in Scheme of amalgamation of banking company in
certain cases.
FATCA /CRS
4.45 Foreign Account Tax Compliance Act (known in short as FATCA) is a
legislation to counter tax evasion in the United States of America (USA). FATCA
was introduced by US Dept of Treasury (Treasury) and US Internal Revenue
418
Other Aspects
Service (IRS) to encourage better tax compliance by preventing US persons from
using banks and other financial organisations to avoid US taxation on their
income and assets.
4.46 As on 13th July 2015, 112 countries have agreed to comply with FATCA
agreements (67 signed IGAs, 45 IGAs agreed in substance). As on 4th June
2015, 61 countries are signatories of Multilateral Competent Authority Agreement
(MCAA) committed to reciprocal tax information exchange. India and the USA
have signed the reciprocal version of model 1 IGA for FATCA on 9th July 2015.
India signed the OECD's CRS (Common Reporting Standards) on 3rd June
2015. The IGA has 2 models India has signed Model 1 IGA wherein banks will
have to report information to the prescribed authority who in turn will submit
information to the IRS.
4.47 In Model 1 IGA, the Foreign Financial Institution (FFI) has to report all
FATCA related information to their governmental agencies, which would then
report the FATCA related information to the IRS. Some Model 1 IGAs are
reciprocal, requiring the US to provide certain information about residents of the
Model 1 country to the Model 1 country in exchange for the information that
country provides to the USA. An FFI covered by a Model 1 IGA will not need to
sign an FFI agreement but needs to register on the IRS's FATCA Registration
Portal or file Form 8957.
4.48 Like FATCA, Common Reporting Standard (CRS) is a reciprocal
exchange of information on financial accounts on an automatic basis with other
countries/ non-sovereign territories so as to combat the menace of offshore tax
evasion and avoidance and stashing of unaccounted money abroad.
4.49 India would be obligated to get its financial institutions to share financial
account information of accountholders who are tax residents in any of these
countries. Likewise, India would also get similar information through financial
institutions of such treaty countries.
4.50 CBDT has notified Rule 114H for Due Diligence Requirement under
FATCA, major requirements for the Bank as under:
All the concerned financial institutions should register on the related e-filling
portal of Income Tax Department as Reporting Financial Institution by submitting
the requisite details. Thereafter, the reports can be submitted online by using the
digital signature of the `Designated Director' by either uploading the Form 61B or
`NIL' report.
4.51 As per RBI Circular RBI/2015-16/165 DBR.AML.BC.No.36
/14.01.001/2015-16, dated August 28, 2015, for the new accounts opened after
419
Guidance Note on Audit of Banks (Revised 2019)
September 1, 2015, the due diligence procedures specified in Rule 114H (4) and
114H (6) would be applicable.
4.52 All the FIs have to submit reports online using the digital signature of the
designated director by either uploading Form 61B or Nil Report by September 10,
2015. The first reporting will be with respect to calendar year 2014 if an account
has been identified as US reportable account consequent to completion of due-
diligence procedures as laid down in Rule 114H. Therefore, the reasons for the
Nil report should be captured as under:
a. For pre-existing accounts:
Option 1: Due diligence procedure not completed
Option 2: Due diligence procedure completed but no reportable US account
identified
b. For new accounts:
Option 1: Alternative procedure invoked
Option 2: Due diligence procedure as applicable to new accounts completed
but no reportable US account identified
4.53 All the regulated entities should take appropriate action for the
implementation of due diligence and reporting requirements as laid down in the
Rules and ensure compliance in a manner that lends itself to credible auditability
including audit of the IT system which should be suitably upgraded to not only
maintain the information required under the Rules but also to record and store
the due diligence procedures. In due course, the detailed guidelines for carrying
out audit of IT system for ascertaining the degree and level of compliance with
due diligence procedures as laid down in the Rules will be issued.
4.54 Statutory Auditor should verify whether the Bank has put a process in
place for complying with guidelines under FATCA/CRS and submitted reports as
required by FATCA.
Indirect Taxes
4.55 Readers may refer publication of ICAI related with compliances of GST.
420
Contents of Accompanying
Pen Drive/CD
Foreword and Preface
of Past Years
Guidance Note on Audit of Banks (Revised 2019)
Foreword to Thirteenth Edition
Independent audit of financial statement of banks is essential for a healthy,
safe and sound banking system. Audit of banks involves number of
peculiarities e.g. huge volumes and complexity of transactions in banks, wide
geographical spread of banks' network, large range of products and services
offered by banks, extensive use of technology in banks, oversight by the
banking regulator etc. All these factors make the task of the bank auditors
quite challenging in doing the audits.
The Guidance Note on Audit of Banks brought out by the Auditing and
Assurance Standards Board of ICAI every year is an important resource
which provides detailed guidance to the members on various aspects of
statutory bank audits. I am happy that the Auditing and Assurance Standards
Board has brought out the revised 2018 edition of the Guidance Note on
Audit of Banks for the benefit of the members. The revised Guidance Note
was initially developed by an expert group constituted by the Board and
thereafter it was finalised with the contribution of the Board members. The
Guidance Note is comprehensive and self-contained reference document for
the members.
At this juncture, I wish to place my appreciation for CA. Shyam Lal Agarwal,
Chairman, CA. Sanjay Vasudeva, Vice-Chairman and other members of the
Auditing and Assurance Standards Board & the expert group for their efforts
in bringing out this Guidance Note to help the members in maintaining quality
in bank audits in a timely manner.
I am confident that the members would find the Guidance Note very useful in
their professional assignments.
New Delhi CA. Naveen N. D. Gupta
March 09, 2018 President, ICAI
422
Foreword and Preface of Past Years
Preface to Thirteenth Edition
Banking sector is the backbone of any economy as it provides finances to
various segments of economy and helps in sustainable socio-economic
growth of the economy. Like other economic activities, the banking sector is
also exposed to various risks in its operations. For financial stability in the
economy, it is essential that banking sector stays healthy, safe and sound.
For safe and sound banking sector, one of the most important factors is
reliable financial information supported by quality bank audits. By conducting
audits of financial statements of banks, the auditors play an important role in
building a resilient banking sector.
The Auditing and Assurance Standards Board of ICAI has been helping the
members in maintaining quality in bank audits by bringing out the publication
"Guidance Note on Audit of Banks" every year. Since the issuance of the last
edition of the Guidance Note in 2017, apart from the Master Directions and
Circulars issued by RBI, certain important developments have also taken
place in the banking sector. It is, therefore, essential that the members
undertaking statutory audit of banks and bank branches keep themselves
abreast with the latest developments in the banking sector.
I am happy to place in hands of the members, this revised 2018 edition of the
Guidance Note on Audit of Banks. The Guidance Note discusses in depth the
various important items on the financial statements of banks, its peculiarities,
manner of disclosure in the financial statements, the RBI prudential directions
thereon, audit procedures, reporting on Long Form Audit Reports both at
central and branch level, Ghosh and Jilani Committee recommendations,
special purpose reports and certificates, etc. The Guidance Note, inter alia,
has been updated for the impact of the Master Directions, Master Circulars
and other relevant circulars issued by RBI, the relevant pronouncements of
the ICAI, GST provisions. The Guidance Note also includes a new Chapter
on Scrutiny of Advance Accounts presented in Ind AS by Borrowers. For the
benefit of the members, the CD accompanying the Guidance Note contains
Illustrative formats of engagement letter, auditor's report, written
representation letter, Features of the Gold Monetization Scheme,
Abbreviations used in the Banking Industry, Basis of Selection of Advances
Accounts in case of bank branch audit, updated bank branch audit
programme for the year 2017-18, Verification of the aspects of the Treasury/
Investments of the Bank in Statutory Audit, Flow Charts for Use of Core
423
Guidance Note on Audit of Banks (Revised 2019)
Banking Solution software in case of Bank Branch Audit, the text of Master
Directions, Master Circulars and other relevant Circulars issued by RBI.
At this juncture, I wish to place on record my gratitude to all the members of
the Mumbai study group viz., CA. Shriniwas Y. Joshi (Convenor), CA.
Gautam Shah, CA. Sandeep D Welling, CA. Vipul K Choksi, CA. Vikas
Kumar, CA. Abhijit Sanzgiri, CA. Niranjan Joshi, CA. Ashutosh Pednekar,
CA. Dhananjay Gokhale, CA. Manish Sampat, CA. G. N. Sampath, CA.
Shivratan Agarwal, CA. Parag Hangekar, CA. Sanjay Khemani, CA. Sanjay
Rane, CA. Abhay Kamat, CA. Pankaj Tiwari, CA. Ketan Jogalekar, CA.
Nachiket Deo, CA. Parag Kulkarni, CA. Dilip Dixit, CA. Jitendra Ranawat and
CA. Prakash Kulkarni for working on this herculean project despite the
demands of their professional and personal lives. My sincere thanks to (i) all
the Members of Jaipur Study Group constituted under my convenorship, viz.,
CA. Bhupendra Mantri, CA. Vishnu Dutt Mantri, CA. Vikas Gupta, CA. Ajay
Atolia, CA. Anil Mathur, CA. Vijay Kumar Jain, CA. Prahalad Gupta, CA.
Jugal Kishore Agrawal, CA. P. D. Baid, CA. Mukesh Gupta, CA. Ram Avtar
Sharma, CA. Vikas Rajvanshi, CA. Vimal Chopra, CA. Thalendra Sharma,
CA. Varun Bansal, CA. Mukesh Khandelwal, and CA. Keshav Garg (ii) all the
Members of Delhi Study Group constituted under the convenorship of CA.
Sanjay Vasudeva, Vice Chairman, AASB, viz., CA. V Rethinam, CA. Rajiv
Puri, CA. M. M. Khanna, CA. Simran Singh, CA. Bupinder Singh, CA. Rakesh
Gupta, CA. Lalit Ahuja, CA. D. S. Rawat, CA. Bhuvnesh Maheshwari, CA.
Nitin Jain, CA. Ashish Agarwal, CA. Anuj Dhingra, CA. Himanshu Garg and
Mr. Rakesh Sharma (iii) all the Members of Kolkata Study Group constituted
under the joint convenorship of CA. Debashis Mitra and CA. Ranjeet Kumar
Agarwal viz., CA. Dipankar Chatterji, CA. Santanu Ghosh, CA. Veena
Hingarh, CA. Arif Ahmed, CA. Rajendra Nath Basu, CA. Sukamal Chandra
Basu, CA. Mrityunjay Ray, CA. Nirupam Haldar CA. Krishanu Bhattacharyya,
CA. Sunil Singhi, CA. Vikash Banka, CA. Ajay Agarwal, CA. Selu
Jhunjhunwala, CA. M. R. Jain, CA. Anindra Nath Chatterjee, CA. Tushar
Basu and CA. Ashok Kumar Samanta (iv) all the Members of Chennai Study
Group constituted under the joint convenorship of CA. G. Sekar, CA. M P
Vijay Kumar, CA. K. Sripriya viz., CA. R. Sundararajan, CA. Sivaprasad N.,
CA. Sukumaran T. G., CA. G.N. Ramaswami, CA. Anusha Sreenivasan, CA.
Asir Raja Selvan M, CA. S. Ramesh, CA. Vijay T. C., Dr. S. Gurusamy, CA.
V. Chandrasekaran, CA. T. R. Chandrasekaran, CA. Mahesh Krishnan, CA.
Uttamchand Jain and CA. Vittalraj to review the exposure draft of Guidance
Note on Audit of Banks 2018 edition.
424
Foreword and Preface of Past Years
I wish to place on record my sincere thanks to Honourable President, ICAI,
CA. Naveen N. D. Gupta, Honourable Immediate Past President, ICAI,
CA. Nilesh S. Vikamsey and Honourable Vice President, ICAI, CA. Prafulla
Premsukh Chhajed for their whole hearted support to the activities of the
Board.
I am also thankful to all my Central Council colleagues for their support and
guidance to the activities of the Board. I also wish to place on record my
gratitude to CA. Sanjay Vasudeva, Vice Chairman, AASB and all the
members and special invitees on the Board for the year 2017-18, without
whose support, the Guidance Note would not have been possible in the given
time. I also wish to thank CA. Megha Saxena, Secretary, CA. Rajnish
Aggarwal, CA. Nitish Kumar and other staff members of her team for their
hard work in giving the Guidance Note its final shape.
I am sure that the members would find the Guidance Note useful as its earlier
editions while conducting the audits of banks/ bank branches.
Jaipur CA. Shyam Lal Agarwal
March 09, 2018 Chairman
Auditing and Assurance Standards Board
425
Guidance Note on Audit of Banks (Revised 2019)
Foreword to Twelfth Edition
Banking sector is the backbone of any economy as it is essential for sustainable
socio-economic growth and financial stability in the economy. The banking sector
is also crucial as it deals with mammoth amounts of public monies and is highly
sensitive to reputational risk. Like all economic activities, the banking sector is
also exposed to various risks in its operations. It is of utmost importance to
ensure that banking sector stays healthy, safe and sound. For safe and sound
banking sector, one of the most important factors is reliable financial information
supported by quality bank audits.
The Guidance Note on Audit of Banks brought out by the Auditing and Assurance
Standards Board of the ICAI every year is an important resource which provides
detailed guidance to the members on various aspects of bank audits. It is
heartening that the Auditing and Assurance Standards Board has come out with
this revised 2017 edition of the Guidance Note on Audit of Banks for the benefit
of the members. The revised Guidance Note was initially developed by an expert
group constituted by the Board for this project and thereafter it was finalised with
the contribution of the Board members and the Central Council members of ICAI.
I am happy that the Guidance Note is comprehensive and self-contained
reference document for the members.
I wish to place my appreciation for CA. Shyam Lal Agarwal, Chairman, CA.
Sanjay Vasudeva, Vice-Chairman and other members of the Auditing and
Assurance Standards Board for bringing out this revised Guidance Note to help
the members in maintaining quality in bank audits.
I am confident that the members would find the Guidance Note highly useful in
their professional assignments.
New Delhi CA. M. Devaraja Reddy
February 7, 2017 President, ICAI
426
Foreword and Preface of Past Years
Preface to Twelfth Edition
Independent audit of financial statement of banks is important for a healthy, safe
and sound banking system. Audit of banks involves a number of peculiarities e.g.
huge volumes and complexity of transactions, wide geographical spread of
banks' network, large range of products and services offered, extensive use of
technology, strict vigilance by the banking regulator etc. All these factors make
the task of the auditors quite challenging in maintaining quality in bank audits.
The Auditing and Assurance Standards Board of ICAI has been helping the
members in maintaining quality in bank audits by bringing out its benchmark
publication "Guidance Note on Audit of Banks" every year. Since the issuance of
the last edition of the Guidance Note in 2016, apart from the Master Directions
and Circulars issued by RBI, certain important developments have also taken
place in the banking sector, including the recent demonetisation, warranting
appropriate attention of the auditors. It is, therefore, essential that the members
undertaking statutory audit of banks, both at the branch as well as the central
level, keep themselves abreast with the latest developments in the banking
sector.
I am happy to place in your hands this revised 2017 edition of the Guidance Note
on Audit of Banks. The Guidance Note discusses in depth the various important
items on the financial statements of banks, its peculiarities, manner of disclosure
in the financial statements, the RBI prudential directions thereon, audit
procedures, reporting on Long Form Audit Reports, Ghosh and Jilani Committee
requirements, special purpose reports and certificates, etc. The Guidance Note,
inter alia, has been updated for the impact of the Master Directions and other
relevant circulars issued by RBI in 2016, guidance on demonetization at
appropriate places, relevant pronouncements of the ICAI having bearing on bank
audits. For the benefit of the members, the CD accompanying the Guidance Note
contains Illustrative formats of engagement letter, auditor's report, written
representation letter, updated bank branch audit programme for the year 2016-
17, the text of Master Directions issued by RBI in 2016, the text of Master
Circulars and relevant General Circulars issued by RBI.
At this juncture, I wish to place on record my gratitude to all the members of the
Mumbai study group viz., CA. Nihar Niranjan Jambusaria, Convenor, CA.
Shriniwas Y. Joshi, CA. Sandeep D Welling, CA. Vipul K Choksi, CA. Vikas
Kumar, CA Abhijit Sanzgiri, CA. Niranjan Joshi, CA. Kuntal Shah, CA. Dhananjay
Gokhale, CA Ashutosh Pednekar, CA. Manish Sampat, CA. G. N. Sampath, CA
427
Guidance Note on Audit of Banks (Revised 2019)
Zubin Billimoria, CA. Gautam Shah, CA. Giriraj Soni, CA. Shivratan Agarwal, CA.
Parag Hangekar, CA. Sanjay Khemani, CA. Sanjay Rane, CA. Ketan Saiya, CA.
Abhay Kamat and CA. Sanat Chitale for working on this herculean project
despite the demands of their professional and personal lives. My sincere thanks
to (i) all the Members of Jaipur Study Group under my convenorship, viz., CA.
Bhupendra Mantri, CA Vijay Kumar Jain, CA Vishnu Dutt Mantri, CA Vikas
Gupta, CA Prahalad Gupta, CA Ajay Atolia, CA Jugal Agrawal, CA Mukesh
Gupta, CA Sandeep Jhanwar, CA Ashok Singhal, CA Vijay Jain, CA. Abhishek
Sharma, CA Shailendra Agarwal, CA Keshav Garg and CA Anil Jain (ii) all the
Members of Delhi Study Group constituted under the convenorship of CA. Sanjay
Vasudeva, Vice Chairman, AASB, viz., CA. K.A. Balasubramanian, CA. V
Rethinam, CA. Rajiv Puri, CA. Anil Sharma, CA. Rohit Mehta, CA. M M Khanna,
CA. Simran Singh, CA. Pramod Kr Maheshwari, CA. Parveen Kumar, CA. Nitin
Jain, CA. Anuj Dhingra and CA. Himanshu Garg (iii) all the Members of Kolkata
Study Group constituted under the convenorship of CA. Debashis Mitra viz., CA.
Dipankar Chatterjee, CA. Santanu Ghosh, CA. Veena Hingarh, CA. Arif Ahmed,
CA. Abhijit Bandyopadhyay, CA Vivek Newatia, CA. Rajendra Nath Basu, CA.
Sukamal Chandra Basu, CA. Mrityunjay Ray and CA. Nirupam Haldar (iv) all the
Members of Kolkata Study Group constituted under the convenorship of CA
Ranjeet Kumar Agarwal viz., CA. Krishanu Bhattacharya, CA. Jay Narayan
Gupta, CA. Sunil Singhi, CA. Ajit Verma, CA. R K Roy Choudhary, CA. Vikash
Banka, CA. Ajay Agarwal, CA. Niraj Jhunjhunwala, CA. Binay Singhania, CA. H
K Verma, CA. Kshitiz Chhawcharia, CA. Mrityunjay Ray and CA M R Jain (v) all
the Members constituted under the convenorship of CA. M P Vijay Kumar at
Bengaluru Study Group, viz., CA. K Raghu, CA. Madhukar Narayan Hiregange,
CA. Cotha S Srinivas, CA. B. P. Rao, CA. Nityananda N, CA. Manohar Gupta P,
CA. Ananthan, CA. R Shasidhara and CA. Gururaj Acharya and CA. Vivek
Krishna Govind from Cochin to review the exposure draft of Guidance Note on
Audit of Banks 2017 edition.
I wish to place on record my sincere thanks to CA. M. Devaraja Reddy, President
ICAI and CA. Nilesh S. Vikamsey, Vice President ICAI for their whole hearted
support to the activities of the Board.
I am also thankful to all my Central Council colleagues for their all-time support
and guidance to the activities of the Board. I also wish to place on record my
gratitude to all the members and special invitees on the Board for the year 2016-
17, viz., CA. Sanjay Vasudeva, Vice Chairman, AASB, CA. Nandkishore
Chidamber Hegde, CA. Nihar Niranjan Jambusaria, CA. Dhinal Ashvinbhai Shah,
CA. Babu Abraham Kallivayalil, CA. Madhukar Narayan Hiregange, CA. G.
Sekar, CA. K. Sripriya, CA. M P Vijay Kumar, CA. Ranjeet Kumar Agarwal, CA.
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Sushil Kumar Goyal, CA. Debashis Mitra, CA. Manu Agrawal, CA. Kemisha Soni,
CA. Sanjiv Kumar Chaudhary, CA. Mangesh Pandurang Kinare, Shri Vithayathil
Kurian, Dr. P.C. Jain, Shri Vijay Kumar Jhalani, CA. Abhijit Bandyopadhyay, CA.
Harinderjit Singh, CA. Murali Krishna, CA Vijay Kumar Jain, CA. Akhil Bhalla, CA.
Sandeep Dinanath Welling, CA. V. Balaji, CA. Sandeep Sharma and CA.
Khushroo B. Panthaky without whose support, the Guidance Note would not
have been possible in the given time. I also wish to thank CA. Megha Saxena,
Secretary, CA. Rajnish Aggarwal, Sr. Education Officer, CA. Nitish Kumar,
Executive Officer to the Board and other officers and staff of AASB for their hard
work.
I am sure that the members would find the Guidance Note useful as its earlier
editions while conducting the audits of banks/ bank branches.
Jaipur CA. Shyam Lal Agarwal
February 11, 2017 Chairman
Auditing and Assurance Standards Board
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Guidance Note on Audit of Banks (Revised 2019)
Foreword to Eleventh Edition
Banking industry plays a critical role in driving the economic growth. It is closely
regulated and supervised to channelize the growth in the desired direction and
keep economy in proper shape. The sector helps in overall social good by
facilitating the growth that reaches all strata of society. In fact, the sector is
helping in the financial inclusion so that the fruits of growth are enjoyed by the
economically weaker sections and their overall interests are protected.
To monitor the sector and bring synergies with other sectors, the Government
and the banking regulator need credible financial and non-financial information.
This further enables them to fulfil the promise of "greater good for greater
number of people" that democracy like India endeavours for.
The Government and the regulators require credible information from banks to be
able to make informed decisions. In this context, statutory audits of banks'
financial statements are highly crucial. For quality bank audits, it is essential that
the statutory auditors are well equipped in terms of knowledge of the banking
sector and keep themselves abreast with the latest developments.
The Guidance Note on Audit of Banks brought out by the Auditing and Assurance
Standards Board of the Institute of Chartered Accountants of India every year is
an important resource that provides detailed guidance to the bank auditors on the
basic tenets of a bank audit. I am, therefore, very happy to note that the Auditing
and Assurance Standards Board has come out with the revised 2016 edition of
the Guidance Note on Audit of Banks.
At this juncture, I wish to place my appreciation for CA. Abhijit Bandyopadhyay,
Chairman, CA. J. Venkateswarlu, Vice Chairman and other members of the
Auditing and Assurance Standards Board for their zeal and commitment in
bringing out this literature to help the members in maintaining quality in bank
audits.
I am confident that the readers will find the 2016 Guidance Note highly useful in
their professional assignments in a similar manner as its previous editions.
New Delhi CA. Manoj Fadnis
January 25, 2016 President, ICAI
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Foreword and Preface of Past Years
Preface to Eleventh Edition
The economic development of any country, especially an emerging economy like
ours, depends significantly on the depth and reach of its banking sector. As the
recent global experience amply shows, an economy would survive only so long
as its banking sector stands on sound banking fundamentals and is supported by
a regulatory environment that, on the one hand, provides a fair opportunity to the
banks to promote economic activity and on the other hand provides control
mechanism that ensures that public monies and public interest remain protected.
The statutory audit of banks forms an integral and important part of such control
mechanism of the regulators. It provides the stakeholders a comfort with regard
to credibility of the financial information that a bank generates at every year end.
Given the nature, scope and volume of transactions undertaken by banks in
India, coupled with their geographical spread and the various regulatory
directions to which they are subject, audit of the financial statements of banks
indeed becomes very challenging for their auditors.
The Auditing and Assurance Standards Board of ICAI has been actively
supporting the members in their role as statutory auditors of banks by bringing
out a number of technical publications dealing with the various aspects of bank
audit. The Guidance Note on Audit of Banks has always been a benchmark
publication in this context.
The Guidance Note is updated every year to reflect the important developments
that have taken place in the banking sector, warranting attention of the statutory
auditors, for example, RBI's master circulars, general circulars of relevance,
consequential updation of guidance for the auditors, where required, various
pronouncements of ICAI, etc.
I am, therefore, happy to place in your hands the 2016 edition of the Guidance
Note on Audit of Banks. In addition to the updations required on account of
Master Circulars issued in 2015, the Guidance Note, inter alia, has been revised
to include the new developments in the banking industry, such as, introduction of
payment and small finance banks, how RBI exercises control over banking
industry, some international developments of importance in the global banking
industry, risk assessment and controls related to products regulated by SEBI and
other regulators, Red Flag Accounts and Early Warning System, developments in
respect of anti money laundering provisions, additional examples of IT and
related frauds, verification of IT assets, guidance on capitalization of assets,
FIMMDA Trade Reporting and Confirmation System, explanation of terms
commonly used in case of investments by banks, audit procedures for loss on
derivative transactions and margins held with exchanges, margins held under
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credit support annex, additional guidance on consolidation of branch accounts,
new chapter on consolidation of financial statements, etc.
The CD accompanying the Guidance Note contains Illustrative formats of the
engagement letter, the auditor's report and the written representation letter,
updated bank branch audit programme for the year 2015-16, the text of Master
Circulars issued by RBI on July 1, 2015 and the text of General and Other
Circulars of RBI.
At this juncture, I wish to place on record my gratitude to all the members of the
Mumbai study group viz., CA. Shriniwas Y. Joshi, Convenor, CA. Gautam Shah,
CA. Vikas Kumar, CA. Sandeep D. Welling, CA. Shivratan Agarwal, CA. N.
Sampath Ganesh, CA. Vipul Choksi, CA. Niranjan Joshi, CA. Manish Sampat,
CA. Sanjay Khemani, CA. Abhay V. Kamat, CA. Ashutosh Pednekar, CA.
Dhananjay J. Gokhale, CA. Mrudul Gokhale, CA. Parag Hangekar, CA. Sanjay
Rane, CA. Kedar Mehendale, Mr. Prabhat Gupta, CA. Rukshad Daruvala, CA.
Abhijit Sanzgiri, CA. Nilesh Joshi and CA. Nitant Trilokekar for their dedication in
taking up this herculean project despite the demands of their professional and
personal lives.
I take this opportunity to place on record my sincere thanks to CA Manoj Fadnis,
President ICAI and CA M Devaraja Reddy, Vice President ICAI for their support
to the activities of the Board.
I am also thankful to all my Central Council colleagues for their support and
guidance to the activities of the Board. I also wish to place on record my gratitude
to all the members and special invitees on the Auditing and Assurance Standards
Board for the year 2015-16, viz., CA. J. Venkateswarlu, Vice Chairman, AASB,
CA. Prafulla Premsukh Chhajed, CA. Pankaj Inderchand Jain, CA. Nihar Niranjan
Jambusaria, CA. Dhinal Ashvinbhai Shah, CA. Nilesh S. Vikamsey, CA. Babu
Abraham Kallivayalil, CA. K. Raghu, CA. G. Sekar, CA. Sumantra Guha, CA.
Shyam Lal Agarwal, CA. Sanjiv Kumar Chaudhary, CA. Naveen N.D. Gupta, CA.
Charanjot Singh Nanda, Shri P.K. Mishra, Shri Salil Singhal, Shri R.K. Jain, CA.
V. Balaji, CA. Radha Krishna Agrawal, CA. Kamlesh Amlani, CA. Aseem Trivedi,
CA. Krishna Kumar T., CA. Rajeevan M., CA. Sanjay Vasudeva, CA. Vijay
Sachdeva, Dr. Sanjeev Singhal, Shri Narendra Rawat, CA. Aniruddh Sankaran
and Shri R. Kesavan without whose support, the Guidance Note would not have
been possible.
I am sure that the members would find this edition of the Guidance Note as
useful as its earlier editions. I would, however, be happy to have your feedback
on the Guidance Note.
Kolkata CA. Abhijit Bandyopadhyay
January 25, 2016 Chairman, Auditing & Assurance Standards Board
432
Foreword and Preface of Past Years
Foreword to Tenth Edition
The banking sector in India, perhaps, is one of the largest in the world as far as
its extensive branch network is concerned. The role of the banking sector in the
overall growth and development of the Indian economy is also quite significant
and laudable. Like all economic activities, the banking sector is also exposed to
various risks in the conduct of their operations. For safe and sound banking
sector, one of the most important factors is reliable financial information
supported by audits performed in accordance with the established performance
benchmarks.
I am happy that the Auditing and Assurance Standards Board of the Institute of
Chartered Accountants of India, in order to help the members in maintaining
quality in bank audits, has come out with the revised 2015 edition of the
Guidance Note on Audit of Banks. The Revised edition incorporates the impact of
the various circulars of the Reserve Bank of India, provisions of the Companies
Act, 2013 and certain important pronouncements of the Institute which would be
relevant to bank audits for the financial year ending March 31, 2015.
At this juncture, I wish to place my appreciation for CA. Abhijit Bandyopadhyay,
Chairman, Auditing and Assurance Standards Board for his zeal and
commitment to reach out to the members in the profession in maintaining quality
in the audit services rendered by them.
I am confident that the members would find the 2015 edition of the Guidance
Note immensely helpful.
New Delhi CA. Manoj Fadnis
February 19, 2015 President, ICAI
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Guidance Note on Audit of Banks (Revised 2019)
Preface to Tenth Edition
Banking is a very dynamic industry. Its contours are always on the change, in
tandem with the changes in the sentiments of the national as well as global
economy. On the other hand, it is a tool in the hands of the policy makers to
create the desired sentiments and level of activity in the economy as also social
development.
Given the huge spread of the banking sector in terms of nature of activities
undertaken, client profile, geography, etc., as also the fact that the banking
industry is inextricably linked to the various players in the economy, it is also
exposed to a large number of risks that can affect their financial stability. Banks,
therefore, function under the tight supervisory and regulatory directions of the
Reserve Bank of India to minimise these internal and external risks that face the
banking industry. Accordingly, banks also have extensive systems for internal
controls to comply with these directions and to otherwise also protect them from
these risks.
These aspects make audit of the financial statements of banks extremely typical.
For example, understanding the bank and its operating environment, its controls
environment at macro and micro levels, risk of misstatements in the financial
statements, etc., can be very challenging and time consuming. As a corollary,
the audit planning too would require considerable attention of the auditor.
Similarly, deciding audit materiality, sample size, application of analytical
procedures too would need careful exercise of professional judgment by the
auditors. I would not hesitate to add that audit of a bank is one of the best
example how application of Standards on Auditing, including the concept of
exercise of professional scepticism by the auditors, ensures audit quality.
I am, therefore, happy to place in your hands this 2015 Guidance Note on Audit
of Banks. The Guidance Note provides an insight into the banking industry in
India and how they carry out their day to day functions. It also discusses in depth
the various important items on the financial statements of a bank, its peculiarities,
manner of disclosure in the financial statements, the RBI prudential directions
thereon, audit procedures, etc. Similarly, the Guidance Note has Chapters on
audit procedures for reporting on long form audit reports for banks and bank
branches, reporting under Ghosh and Jilani Committee requirements, special
purpose reports and certificates, etc. At this juncture, I may also mention that, as
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Foreword and Preface of Past Years
the members may be aware, the Auditing & Assurance Standards Board has
been working closely with the Reserve Bank of India for bringing out revised and
more contemporary Long Form Audit Reports (LFARs) for banks and bank
branches. As and when the revised LFARs are notified by the RBI, we will
separately bring out relevant guidance for the auditors. Accordingly, as of
now, this edition of the Guidance Note contains the existing LFARs and auditors'
guidance relevant thereto.
The Guidance Note, inter alia, has been updated for the impact of RBI Master
Circulars issued in 2014, Basel III, service tax requirements, etc. Importantly, the
auditors of the banking companies, in addition to the reporting requirements
under the Banking Regulation Act, 1949, would also need to report pursuant to
section 143 of the Companies Act, 2013. The auditors would accordingly need to
amend their audit engagement letters and the auditor's report. Illustrative formats
of an engagement letter and an auditor's report for a banking company, meeting
the requirements of the Banking Regulation Act, 1949 as well as the Companies
Act, 2013, have also been given in the Appendices given in the CD. Similarly, an
updated bank branch audit programme for 2014-15 audits is also given.
I am sure the readers appreciate that updating this Guidance Note is a herculean
task. Accordingly, my thanks are due to the Mumbai study group viz., CA
Shriniwas Y Joshi, convenor, CA Abhay Kamat, CA Ashutosh Pednekar, CA
Ganesh Sampath, CA Gautam Shah, CA Manish Sampat, CA Niranjan Joshi, CA
Sandeep Welling, CA Sanjay Khemani, CA Shivratan Agarwal, CA Shrawan B
Jalan, CA Vikas Kumar, CA Vipul Choksi, CA Zubin Billimoria and CA Sandeep
Sarawgi, for their dedication in taking up this task despite the demands of their
professional and personal lives.
I take this opportunity to place on record my sincere thanks to CA Manoj Fadnis,
President ICAI and CA M Devaraja Reddy, Vice President ICAI for their support
to the activities of the Board.
I am also thankful to all my Central Council colleagues for their support and
guidance extended by them at all junctures. I also wish to place on record my
gratitude to all the members and special invitees on the Auditing & Assurance
Standards Board (2014-15), viz., CA. K. Raghu, CA. Rajkumar S. Adukia, CA.
Nihar Niranjan Jambusaria, CA. Sanjeev K. Maheshwari, CA. Nilesh S.
Vikamsey, CA. Shiwaji Bhikaji Zaware, CA. V. Murali, CA. S.
Santhanakrishnan, CA. J. Venkateswarlu, CA. Subodh Kumar Agrawal, CA.
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Guidance Note on Audit of Banks (Revised 2019)
Mukesh Singh Kushwah, CA. Sanjiv Kumar Chaudhary, CA. Atul Kumar Gupta,
Shri P Sesh Kumar, Shri Bhaskar Chatterjee, CA. Sanjay Kumar Jain, CA. Sunil
Ramakant Bhumralkar, CA. K. Sai Ram, CA. Navin Tilakraj Gupta, CA. Ravi
Prasad, CA. Uttam P. Agarwal, Shri R Kesavan, RBI, Shri Anindya K Das,
SEBI, CA. Vijay Sachdeva, ASSOCHAM, CA. Sanjay Vasudeva and CA Amit
Roy, CII without whose support, the Guidance Note would not have been
possible.
I am sure that the members would find the 2015 edition of the Guidance Note as
useful as its earlier editions. I would, however, be happy to have your feedback
on the Guidance Note.
Kolkata CA ABHIJIT BANDYOPADHYAY
18th February 2015 Chairman,
Auditing & Assurance Standards Board
436
Foreword and Preface of Past Years
Foreword to Ninth Edition
The banking industry in India has a huge of history, which covers the traditional
banking practices from the time of Britishers to the reforms period, nationalization
to privatization of banks and now increasing numbers of foreign banks in India.
Therefore, the banking industry in India has been through a long journey and has
also achieved new heights with the changing times. The use of technology
brought a major revolution in the working system of the banks. Nevertheless, the
fundamental aspects of banking i.e. trust and confidence of the people on the
institution remains the same, which comes on the back of strong quality of audit
system and practices in place.
Since the issuance of the last edition of the Guidance Note on Audit of Banks, a
number of important developments have taken place in the banking sector,
warranting attention of the auditors. It is, therefore, essential that the members
undertaking statutory audit of banks, both at the branch as well as the central
level, keep themselves abreast with the latest developments in the banking
sector.
I am pleased that in order to help the members maintain the quality in bank
audits, the Auditing and Assurance Standards Board of the Institute of Chartered
Accountants of India under the able and dynamic Chairmanship of CA. Abhijit
Bandyopadhyay, has come out with a completely revised and edited 2014 edition
of the Guidance Note on Audit of Banks. The revised edition incorporates the
guidance for the statutory auditors at branch as well as central level w.r.t. the
various circulars of the Reserve Bank of India as well as important
pronouncements of the Institute. I am also happy that the 2014 Guidance Note
has been totally revamped to make it more reader-friendly.
I hope that the members would find the 2014 edition of the Guidance Note
immensely helpful.
New Delhi CA. K. Raghu
February 24, 2014 President, ICAI
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Guidance Note on Audit of Banks (Revised 2019)
Preface to Ninth Edition
Independent audit of financial statements of banks is one of the important tools
for throwing light on their financial health, the state of their affairs, the results of
their operations and the position of their cash flows. Financial statement audit
therefore is important for a strong and resilient banking industry. Audit of banks,
however, involves certain typicalities which make the task of the auditors quite
onerous. Most significant of these being volume and complexity of transactions,
geographical spread, client portfolio, wide variety of products and services
offered, extensive use of technology and above all, high sensitivity to the
slightest of changes in the social, economic or political environment. As a result,
the risks faced by banks vary in nature and quantum with the all these aspects.
Obtaining an appropriate and adequate understanding of these aspects and the
resultant risks, particularly, their impact on the truth and fairness of a bank or its
component's financial statements becomes a humungous but nonetheless
essential task for the auditors. Every year, the Auditing and Assurance Standards
Board of the Institute of Chartered Accountants of India brings out the Guidance
Note on Audit of Banks to help the common members understand the important
aspects of the banking industry so that they can understand these risks and plan
and perform their audits effectively and efficiently against the strict time
deadlines.
It is, therefore, my great pleasure to place in your hands, the 2014 Guidance
Note on Audit of Banks. The 2014 edition of the Guidance Note has been written
to not only reflect the important regulatory changes that have been brought about
by the Reserve Bank of India since 2013 through its Master and other general
circulars issued till 23rd February 2014 as usual but also implementation of Core
Banking Solutions at almost all levels in the banks. The guidance to the auditors
has been suitably revised to reflect the impact of CBS on financial reporting
system. Besides, in sync with the requirements of the current suite of Standards
on Auditing, the Guidance Note has also been given the flavour of risk-based
audit approach. Further, guidance has also been included on aspects on which
members have frequently posed queries. We have also identified and removed
repetitive guidance and shifted certain conceptual and basic level aspects to the
accompanying CD to reduce the volume of the publication and make the
Guidance Note more user-friendly. In addition to the text of the Guidance Note,
this CD also contains important data such as text of RBI's Master Circulars as
well as other important circulars issued till 23rd February 2014, appendices,
illustrative checklists, etc.
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Foreword and Preface of Past Years
At this juncture, I wish to place on record my gratitude to each and every member
of the Mumbai study group viz., CA. Shriniwas Y Joshi, CA. Abhay Kamat, CA.
Ashutosh Pednekar, CA. Ganesh Sampath, CA. Gautam Shah, CA. Manish
Sampat, CA. Neville Daruwalla, CA. Niranjan Joshi, CA. Sandeep Kumar
Sarawgi, CA. Sandeep Welling, CA. Sanjay Khemani, CA. Shivratan Agarwal,
CA. Shrawan Kumar B Jalan, CA. Ulhas Chitale, CA. Vikas Kumar, CA. Vipul
Choksi, CA. Zubin Billimoria for taking time out of their pressing professional and
personal preoccupations to work on this herculean project .
I also place on record my sincere thanks to CA K Raghu, President, ICAI and
CA. Manoj Fadnis, Vice President, ICAI for their constant support to the activities
of the Board.
I am also thankful to all my Council colleagues, for their unstinted support
and helpful guidance that I have always been fortunate to receive in the
activities of the Board. I also wish to express my gratitude to all the
members and special invitees on the Auditing and Assurance Standards
Board for 2013-14, viz., CA. Naveen N.D. Gupta, the then Vice Chairman,
CA. Rajkumar S. Adukia, CA. Subodh K Agrawal, CA. Jay Ajit Chhaira, CA.
Sanjeev K. Maheshwari, CA. Shiwaji Bhikaji Zaware, CA. M. Devaraja Reddy,
CA. Dhinal Ashvinbhai Shah, CA. S. Santhanakrishnan, CA. J.
Venkateswarlu, CA. Vijay Kumar Gupta, CA. Sanjiv K Chaudhary, Shri
Gautam Guha, Shri Bhaskar Chatterjee, CA. Sanjay Vasudeva, CA. Niraj
Kumar Jhunjhunwala, CA. Ganesh Balakrishnan, CA. Charanjeet Surendra
Attra, CA. Harinderjit Singh, CA. Saunak Ray, Shri Anindya Kumar Das, CA.
Nilesh S. Vikamsey, CA. Jitendra K Agarwal, CA. Amit Roy, CA. Vijay
Sachdeva and CA. Aniruddh Sankaran without whose support this publication
would not have been possible. I also wish to thank the Secretariat of the
Auditing and Assurance Standards Board for their efforts in giving the
Guidance Note its final shape.
I am sure that the 2014 edition of the Guidance Note on Audit of Banks would
also be as warmly received by the members as its earlier editions. I look forward
to the readers' feedback on the publication.
Kolkata CA. Abhijit Bandyopadhyay,
February 24, 2014 Chairman,
Auditing & Assurance Standards Board
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Guidance Note on Audit of Banks (Revised 2019)
Foreword to Eighth Edition
The Banking Sector is the most dominant segment of the financial sector in the
Indian economy. It is fairly mature in terms of product range and reach. The
banking sector, like all economic activities, is also exposed to the risk in the
conduct of their business. However, Indian banks continue to build on their
strengths with good quality audits serving as the backbone of the strong banking
system in place today.
In terms of quality of assets and capital adequacy, Indian banks are considered
to have clean, strong and transparent balance sheets relative to other banks in
comparable economies. The statutory auditors have had a critical role to play in
this.
I am happy that the Auditing and Assurance Standards Board of the Institute of
Chartered Accountants of India has come out with the Revised 2013 Edition of
the Guidance Note on Audit of Banks. The Revised edition incorporates the
impact of the various circulars of the Reserve Bank of India as well as certain
important pronouncements of the Institute which would be relevant to bank audits
for the financial year ending March 31, 2013.
At this juncture, I wish to place my appreciation to CA. Abhijit Bandyopadhyay,
Chairman, Auditing and Assurance Standards Board for his zeal and
commitment in bringing out such literature and make it available to the members
at large thereby enabling them in maintaining quality in the audit services
rendered.
I am confident that the members would find the revised edition of the Guidance
Note immensely helpful.
New Delhi CA. Subodh Kumar Agrawal
March 14, 2013 President, ICAI
440
Foreword and Preface of Past Years
Preface to Eighth Edition
Audit of banks has been much in the limelight in the professional and regulatory
circles for a variety of reasons. As the financial year 2012-13 draws to an end,
the members who have been allotted bank statutory central audits and bank
branch audits would be busy preparing for these audits. The Profession must
utilize this opportunity to demonstrate how an audit of financial statements is not
just a regulatory requirement to be complied with but it indeed has an immense
value to not only the auditee banks but also to the banking regulator, i.e., the
Reserve Bank of India.
At this juncture, it gives me immense pleasure to place in your hands the 2013
edition of the Guidance Note on Audit of Banks, which would help the auditors in
efficient and effective conduct of the audit. This edition of the Guidance Note has
been updated since the last edition which came out in 2011. During these two
years a number of important directives have been issued by the banking
regulator i.e., the Reserve Bank of India which the statutory auditors are required
to be aware of, particularly, those brought about by the RBI through its various
Master Circulars and a number of other relevant circulars. I also take this
opportunity to reiterate that the auditor's report for the financial year 2012 13
onwards would have to be issued in the revised format as prescribed under the
Revised SA 700 issued by the Institute of Chartered Accountants of India.
I take this opportunity to place on record my sincere gratitude and appreciation
for the members of the Mumbai study group, viz., CA Shriniwas Y. Joshi,
coordinator of the study group, CA Vipul Choksi, CA Ashutosh Pednekar, CA
Akeel Master, CA Sanjay Khemani, CA Vikas Kumar, CA Zubin Billimoria, CA
Manish Sampat, CA Niranjan Joshi, CA Sandeep Welling, CA Shivratan Agarwal,
CA Ulhas Chitale, CA Gautam Shah, CA Neville M. Daruwalla and CA Ashwin
Suvarna for squeezing time out of their pressing professional and personal
commitments to work on the 2013 edition of the Guidance Note on Audit of
Banks and finalise it in a short time.
I also wish to place on record my gratitude to CA. Subodh K Agrawal, President,
ICAI and CA. K Raghu, Vice President, ICAI for their unstinted support to the
activities of the Board.
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Guidance Note on Audit of Banks (Revised 2019)
I am also grateful to my colleagues at the Auditing and Assurance Standards
Board, CA. Naveen ND Gupta, Vice Chairman, AASB, CA. Rajkumar S Adukia,
CA. Jay Ajit Chhaira, CA. Shriniwas Y Joshi, CA. Sanjeev Maheshwari, CA.
Dhinal A Shah, CA. Shiwaji B Zaware, CA. M. Devaraja Reddy, CA. S.
Santhanakrishnan, CA. J. Venkateswarlu, CA. Manoj Fadnis, CA. Sanjiv K
Chaudhary and CA. Vijay K Gupta for their support to the various projects of the
Board. I also wish to thank the Secretariat of the Auditing and Assurance
Standards Board for their efforts in giving the Guidance Note its final shape.
I am sure that like its predecessors, the readers would find this updated edition of
the Guidance Note also extremely useful.
Kolkata CA. Abhijit Bandyopadhyay,
March 14, 2013 Chairman,
Auditing & Assurance Standards Board
442
Foreword and Preface of Past Years
Foreword to Seventh Edition
The Banking system remains, as always, the most dominant segment of the
financial sector in the Indian economy. Today, the banking sector in India is fairly
mature in terms of supply, product range and reach. The banking sector, like all
economic activity is also exposed to risk in the exercise of their business. Indian
banks continue to build on their strengths with good quality audits serving as the
backbone of the strong banking system in place today.
In terms of quality of assets and capital adequacy, Indian banks are considered
to have clean, strong and transparent balance sheets relative to other banks in
comparable economies in its region. The responsibility for this lies on the
shoulders of the auditors.
I am pleased to note that the Auditing and Assurance Standards Board of the
Institute of Chartered Accountants of India has, in order to help the members
maintain the good quality of bank audits, come out with the 2011 Edition of the
Guidance Note on Audit of Banks. The Revised edition incorporates the impact
of the various circulars of the Reserve Bank of India as well as certain important
pronouncements of the Institute which would be relevant to bank audits for the
financial year ending March 31, 2011.
At this juncture, I wish to place my appreciation to CA. Abhijit Bandyopadhyay,
Chairman, Auditing and Assurance Standards Board for his zeal and
commitment to reach out to the members in the profession in maintaining quality
in the audit services rendered by them. More so, as the Guidance Note on Audit
of Banks is a publication which is eagerly awaited by one and all.
I am extremely confident that the members would find the revised edition of the
Guidance note immensely helpful in efficiently conducting audit of banks.
New Delhi CA. G RAMASWAMY
President, ICAI
March 11, 2011
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Preface to Seventh Edition
The banking industry is a systemically important industry for the Indian economy
in general and financial sector in particular as it comprises nearly 90% of the
total financial services sector of the country. The banking industry in India has
undergone significant transformation since the initiation of the financial sector
reforms that were part of the structural reforms of early 1990s. The banking
sector has steadily evolved from a state-directed banking system into a fairly
open competitive banking system.
Banking in India has become service oriented, maturing from the days of
`walking in business' to the present situation of 24 hour banking solutions to
attract customers. With such widespread and rapid growth of the banking
industry and their entry into a wide variety of services like insurance, mutual
funds, etc., the onus of the healthy sustenance and growth of the banking
industry lies on the back of reliable financial statements which can only be
assured by good quality audits. The bank audit is thus an important step for all
banks who seek a better optimization of its overall management.
To help the members provide value add audit of the financial statements of a
bank, the Institute has brought out the 2011 edition of the Guidance Note on
Audit of Banks, thoroughly revised in the light of the relevant circulars issued by
the Reserve Bank of India between 2009 till date. Since adequate and
appropriate understanding of an auditee is a prerequisite for any effective audit,
the Guidance Note contains comprehensive information on the working of a
modern bank, its control systems, books of account, legal and regulatory
requirements, including introduction of new banking concepts, in addition to
comprehensive information and audit guidance on important items on the
financial statements of banks.
The 2011 Guidance Note covers critical aspects such as Knowledge of the
Banking Industry, Risk Assessment and Internal Control, Items of Bank's
Financial Statements and Auditing Aspects, Long Form Audit Reports, Special
Aspects. The text of the relevant circulars of the Reserve Bank of India is given in
the CD with the Guidance Note.
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At this juncture, I would wish to place my gratitude to CA. G Ramaswamy,
President and CA. Jaydeep N Shah, Vice President, ICAI for their support and
valuable guidance to the initiatives of the Auditing and Assurance Standards
Board. My sincere thanks is also due to CA. M M Khanna, CA. Sanjay Vasudeva
and CA. Ajay K Jain from New Delhi and CA. Vipul Chokshi from Mumbai for
their valuable inputs in making the 2011 edition of the Guidance Note more
useful and comprehensive.
I also wish to place on record my sincere thanks to my colleagues at the Board,
viz., CA. Rajkumar S Adukia, Vice-Chairman, AASB, CA. Amarjit Chopra, CA.
Naveen N.D. Gupta, CA. Sanjeev K. Maheshwari, CA. M. Devaraja Reddy, CA.
Rajendra Kumar P., CA. J. Venkateswarlu, CA. Sumantra Guha, CA. Anuj Goyal,
CA. Pankaj Tyagee, CA. Jayant P. Gokhale, CA. S. Santhanakrishnan, CA.
Mahesh P. Sarda, CA. Vijay Kumar Garg, CA. V. Murali, CA. Nilesh S. Vikamsey,
Ms. Usha Sankar, Shri Prithvi Haldea, CA. David Jones, CA. Sanjay Vasudeva,
CA. Raviprasad, CA. P.R. Vittel, CA. C.N. Srinivasan and CA. Ramana Kumar B
for their views for further improvements to the Guidance Note. My sincere
gratitude is also due to all my other Central Council colleagues without whose
support this edition of the Guidance Note would not seen the light of the day.
I am extremely confident that the Guidance Note would prove to be highly useful
and relevant for authoritative reference for the auditors and also for all those who
are connected with the banking industry in one way or other.
Kolkata CA. Abhijit Bandyopadhyay
March 11, 2011 Chairman
Auditing and Assurance Standards Board
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Guidance Note on Audit of Banks (Revised 2019)
Foreword to Sixth Edition
India's banking industry must strengthen itself significantly in order to support the
modern and vibrant economy which India aspires to be. The last decade has
seen many positive developments in the Indian banking sector. Policy makers
have made some notable changes in policy and regulation to help strengthen the
sector. These changes include strengthening prudential norms, enhancing the
payments system and integrating regulations between commercial and co-
operative banks.
For safe and sound banking system, one of the most important ingredient is
reliable, clear financial information supported by quality audits. At the same time,
audit also complements supervisory efforts of the regulators in risk management
and efficient functioning of banking system.
In order to equip our members with requisite updated knowledge on functional
areas of the banking operation, I am pleased to note that the Auditing and
Assurance Standards Board of the Institute has brought out the revised
edition of the Guidance Note on Audit of Banks. The revised edition has been
updated by incorporating insightful guidance into the impact of various new/
revised circulars issued by the Reserve Bank of India.
I am sure that the members will find the revised Guidance Note, like its
earlier editions, useful in providing a comprehensive overview of the
functioning of a bank and guidance on critical aspects of a bank audit. I am
confident that this publication would surely help the members in discharging
their responsibility in an effective manner.
New Delhi Ved Jain
February 04, 2009 President, ICAI
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Preface to Sixth Edition
Liberalization and de-regulation process that started in 1991-92 made a sea
change in the working and reach of the banking system. From a totally regulated
environment, it has moved gradually into a market driven competitive system
though the move towards global benchmarks has been, by and large, calibrated
and regulator driven.
In this dynamic environment, the auditors of banks, in their own way, play a
crucial role in upholding and enhancing the credibility of the banking system. In
order to equip the members with updated knowledge on banking industry, the
Auditing and Assurance Standards Board has been from several past years
coming out with Guidance Note on Audit of Banks. The 2009 edition of the
Guidance Note has thoroughly been revised by taking the impact of the relevant
circulars issued by the RBI from time to time. The audit procedures have been
thoroughly revised in view of the issuance of risk-based Standards on Auditing
which have come into force with effect from 1st April, 2008. Further, three new
chapters have been added in the 2009 edition, i.e., "Special features of bank
treasury operations, foreign exchange and derivative transactions", "Basel II" and
"Disclosure requirements in financial statements".
I wish to place on record my sincere gratitude to CA. Vipul K. Choksi, FCA,
convenor of the Study Group constituted at Mumbai and all the other members of
the Study Group, viz., CA Abhijit Sanzgiri, CA Ashutosh Pednekar, CA Akeel
Master, CA Ketan Vikamsey, CA Sanjay Khemani, CA Vikas Kumar, CA Zubin
Billimoria, CA. Kamlesh Vikamsey, CA. Uday Chitale, CA. Asit Pal, CA. Jatin
Lodaya, CA. Shiv Ratan Agarwal CA. Manoj Daga and CA Dharini Shah who
have squeezed time from their professional and personal commitments to
complete this mammoth task of revising the Guidance Note. I would also take the
opportunity of placing on record my gratitude to all the members of the Expert
Group viz., CA. Amarjit Chopra, CA. K. P. Khandelwal CA. S. Santhanakrishnan,
CA. Manoj Fadnis and CA. Shanti Lal Daga for their invaluable comments and
suggestions. I am also thankful to all my colleagues on the Auditing and
Assurance Standards Board and Council for their continuous support and
guidance.
I am sure that the members will find the guidance contained in this revised
edition effective in conducting audit of banks and their branches.
New Delhi Harinderjit Singh
February 04, 2009 Chairman
Auditing and Assurance Standards Board
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Foreword to Fifth Edition
Sounding clichéd as I may do, yet I would begin with stating what has been
said at a number of for a number of times that the economic growth and
development of the society hinges to a large extent on the soundness of the
accountancy profession. It is one profession which has had a reach and has
enjoyed unwavering trust of one and all, not withstanding the political,
cultural or economic barriers that might have separated them.
Whereas this unwavering trust has placed the accountancy profession in a
unique position to command authority and respect, it has also been
something which has given sleepless nights to not only the regulators but
also the professional accountancy bodies across the world. These
professional bodies have been working relentlessly towards equipping their
members with the latest knowledge and skill sets to help them perform
efficiently and uphold that trust.
The Institute too has been committed to that cause and has a clear approach
to keeping its members technically sound. Issuing authoritative technical
literature has been an integral part of this approach. The challenge however
is to keep that literature current and relevant. I am happy to note that the
Auditing and Assurance Standards Board of the Institute has brought out the
revised version of the Guidance Note on Audit of Banks incorporating the
latest regulatory and other professional requirements having an impact on
audit of banks.
I am sure that the readers will find the revised Guidance as useful as its
earlier version, not only as a one stop reference for audit procedures in case
of banks but also as a concise compendium of significant banking activities.
New Delhi Sunil H. Talati,
February 4, 2008 President, ICAI
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Preface to Fifth Edition
Banking is a unique industry in itself. In a world divided by political,
economic and social boundaries and barriers, it acts as a glue to keep it
integrated in one way or the other. This fact has been underlined time and
again; the tremors of the recent crises in the US banking industry have been
felt in almost all parts of the world. Extensive geographical spread, wide
array of products and services offered, high volumes of transactions many of
which are quite complex, advanced level of automation, large customer base
are some of the other elements of uniqueness of the banking industry.
This uniqueness of banking industry, however, poses a major challenge in
the audit of banks. The answer to this challenge for the auditors lies, to a
considerable extent, I personally believe, in two things, one, having a firm
grip on the knowledge of the banking industry and second, in keeping update
with the professional (in particular the latest auditing standard &
pronouncements), regulatory and other industry related developments. The
Guidance Note on Audit of Banks (2008 edition) has been designed keeping
in view the aforesaid requirements. The Guidance Note has been divided
into four parts, first, the knowledge of the banking industry and its operational
aspects; second, related audit procedures; third, LFAR both at the branch as
well as head office level; and fourth, special purpose reports and certificate
and other special aspects, etc. Also the relevant circulars are contained in
the accompanying CD. At this juncture, I also wish to underline the fact that it
is necessary to read the Guidance Note in its entirety to properly appreciate
the guidance given therein.
I would like to place on record my sincere gratitude to CA S Swaminathan,
from Chennai who volunteered to undertake this mammoth task of revising
and restructuring the 2006 edition of the Guidance Note. I am also thankful
to all my colleagues in the Auditing and Assurance Standards Board and
Council for their continuous support and guidance. I would also like to place
on record my thanks to CA. Ashok Batra from Delhi and CA. Mitil Chokshi
from Mumbai for providing his invaluable inputs on the Guidance Note. I also
wish to appreciate the contribution of CA. Priya Subramaniam, Senior
Assistant Director, Board of Studies in respect of taxation of banks. Finally, I
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also wish to record my thanks to Shri Vijay Kapur, Director, Auditing and
Assurance Standards Board and his team at the AASB Secretariat for giving
final shape to the revised Guidance Note.
I am sure that the readers would find the guidance note useful.
New Delhi Harinderjit Singh
February 4, 2008 Chairman
Auditing and Assurance Standards Board
450
Foreword and Preface of Past Years
Foreword to Fourth Edition
Since the issuance of the last edition of the Guidance Note on Audit of Banks
in March 2005, a number of important developments have taken place in the
banking sector, warranting attention of the auditors. Some of these
developments are usual and happen every year such as the issuance of the
revised income recognition and asset classification norms, investment
exposure norms, etc. Some of these changes, however, highlight some
major policy shifts by the Reserve Bank of India and would have a lasting
impact on the future of the banking industry in India, such as move towards
risk-based supervision of banks, para banking activities, new capital
adequacy norms, etc.
In addition, the banking industry in India in the recent past has been a
witness to the flurry of merger and acquisition activities. Further, the recent
years have also seen a growing interest of the banking industry in the capital
markets. It is, therefore, essential that members undertaking statutory audit
of banks keep themselves abreast with the latest developments in the
banking including the actions of the banking regulator, the Reserve Bank of
India. I am happy to note that the Auditing and Assurance Standards Board
has brought out the 2006 edition of the Guidance Note on Audit of Banks well
in-time to keep the members abreast with the vital changes in the banking to
help them appropriately understand the impact of these changes on their
audit.
I sincerely hope that the members would find this edition of the Guidance
Note also useful and informative.
New Delhi T.N. Manoharan
March 14, 2006 President
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Guidance Note on Audit of Banks (Revised 2019)
Preface to Fourth Edition
The economic development of any country depends significantly on the support
that it gets from the banking sector of the economy. In order to build up a
resilient banking industry, it is essential that the industry is founded on sound
banking principles and practices, complemented by effective regulation and
supervision. The recent past has witnessed the banking industry becoming the
focus of investment opportunities be it by way of IPOs or mergers and
acquisitions or FDI. Another significant development over the past few years has
been the growing activism of the banking industry in the capital markets.
The mammoth amounts of public monies being handled by the banks as well
as the inherent vulnerable nature of the banking industry, however, make it
imperative that the activities of the industry are closely monitored and regulated
without strangulating the spirit of entrepreneurship. Audit forms an integral and
important part of such monitoring and regulation. For past number of years the
members of the Institute have been taking on this responsibility with that extra
fervour and commitment. The Institute too has been actively supporting the
members in their role as statutory auditors of banks by bringing out a number
of technical publications dealing with the various aspects of bank audit,
especially the Guidance Note on Audit of Banks. The Guidance Note deals
with several important aspects of bank audit both at branch as well as head
office level. Keeping abreast with the latest developments in the banking
industry and understanding their impact on audit of banks is quintessential for
the auditors if they want to make any value addition.
The 2006 edition of the Guidance Note contains guidance on important aspects
such as risks associated with the banking industry, assessment of the risk based
internal audit system in banks, audit of ATMs, audit under CDR, and more
importantly the revised formats of the audit reports of nationalized banks as well
as banking companies, to name a few. This edition of the Guidance Note is
targeted at helping the members understand the various developments in the
banking industry since the issuance of the 2005 edition of the Guidance Note and
their impact on their audits. Some of the important aspects of the banking
industry that have undergone a change as a result of regulatory intervention
include the changes in the prudential norms on income recognition and asset
classification, exposure norms for credit and investment portfolio, loans and
advances, capital adequacy requirements, changes in the CRR, SLR, new
guidelines on corporate debt restructuring as well as small and medium
enterprises, introduction of risk based supervision in banks, guidelines on
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securitization of standard assets, KYC norms, etc. Some other important
developments that have impacted the banking industry are the banking cash
transaction tax, the fringe benefit tax, service tax etc. Further, for ease of
reference of the readers, the important changes in the 2006 edition from the
2005 edition are also indicated by way of footnote references.
The 2006 edition of the Guidance Note is divided into two Sections, Section I
contains the Text of the guidance whereas Section II contains the
Appendices. Section I is divided into four parts initial considerations, audit
of branches, audit of head office and special purpose reports and certificates.
Part II contains the text of the relevant circulars of the Reserve Bank of India
as well as the formats of the audit reports. For the benefit of the readers, the
appendices have also been given in a CD along with the Guidance Note.
At this juncture, I wish to place on record my immense gratitude to S/Shri
Dinesh Mehta, FCA, Rajiv Sogani, FCA, Anil Goyal, FCA, Atul Atolia, FCA,
Ashok Batra, FCA and Nitant Trilokekar, FCA who squeezed time out of their
busy professional and personal lives to revise certain important aspects of
the Guidance Note. My thanks are also due to Shri Nagesh D Pinge, Sr.
General Manager, ICICI Bank for his contribution in respect of the guidance
on risk based internal audit in banks. I also express my gratitude to Shri
Amarjit Chopra, FCA, my colleague in the Council as well as my immediate
predecessor as Chairman, Auditing and Assurance Standards Board under
whose able guidance and vision the revision of the 2005 Guidance Note was
initiated. I also wish to place my sincere thanks to my colleagues at the
Auditing and Assurance Standards Board for their valuable inputs on the
draft Guidance Note. My thanks are also due to my colleagues at the
Council, in specific to Shri Harinderjit Singh, also Vice Chairman of AASB as
well as Shri S C Vasudeva, for their incisive comments on improving upon
the draft Guidance Note and giving it a final shape. I also wish to place on
record the efforts put in by Shri Vijay Kapur, Secretary, Auditing and
Assurance Standards Board and his team of officers, viz., Smt. Puja
Wadhera, Senior Technical Officer, Shri Nitin Singhal and Shri Amit Sinha,
Executive Officers in finalizing the Guidance Note.
I am confident that the bank audit being just round the corner, this edition of
the Guidance Note too, as its predecessors, prove to be of immense use to
the members as also other interested readers.
New Delhi Sunil Goyal
March 16, 2006 Chairman
Auditing and Assurance Standards Board
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Guidance Note on Audit of Banks (Revised 2019)
Foreword to Third Edition
An audit based on the sound knowledge of the audit client is quintessential if
the Profession has to maintain its competitive edge as well as the confidence
reposed in it by all. Audit of the banking sector is no exception to that. In
fact, audit of a bank requires quite good knowledge of almost all the
functional areas of the banking operations.
As all are aware, the Institute has taken a number of initiatives to keep the
members abreast with the latest developments in the areas of professional
relevance, be it in the form of technical literature or seminars, etc. The 2005
edition of the Guidance Note on Audit of Banks, developed by the Auditing
and Assurance Standards Board is one such initiative. This edition is
thorough update of the Guidance Note issued in 2001 and the subsequent
2003 Supplement.
I am happy to note that the 2005 edition also contains an insightful guidance
into the impact of various new/revised circulars of the Reserve Bank of India
with respect to prudential norms, exposure norms on investments, etc. In
tune with times, the Guidance Note also contains specific guidance on
service tax matters.
With bank audits just around the corner, I am sure that this edition of the
Guidance Note on Audit of Banks too will prove to be immensely useful to our
members in discharge of their attest functions in the most appropriate
manner.
New Delhi (Kamlesh S. Vikamsey)
March 31, 2005 President
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Foreword and Preface of Past Years
Preface to Third Edition
The banking industry is no doubt the backbone of any economy. It is,
therefore, very essential to ensure that the banking industry remains healthy
and robust. The accountancy profession, within its given means and scope
of work contributes actively by ensuring proper financial reporting and
disclosure aspects of the banking industry. Statutory audit of banks is one
such area by which the accountancy profession makes such a contribution.
To be able to contribute to the health of the banking industry, it is essential
that the statutory auditors are well equipped in terms of the knowledge of the
banking industry. Guidance Note on Audit of Banks is an important tool in
the kitty of the members of the Institute to gain an insight into the systems
and processes in the significant functional areas of the banking industry,
such as the acceptance of deposits, credit, investments, fixed assets, branch
functions, etc. These all are obviously aimed at helping the members
understand and effectively evaluate the internal controls and accounting
systems in a bank.
A number of changes have taken place in the banking sector, having a bearing
on the functioning of the banks as also, consequently, statutory audit of banks.
The 2005 edition of the Guidance Note, therefore, is an extensively revised and
updated version of the 2001 Guidance Note and the 2003 Supplement, all with
the basic aim of keeping our members abreast with the latest developments in
the area of bank audits. Like the 2001 Guidance Note and the Supplement, the
2005 edition too delves into the impact of several new circulars in the field of
prudential and income recognition norms, investment norms, exposure of
investments, investment portfolio etc., on the functioning of as well as financial
reporting by the banks. In addition, the Guidance Note also touches upon the
aspect of application of various Accounting Standards, issued after the 2003
Supplement as well as the Report of the N D Gupta Committee on Compliance
with Accounting Standards by Banks. Another critical area in the banking
industry, which is being stressed upon by the Reserve Bank of India is
prevention of money laundering. The regulator has issued a number of
circulars relating to "Know Your Customer" guidelines. These circulars too
have been dealt with by the revised Guidance Note.
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Guidance Note on Audit of Banks (Revised 2019)
The revised Guidance Note also provides an insight into the technological
advancements impacting the banking sector, such as the internet banking
feature, etc. In addition to the above, as is the norm, the Appendices to the
revised Guidance Note contain the text of various relevant circulars issued by
the Reserve Bank of India as a source of ready reference for readers as also
the illustrative format of the auditor's report. In nut shell, the Guidance Note
aims to provide a comprehensive overview of the functioning of a bank and
critical aspects of a bank audit.
At this juncture, I wish to place my gratitude to the Study Group constituted at
Indore under the Convenorship of Shri Manoj Fadnis, FCA, which prepared
the basic draft of the revised Guidance Note at such a short notice. In
particular my special thanks are due to S/Shri Aseem Trivedi and Santosh
Deshmukh of Indore for the hard work put in by them. S/Shri Ashok Batra
and Nishith Seth of Delhi also deserve special mention for their valuable
contribution. I am also grateful to all my colleagues at the Auditing and
Assurance Standards Board for providing insights from their rich knowledge
and experience for improving upon the draft Guidance Note. A word of
thanks is also due to all my colleagues at the Council for providing their
invaluable guidance and support in giving the final shape to the revised
Guidance Note.
I am extremely grateful to Shri Vijay Kapur, Secretary, Auditing and
Assurance Standards Board, for his efforts and valuable inputs which were
so essential in bringing out this Guidance Note. Also my thanks are due to
technical staff of Auditing and Assurance Standards Board for their valuable
contribution.
I am sure that the members and other interested users will find this edition of
the Guidance Note useful in discharge of their professional obligations.
New Delhi Amarjit Chopra
March 30, 2005 Chairman
Auditing and Assurance Standards Board
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Foreword to Second Edition
The banking system in India, perhaps, is one of the largest in the world as far
as its extensive branch network is concerned. The role of the banking sector
in the overall growth and development of the Indian economy is also quite
significant and laudable. Today, disclosure practices followed by Indian
commercial banks are almost at par with those of international banks. The
introduction of prudential norms, capital adequacy norms, requirement to
attach the financial statements of the subsidiaries beginning from year 2000-
01 are definite measures to bring more transparency in the banking industry.
In this context, the Reserve Bank of India has been performing a stellar role
by issuance of detailed guidelines in close consultation with the ICAI.
In view of stringent disclosure practices and far-reaching technological
developments, the role of accounting profession with respect to the banking
industry has assumed considerable significance. The original Guidance Note
on Audit of Banks was issued in 1994. In view of far reaching changes, it
was imperative to revise the Guidance Note, to bring it in line with these
developments. I am pleased to note that the Auditing Practices Committee of
the Institute has brought out the revised Guidance Note on Audit of Banks. A
salient feature of the revised Guidance Note is that a considerable emphasis
has been laid on explaining the distinguishing characteristics of the banking
industry how it operates, what transactions take place, the sequence of
these transactions, the accounting system for recording the transactions and
the legal and regulatory framework within which it operates. Another
important feature of the revised Guidance Note worth mentioning is that it
deals separately with the audit of banks at the head office and that at the
branch level.
The draft of the Guidance Note was considered by the Council of the Institute
at its meeting held on 6th, 7th and 8th March 2001. I wish to specially
commend the efforts and contribution made by Mr. S. Gopalakrishnan,
Chairman, Mr. K.S. Vikamsey, Vice-Chairman and all the members of the
Auditing Practices Committee who undertook the mammoth task of bringing
out the revised Guidance Note in such short span of time. I also wish to
thank the members of the Central Council of the Institute for their valuable
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Guidance Note on Audit of Banks (Revised 2019)
suggestions in enriching the contents of the revised Guidance Note.
I appreciate the efforts of Mr Vijay Kapur, Secretary, Auditing Practices
Committee of the Institute and his team of Officers, without whose untiring
efforts, this Guidance Note would not have been published in time.
I am sure that the revised Guidance Note would prove immensely useful not
only to the members who have an experience in audit of banks but also those
members who are uninitiated to the area of bank audit.
New Delhi (N.D. Gupta)
March 20, 2001 President
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Preface to Second Edition
While the auditing principles remain the same regardless of the nature of the
entity under audit, the manner of their application has to be determined in the
context of the specific features of the industry to which the entity belongs and
also the specifics of the entity itself. This revised Guidance Note seeks to
provide guidance on application of generally accepted auditing principles in
the specific context of Banks.
A number of developments have taken place in the Banking industry. Some
of the prominent changes include, from time to time, in prudential guidelines
relating to income recognition, asset classification, provisioning and
investment valuation, capital adequacy and extensive computerization of
Banking operations. These developments have necessitated a thorough
revision of the Guidance Note to maintain its relevance in the changed
scenario.
This Guidance Note makes a clear distinction between audit at Branch level
and Head office level and elaborates on general considerations in audit of
Banks at Head Office/Branch level and special consideration in the case of
audit of Branches.
The Guidance Note consists of 29 chapters (besides a number of
appendices), divided into four parts:
Part I deals with general considerations in audit of banks and applies
to audit at both head office level and branch level.
Part II deals with special considerations in the case of audit of
branches.
Part III deals with audit at head office and zonal/regional office level.
Part IV deal with special-purpose reports and certificates to be
issued by auditors of head office or branches of banks.
While every attempt has been made to cover the latest circular issued by
Reserve Bank of India on the subject, it is advisable for` the members in the
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Guidance Note on Audit of Banks (Revised 2019)
ever changing scenario to keep a constant watch on the latest developments
in the Banking sector and familiarize themselves on the update.
I am confident that the members will find this Guidance Note user friendly
and a good companion on the subject.
I take this opportunity to express my sincere thanks to Shri M.M. Khanna,
Past Council Member and past/present members of the Auditing Practices
Committee for their valuable contribution in the preparation of the Guidance
Note.
I would like to record my sincere appreciation to the faculty who assisted the
Committee in preparation of this Guidance Note. I also wish to thank Shri
Vijay Kapur, Secretary, Auditing Practices Committee and his team whose
untiring efforts made it possible for the Committee to bring out this Guidance
Note in good time.
Hyderabad (S. Gopalakrishnan)
March 20, 2001 Chairman
Auditing Practices Committee
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Foreword and Preface of Past Years
Foreword to First Edition
I am glad to note that the Auditing Practices Committee of the Council of the
Institute is bringing out this Guidance Note on Audit of Banks.
Banking is a dynamic activity which has constantly been undergoing a change.
In recent years, there has been a remarkable change in the nature, volume and
spread of transactions of banks. Apart from this, the non-traditional functions of
banks, e.g., foreign exchange activities, merchant banking, portfolio
management, investment, etc., have acquired considerable importance during
this period. Another significant development from the auditors' view point is the
issuance, by the Reserve Bank of India, of detailed guidelines regarding income
recognition, asset classification, provisioning and other related matters. Yet
another development which affects the work of bank auditors is the revision of
formats of financial statements of banks as also of the formats of long form audit
reports. These developments made it imperative for the Institute to revise its
existing publications dealing with audit of banks. I am glad that the Auditing
Practices Committee took up the work of revision on a priority basis and
completed this task in a short period. The draft prepared by the Committee was
considered by the Council at its meeting held in September, 1994 and approved
for publication.
The members would recall that during the first half of 1994, a series of seminars
on the subject of `Bank of Audit' was organised at all major places throughout the
country. For this purpose, the Institute had brought out a uniform background
material. The present Guidance Note draws heavily on the background material,
supplemented by the large number of suggestions made during the course of the
seminars. The Guidance Note, thus, reflects the collective thinking of the
profession on the subject.
It is noteworthy that the earlier edition of this publication on `Audit on Banks' was
in the form of a `Study'. However, considering the importance of the banking
sector in the economy, it has been decided to bring out the present edition in the
form of a Guidance Note. As the members are aware, Guidance Notes are
recommendatory in nature. Accordingly, while carrying out the statutory audit of
a bank or a branch of a bank, a member should ordinarily follow the
recommendations made in this Guidance Note except where he is satisfied that
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Guidance Note on Audit of Banks (Revised 2019)
in the circumstances of the case, it may not be necessary to do so.
In the fast changing economic scenario of the country, the banking sector is likely
to witness many more changes in the years to come. I am sure, the Auditing
Practices Committee will strive to keep this publication up-to-date by revising it
periodically. However, the process of revision, by its very nature, takes time.
Therefore, I would strongly urge upon the members to keep a constant watch on
the developments in the banking sector specially insofar as they affect their work
and adapt their audit procedures and techniques in response to the changes in
the environment.
I have great pleasure in acknowledging the efforts and the contribution made by
the Chairman of the Auditing Practices Committee, Mr. Dipankar Chatterji. I
profoundly thank members of the Auditing Practices Committee and of the
Council for their valuable suggestions. On behalf of the Council, I would like to
record the sincere appreciation to the faculty of the Technical Directorate
especially to Dr. Kamal Gupta, Technical Director and Mr. Ashok Arora, Deputy
Director, for their utmost dedication and technical input in bringing out this
publication.
I am sure, the members would find the guidance contained in this publication
useful in conducting the audit of banks and their branches.
New Delhi B.P. Rao
November 22, 1994 President
462
Foreword and Preface of Past Years
Preface to the First Edition
The Auditing Practices Committee has pleasure in placing before the members this
Guidance Note on Audit of Banks. The Guidance Note is a thoroughly revised,
updated and enlarged edition of the two existing publications titled `Study on Audit
of Banks' and `Guidance Note on Long Form Audit Reports in case of Public Sector
Banks'.
The need for bringing out this revised edition arose because of a number of
significant developments in the banking sector which have affected the work of the
auditors in recent years. One of the most significant developments is the issuance
of guidelines for income recognition, asset classification, provisioning and other
related matters by the Reserve Bank of India. The guidelines lay down objective
parameters for determining the quantum of provision required in respect of
advances. Similarly, with the issuance of guidelines for valuation of investments, a
considerable degree of uniformity has been brought about in the manner in which
investments are accounted for and valued by banks.
The formats of financial statements of banks have been recently modified, thereby
bringing about a greater degree of transparency therein. The Reserve Bank of
India has similarly revised the formats of long form audit reports and also extended
the requirement for obtaining such reports to private banks and foreign banks.
The changes in the nature and volume of activities of banks also affect the work of
the auditors. In particular, the treasury functions of banks such as investments,
foreign exchange, etc., have assumed considerable significance in the last few
years. The portfolio management services rendered by banks have also been a
subject matter of considerable interest during the last couple of years.
This revised edition seeks to respond to the above, as well as several other,
developments that have taken place since the publication of the last editions of the
aforesaid two publications. I would like to particularly draw the attention of the
members to the chapter on Audit Objectives and Approach to audit of banks in the
present-day context. I would also like to make a special mention of chapters
dealing with investments and advances with have been thoroughly revised in the
context of the relevant guidelines issued by the Reserve Bank of India.
Apart from a thorough revision of the existing chapters, several new chapters have
also been added to provide guidance on areas which have gained considerably in
significance during the last few years. These chapters deal with the problem of
arrears in inter-branch accounts, examination of foreign exchange transactions,
application of analytical procedures by the auditors, and consolidation of accounts of
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Guidance Note on Audit of Banks (Revised 2019)
branches. A separate chapter deals with the role of the statutory auditors of banks in
relation to portfolio management services. Similarly, a chapter has been added to
provide guidance on the requirement of the Reserve Bank of India that the statutory
auditors of a bank give a separate report on compliance with the SLR requirements.
The ten appendices to the Guidance Note contain useful reference material for the
auditors. These include the formats of financial statements of banks, revised
formats of audit reports in case of nationalised banks and banking companies,
formats of long form audit reports and the various guidelines issued by the Reserve
Bank of India regarding securities transactions of banks, valuation of investments,
income recognition, asset classification, provisioning and other related matters.
An important aspect to which I would like to invite the attention of the members in
the new nomenclature of this publication. As would be observed, this publication is
in the form of a Guidance Note while the earlier publication on Audit of Banks was
in the form of a `Study'. The decision to bring out this edition in the form of a
Guidance Note has been taken by the Council in the context of the increasing
importance of the banking sector in the economy.
I must acknowledge the very hard work put in by the members of the Auditing
Practices Committee, members of the Study Group formed in Calcutta for
preparing the background material for Seminars on Bank Audit and also Mr. T.
Neogi, F.C.A., Mr S.V. Zaregaonkar, F.C.A., and Mr K.Kannan, F.C.A. who gave
their unstinted time and guidance. The Technical Directorate made an
extraordinary effort to bring out this publication. Special mention must be made of
Mr. Ashok Arora, Deputy Director. Only shortage of space prevents me from
special mention of many others who have given their invaluable help.
The changes in the banking sector are taking place at a rapid pace. In this edition
of the Guidance Note, an attempt has been made to capture the relevant
developments till September 15, 1994. It is, however, appreciated that as the
future unfolds itself, many of the aspects dealt with in the Guidance Note may need
revision. It will be the endeavour of the Auditing Practices Committee to update
this publication on a regular basis. In this task, I invite suggestions from members
as to how the utility of this publication can be enhanced.
I hope the members will find the guidance provided in this publication useful while
conducting statutory audit of banks and their branches.
Calcutta Dipankar Chatterji
November 21, 1994 Chairman
Auditing Practices Committee
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1
Knowledge of the Banking
Industry
Guidance Note on Audit of Banks (Revised 2019)
1
Banking in India
A. An Overview of Banking Institutions in India
01. The banking industry is the pivot of any economy and its financial system.
Banks are one of the foremost agents of financial intermediation in an economy
like India and, therefore, development of a strong and resilient banking system is
of utmost importance. The banking institutions in the country are working in a
competitive environment and their regulatory framework is aligned with the
international best practices. Thus, financial deepening has taken place in India
and continues to be in progress with a focus on orderly conditions in financial
markets while sustaining the growth momentum.
02. As per Section 5(b) of the Banking Regulation Act 1949, "banking" means the
accepting, for the purpose of lending or investment, of deposits of money from
the public, repayable on demand or otherwise, and withdrawal by cheque, draft,
or otherwise. Further, as per Section 5(c) of the said Act, "banking company"
means any company which transacts the business of banking and by way of
Explanation, states that `any company which is engaged in the manufacture of
goods or carries on any trade and which accepts deposits of money from the
public merely for the purpose of financing its business such as manufacturer or
trader shall not be deemed to transact the business of banking within the
meaning of this clause'.
03. Further, section 6 of the said Act lists down the forms of business in which
banking companies may engage. The text of the section is reproduced in
Appendix I of the Guidance Note.
B. Presently, the following types of banking institutions
prevail in India:
(a) Commercial Banks;
(b) Regional Rural Banks;
(c) Co-operative Banks;
(d) Development Banks (more commonly known as `Term-Lending Institutions');
(e) Foreign Banks;
(f) Payment Banks;
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Banking in India
(g) Small Finance Banks; and
(h) EXIM Banks.
(a) Commercial Banks
04. Commercial banks operating in India can be divided into two categories
based on their ownershippublic sector banks and private sector banks.
However, irrespective of the pattern of ownership, all commercial banks in India
function under the overall supervision and control of the RBI.
05. Public sector banks comprise the State Bank of India, IDBI Bank Ltd. and the
nationalized banks. While the majority stake in the Share Capital of all Public
Sector Banks is with the Government of India, there are private
individual/institutional shareholders also. The majority stake in the share capital
of associate banks of State Bank of India has been subscribed to by the parent
i.e. State Bank of India. On 10th August, 2017 Lok Sabha had passed State
Banks(Repeal and Amendment) Bill 2017 to merge five Associate with parent
State Bank of India.
06. The ownership of private sector banks is with institutional shareholders,
private individuals and bodies corporate. Private Sector Banks are of the
following types:
(a) Indian scheduled commercial banks other than public sector banks. These
include the `old' private banks which were in existence before the guidelines
for floating new private banks were issued in 1993, the `new' generation
private banks, and Bandhan Bank and IDFC Bank that were granted
licenses by RBI in March 2014. (The term `scheduled commercial banks'
refers to commercial banks which are included in the Second Schedule to
the Reserve Bank of India Act, 1934.) Under Section 2(e) of the RBI Act, a
scheduled bank is conferred two main privileges (a) availing of refinance
from RBI and (b) permission to participate in the call/notice money market.
It may be noted that not all scheduled banks are commercial banks; some
co-operative banks are also scheduled banks. Commonly known as
`banking companies', these banks are `companies' registered under the
Companies Act, 1956 (now the Companies Act, 2013), or an earlier Indian
Companies Act.
(b) Non-scheduled banks.
(c) Indian branches of banks incorporated outside India, commonly referred to
as `foreign banks'.
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Guidance Note on Audit of Banks (Revised 2019)
07. Some of the banks have set up subsidiaries wholly-owned or partly owned
to operate in some specialized spheres of activity such as merchant banking,
funds management, housing finance, primary dealership, pension fund
management, insurance business, stock broking, credit card activity, factoring,
etc. These subsidiaries do not carry on all the principal functions of a commercial
bank. Modern commercial banks function as universal banks. According to the
Financial Times, universal banks are financial service conglomerates that
combine retail, wholesale and investment banking services under one roof and
reaping synergies between them which is made possible from economies of
scale in information technology and access to capital to serve companies and
retail customers around the world.
Branch Network of Commercial Banks
08. Commercial banks are arguably the most important constituent of the
banking system in India. To carry out their functions effectively, these banks have
established a large network of branches in India. Based on their location, these
`domestic' branches are commonly classified into rural branches, semi-urban
branches, urban branches and metro branches. Apart from these domestic
branches, some banks have also established offices abroad.
09 The foreign offices of banks are generally of the following types:
Full-fledged branches Such branches transact all kinds of banking
business.
Off-shore banking units Such branches transact foreign exchange
business of any kind except domestic banking business with the residents/
corporations, etc., domiciled in the country concerned.
Branches in International Financial Services Centres - Indian banks viz.
banks in the public sector and the private sector authorized to deal in foreign
exchange will be eligible to set up IFSC Banking Units (IBUs). Minimum
capital of US$ 20 million or equivalent is required for opening of a branch at
IBU. Operations from IBU are governed by operational guidelines issued by
RBI time to time.
Subsidiaries The laws in some countries do not permit foreign banks to
open their branches in those countries. Therefore, Indian banks have to set
up wholly or partly-owned subsidiaries in such countries. Further, for
operational reasons, commercial banks may prefer to operate through
subsidiaries, if permitted, instead of opening branches.
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Banking in India
Representative offices Such offices do not transact any banking business.
The objective behind setting up of such offices is to maintain close liaison
with the important bodies there to promote mutual business interests.
10. Generally, branches of banks conduct a variety of banking business under
one roof. The trend of creating `thrust-based' or `focus-based' branches/ market
segmentation has led to setting up of branches by banks exclusively for a
specified segment of their clients. Presently, such specialized branches are
generally of the following types (nomenclature may, however, vary from bank to
bank):
Personal Banking branches, catering to the needs of individual customers
only.
Commercial or Industrial Finance branches, catering to the needs of
industries in the small, medium and/or large sectors.
Recovery branches, which deal only with the recovery aspects of
nonperforming advances which were originally granted at other branches of
the bank.
Housing Finance branches which deal only with housing loan proposals
from individuals, and in some cases, also from the developers of housing
units.
Agricultural Finance branches, catering to the needs of the agriculture sector
only.
Service branches, handling only the local clearing instruments received from
outstation branches or from other local branches of the bank for collection.
Commodity specific branches, which handle the accounts, predominantly
borrowal accounts, of the units belonging to a particular industry, e.g.,
leather, diamonds.
Overseas or International Banking or Foreign Exchange branches catering
to the banking needs of those enterprises which are engaged in imports
into/exports from India.
Corporate Banking/SME/SSI branches, catering exclusively to the
requirements of the large, medium and small scale industrial units
respectively.
NRI (Non-Resident Indian) branches, catering exclusively to the banking
needs of NRIs.
Securities / treasury branches, dealing only with the securities portfolio of the
bank.
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Guidance Note on Audit of Banks (Revised 2019)
Commercial Banks: Services & Products
11. Commercial banks are by far the most widespread banking institutions in
India. Typically, commercial banks provide the following major products and
services:
(a) Acceptance of Deposits: Acceptance of deposits from the public is one of
the most important functions of a commercial bank. Commercial banks
accept deposits in various forms: term deposits, savings bank deposits,
current account deposits, etc.
(b) Granting of Advances: This again is an important function of commercial
banks. Advances granted by commercial banks take various forms such as
cash credit, overdrafts, purchase or discounting of bills, term loans, etc.
Apart from granting traditional facilities, banks are also providing facilities
like External Commercial Borrowings (ECB) on behalf of bank/borrower,
securitization of receivables, etc.
(c) Remittances: Remittances involve transfer of funds from one place to
another. Common modes of remittance of funds are drafts, telegraphic/mail
transfers (TT/MT) and Electronic Funds Transfer (EFT). In the case of
telegraphic/mail transfer, no instrument is handed over to the applicant; the
transmission of the instrument is the responsibility of the remitting branch.
Generally, the payee of both the TT and the MT is an account holder of the
paying branch. In the case of Electronic Funds Transfer (EFT), as the name
suggests, the funds are transferred electronically between two banks. The
common modes of EFT are Real Time Gross Settlement (RTGS), which
can be used for remittance of an amount within a prescribed limit of Rs. 2
Lakhs and above and National Electronic Funds Transfer (NEFT), which
can be used for transfer of any amount. Another form of EFT is Immediate
Payment Service (IMPS).
Pay Orders/Demand Drafts issued against amounts received by a bank,
comprise instruments, the liability in respect whereof is discharged at the
same or another branch of the bank or other banks.
(d) Collections: The customers can lodge various instruments such as
cheques, drafts, pay orders, travellers cheques, dividend and interest
warrants, tax refund orders, etc., drawn in their favour and the trade bills
drawn by them on their buyers with their bank for collection of the amount
from the drawee (the bank or the drawee of the bill). They can also lodge
their term deposit receipts and other similar instruments with the bank for
collection of the proceeds from the bank with which the term deposit, etc., is
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Banking in India
maintained. Banks also collect instruments issued by post offices, like
national savings certificates, postal orders, etc.
The instruments mentioned above may be payable locally or at outside
centres.
Clearing house (CH) settles the inter-bank transactions among the local
participating member banks. Generally, post offices are also members of
the house. There may be separate clearing for CTS (Cheque Truncation
System) and non-CTS instruments. The clearing house is managed by the
RBI, State Bank of India or any other bank nominated by RBI. In case a
bank has many branches within the area of a clearing house, it nominates
one branch to act as the `nodal' branch of that bank for all the branches
within that area. This nodal branch collects instruments to be presented by
other branches also. The accounts of all member banks are maintained by
the clearing house. All member banks have to pay an agreed sum to the
bank managing the clearing house for meeting the cost of infrastructure and
services it provides to them.
In addition to the regular clearing houses as discussed above, Electronic
Clearing Service (ECS) is also in vogue. ECS takes two forms: ECS credit
or ECS debit.
In the case of ECS credit, there is a single receiver of funds from a
large number of customers, e.g., public utilities, mutual funds, etc.
The beneficiary (i.e., the receiver of funds) obtains mandate from its
customers to withdraw funds from their specified bank accounts on a
particular date. These customers may have accounts with different
banks in the same clearing house area. Before the specified date, the
beneficiary compiles bank-branch-wise particulars of the accounts to
be debited and furnishes the details to its own bank which, in turn,
arranges to provide them to the banks concerned, through the clearing
house, for verification of particulars of accounts. Any discrepancies
are rectified and, on the specified date, the accounts are debited by
the respective banks and the beneficiary gets the credit.
In the case of ECS debit, there is a single account to be debited
against which a number of accounts with a number of banks in the
same clearing house area are credited. This system is useful for
distribution of dividend/interest, payment of salaries by large units, etc.
Roll-out of Speed Clearing is one of the many initiatives taken by RBI
for improving efficiency in the time frame for and process of collection
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Guidance Note on Audit of Banks (Revised 2019)
of cheques. It implemented Cheque Truncation System (CTS) in
phase wise manner starting from February 1, 2008. In CTS, the
presenting bank (or its branch) captures the data (on the MICR band)
and the images of a cheque using their Capture System (comprising
of a scanner, core banking or other application). The collecting bank
(Presenting Bank) sends the data and captured images duly signed
and encrypted to the central processing location (Clearing House) for
onward transmission to the paying bank (destination or drawee bank).
For the purpose of participation, the presenting and drawee banks are
provided with an interface / gateway called the Clearing House
Interface (CHI) that enables them to connect and transmit data and
images in a secure and safe manner to the Clearing House (CH). The
Clearing House processes the data, arrives at the settlement figure
and routes the images and requisite data to the drawee banks. This is
called the presentation clearing. The drawee banks through their CHIs
receive the images and data from the Clearing House for payment
processing. The drawee CHIs also generates the return file for unpaid
instruments, if any. The return file / data sent by the drawee banks are
processed by the Clearing House in the return clearing session in the
same way as presentation clearing and return data is provided to the
presenting banks for processing. The clearing cycle is treated as
complete once the presentation clearing and the associated return
clearing sessions are successfully processed. The entire essence of
CTS technology lies in the use of images of cheques (instead of the
physical cheques) for payment processing.
(e) Receipt of Foreign Contribution on behalf of the registered persons/
organization: Scheduled Banks also handle the foreign contribution receipt
on behalf of the registered persons/ organization as per the Foreign
Contribution (Regulation) Act, 2010. Banks receiving foreign contribution
need to ensure that the concerned persons/organization are registered with
the Central Government or has obtained the prior permission to receive
such foreign contribution if required by law, and that no branch other than
the specified branch accepts `foreign contribution'.
(f) Cash Management Product: It is a derivative of the collection business. This
facility is provided for expeditious transfer of funds collected by a customer
at the specified centres in the country to his central account with the use of
computers/satellites. It is particularly useful for large units which have their
sales/collection network in a very wide geographical area. Only selected
branches of a bank may handle the business due to the infrastructural
requirements.
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Banking in India
(g) Issuance of Letters of Credit and Guarantees: These are two important
services rendered by banks to customers engaged in business, industrial
and commercial activities. A letter of credit (LC) is an undertaking by a bank
to the payee (the supplier of goods and/or services) to pay to him, on behalf
of the applicant (the buyer) any amount up to the limit specified in the LC,
provided the terms and conditions mentioned in the LC are complied with.
The guarantees are required by the customers of banks for submission to
the buyers of their goods/services to guarantee the performance of
contractual obligations undertaken by them or satisfactory performance of
goods supplied by them, or for submission to certain departments like
excise and customs, electricity boards, or to suppliers of goods, etc., in lieu
of the stipulated security deposits.
(h) Merchant Banking Business: Many bank branches act as collection agents
to issue business for merchant bankers. The customer and the bank have
to agree to the modalities of the scheme, like names of branches authorized
as collecting branches, the procedure for retaining the subscription and its
remittance periodically, the documents required by the customer from the
collecting branches, etc.
(i) Credit Cards: The processing of applications for issuance of credit cards is
usually entrusted to a separate division at the Central/Head office of a bank.
The dues against credit cards are collected by specified branches,
preferably by direct debit to accounts of the credit card holders. Many of
them also act as `cash points' to provide cash to the cardholder on demand
up to the specified limits. Most credit cards issued by banks are linked to
one of the international credit card networks like VISA, Master or Amex.
(j) Technology-based Services: Banks also provide internet banking services
and phone banking services. The fast changing technology has
synchronized the banking facility in such a way that the customer need not
come physically to the bank for any transactions. The banks are now
providing the facility for payment of utility bills, railway reservation, tax
deposition through ATM/internet and also provide recharge facility to mobile
phone users.
(k) Dividend/Interest/Refund Warrants/redemptions: Many entities require
facilities for distribution of funds to their shareholders and others. Direct
electronic transmission of funds is made to the accounts of the recipients. In
other cases, warrants are issued in favour of shareholders/others, including
those payable at designated branches of specified banks. The aggregate
amount of the liability to be discharged by the constituent, including
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Guidance Note on Audit of Banks (Revised 2019)
warrants or other instruments issued, is funded to the bank by such
constituent.
(l) Safe-keeping Services: Banks provide services for safe keeping/custody of
the scrips and valuables of customers in their vaults. Appropriate records
are maintained in evidence of receipts/delivery and evidence of holdings is
verified from time to time.
(m) Lockers: This facility is provided to customers for safe-keeping of their
valuables, etc., in lockers. The branch has no knowledge of the contents of
the locker. Only the account holder (the hirer) or his bona fide
representative, duly authorized by the account holder, can operate on the
locker. Each access to the locker is properly recorded in the appropriate
registers.
(n) Handling Government Business: Banks act as agents of RBI for receipts
and payments on behalf of various government departments. There are
authorized branches to handle the specified type of work. Normally, a
specified branch acts as a nodal branch for a particular segment of the
government business within a given geographical area. The responsibility of
the nodal branch includes obtaining details of transactions from the linked
branches and to reconcile their accounts inter se and with the department
concerned. Banks are remunerated by Government for handling this
business by way of service charges which are usually as agreed or a stated
percentage of the collections or payments, as the case may be.
(o) Depository Participant (DP) Services: The depository system is meant to
facilitate quick transfer of stock market securities in a dematerialized form
from the seller to the buyer by using satellite connectivity. The depository
scheme is operated presently by two depositories Central Depository
Services Limited (CDSL) and National Securities Depository Limited
(NSDL). Depository participants, i.e., bank branches providing depository
services are in effect agents of the depository concerned. Each participating
branch has to get itself registered with a depository. The customer has to
open an account with the branch which provides the DP services. This
account is credit by the branch with the securities sold by the account
holder and debit with the purchases.
(p) Automated Teller Machines (ATMs) and Cash Deposits Machines /
Recyclers: Operations on ATMs are through a card which contains
information about the cardholder in a magnetic form. The cardholder has to
also use the password (also known as Personal Identification Number, i.e.
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Banking in India
PIN) to carry out any transaction through ATM. Earlier, ATMs were used
merely as cash dispensing machines but now-a-days, other services like
issue of drafts, deposit of cash and instruments, balance enquiry, etc., are
also being provided by many banks. ATMs may be on-site (i.e., housed in
the branch premises) or off-site. The transactions routed by the customers
through the ATMs may be entered into the books of account of the branch
either on-line (i.e., simultaneously with the transactions) or off-line.
However, on an off-line mode, the proper recording of transactions needs to
be ensured. RBI has permitted banks to install Cash Deposit Machines
(CDM) with specific guidelines w.r.t. security arrangements, handling of
suspect / counterfeit notes and availability of audit trail. The recycler
machines accept as well as dispense cash from the same machine.
(q) Exchange of Notes: Following the `clean note policy' RBI provides the
facility of exchange of soiled/mutilated /unusable notes.
(r) Debit Cards: Debit cards are issued by the bank to its account holders to
provide facility of access to cash at ATMs/ purchase of goods and services
there against, where the debit to the bank account of the holder is
simultaneous.
(s) Auto Sweep facility in saving accounts: Banks offer auto sweep facility in
saving accounts of their customers where the balances in excess of those
stipulated limit, automatically get transferred to term deposit accounts to
avail of a higher rate of interest and also automatically get reversed to
replenish any shortfall in such stipulated limits.
(t) Derivatives: Financial derivatives are gaining importance in India. Banks are
offering derivative options against exchange fluctuation losses.
(u) Prepaid Payment Instruments in India1: Pre-paid payment instruments are
payment instruments that facilitate purchase of goods and services against
the value stored on such instruments. The value stored on such instruments
represents the value paid for by the holders by cash, by debit to a bank
account, or by credit card. The pre-paid instruments can be issued as smart
cards, magnetic stripe cards, internet accounts, internet wallets, mobile
accounts, mobile wallets, paper vouchers and any such instrument which
can be used to access the pre-paid amount (collectively called Prepaid
Payment Instruments or PPI hereafter). The pre-paid payment instruments
1
RBI vide its circular no. DPSS.CO.PD.PPI.No.01/02.14.006/2016-17 dated July 1, 2016 on
"Policy Guidelines for issuance and operation of Prepaid Payment Instruments in India" provides
the broad guidelines on this subject.
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Guidance Note on Audit of Banks (Revised 2019)
that can be issued in the country are classified under three categories viz.
(i) Closed system PPI (ii) Semi-closed system PPI and (iii) Open system
PPI. Issuer may be the persons operating the payment systems issuing
prepaid payment instruments to individuals/organizations.
The money collected is retained by these persons and they make payment
to the merchants who are part of the acceptance arrangement directly, or
through a settlement arrangement.
Banks who comply with the eligibility criteria are permitted to issue all
categories of pre-paid payment instruments. However, only those banks
which have been permitted to provide Mobile Banking Transactions by the
Reserve Bank of India shall be permitted to launch mobile based pre-paid
payment instruments (mobile wallets & mobile accounts).Banks are also
permitted to issue prepaid instruments to principal agents approved under
the Money Transfer Service Scheme (MTSS) of the Reserve Bank of India
or directly to the beneficiary under the scheme for loading of the funds from
inward remittances.
Further, the regulatory guidelines require that other non-bank persons
issuing PPI need to maintain their outstanding balance in an escrow
account with any scheduled commercial bank subject to the following
conditions:
The amount so maintained be used only for making payments to the
participating merchant establishments.
No interest is payable by the bank on such balances with an exception
that the entity can enter into an agreement with the bank where escrow
account is maintained, to transfer "core portion" of the amount, in the
escrow account to a separate account on which interest is payable,
subject to the certain conditions.
A quarterly certificate from the auditors be submitted certifying that the
entity has been maintaining adequate balance in the account to cover
the outstanding volume of payment instruments issued.
The entity shall also submit an annual certificate, as above, coinciding
with the accounting year of the entity to the Reserve Bank of India.
Adequate records indicating the daily position of the value of
instruments outstanding vis-à-vis balances maintained with the banks
in the escrow accounts be made available for scrutiny to the Reserve
Bank or the bank where the account is maintained on demand.
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Banking in India
Further, as per RBI/DPSS/2017-18/58 Master Direction
DPSS.CO.PD.No.1164/02.14.006/2017-18 dated October 11,
2017(updated as on December 29, 2017) "Issuance and operation of
Prepaid Payment Instruments in India Auditor Certificate on the balances
in Escrow account" requires a quarterly certificate on the balances held in
the Escrow account in accordance with the above Guidelines, from an
auditor within a fortnight from the end of the quarter to which it pertains.
Para-banking Activities
12. Banks also undertake certain eligible financial services or para banking
activities either departmentally or by setting up subsidiaries. However, banks can
set up subsidiary for undertaking such activities only with prior approval of RBI.
Some of those activities are listed below:
(i) Equipment Leasing, Hire Purchase and Factoring Services: Banks also
undertake equipment leasing, hire purchase and factoring services as
departmental activities.
(ii) Investment in Venture Capital Funds (VCFs): Bank should obtain prior
approval of RBI for making strategic investment in venture capital funds i.e.
investment equivalent to more than 10% of the equity/unit.
(iii) Mutual fund business: Banks are not permitted to directly undertake mutual
fund business but sponsor mutual funds, subject to the RBI guidelines in
this regard. Banks normally refer clients to these mutual funds and earn a
commission2 in return.
Banks may enter into agreements with mutual funds for marketing the
mutual fund units subject to the terms and conditions specified in the RBI
Master Circular RBI/2015-16/30 BR.No.FSD.BC.19/24.01.001/2015-16
dated July 1, 2015 on "Para Banking Activities".
(iv) Money Market Mutual Funds (MMMFs): Banks can also sponsor MMMFs
business subject to the prior approval of the RBI. The MMMFs are,
however, subject to regulation by the Securities and Exchange Board of
2
Keeping in view the need for transparency in the interest of the customers to whom the products
are being marketed / referred, the banks are advised to disclose to the customers, details of all the
commissions / other fees (in any form) received, if any, from the various mutual fund / insurance /
other financial services companies for marketing / referring their products. This disclosure would be
required even in cases where the bank is marketing/ distributing/ referring products of only one
mutual fund/ insurance companies, etc.
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India (SEBI). Banks also, at time, provide cheque-writing facilities for
MMMFs subject to the RBI guidelines in this regard.
(v) Entry of banks into insurance business: Banks intending to set up insurance
joint ventures with equity contribution on risk participation basis or making
investments in the insurance companies for providing infrastructure and
services support should obtain prior approval of Reserve Bank of India
before engaging in such business. However, insurance business will not be
permitted to be undertaken departmentally by the banks.
(vi) Primary Dealership (PD) Business Banks can undertake primary
dealership business subject to the approval of the RBI and after satisfying
certain eligibility criteria prescribed by the RBI:
A) Banks, which do not at present, have a partly or wholly owned
subsidiary and fulfill the following criteria:
a. Minimum Net Owned Funds of Rs. 1,000 crore.
b. Minimum CRAR of 9%.
c. Net NPAs of less than 3% and a profit making record for the last
three years.
B) Indian banks which are undertaking PD business through a partly or
wholly owned subsidiary and wish to undertake PD business
departmentally by merging/taking over PD business from their
partly/wholly owned subsidiary subject to fulfilling the criteria
mentioned in A (a) to (c) above.
C) Foreign banks operating in India who wish to undertake PD business
departmentally by merging the PD business being undertaken by
group companies subject to fulfilment of criteria at A (a) to (c).
(vii) Pension Funds Management: Banks have been permitted to undertake
Pension Funds Management (PFM) through their subsidiaries set up for the
purpose subject to their satisfying the eligibility criteria prescribed by
Pension Fund Regulatory and Development Authority (PFRDA) for Pension
Fund Managers. PFM cannot be undertaken departmentally. Banks
intending to undertake pension funds management should follow the
guidelines set out in the RBI Master Circular No.DBR.No. FSD.BC. 19/
24.01.001/ 2015-16 dated July 1, 2015 on "Para Banking Activities".
(viii) Portfolio Management Services (PMS): The general powers vested in
banks to operate Portfolio Management Services and similar schemes have
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been withdrawn vide RBI circular DBOD.No.BC.73/27.07.001/94-95 dated
June 7, 1994 on Acceptance of Deposits/Funds under Portfolio
Management Scheme. No bank therefore is permitted to, restart or
introduce any new PMS or similar scheme in future without obtaining
specific prior approval of the RBI. However, bank-sponsored NBFCs are
allowed to offer discretionary PMS to their clients, on a case-to-case basis.
The banks operating PMS or similar scheme with specific prior approval of
RBI have to strictly observe the conditions given in RBI Master Circular No.
DBR.No.FSD.BC.19/24.01.001/2015-16 dated July 1, 2015 on "Para
Banking Activities".
(ix) Referral Services: Banks can offer referral services to their customers for
financial products subject to the following conditions:
a) The bank/third party issuers of the financial products should strictly
adhere to the KYC/AML guidelines in respect of the customers who are
being referred to the third party issuers of the products.
b) The bank should ensure that the selection of third party issuers of the
financial products is done in such a manner so as to take care of the
reputational risks to which the bank may be exposed in dealing with the
third party issuers of the products.
c) The bank should make it explicitly clear upfront to the customer that it is
purely a referral service and strictly on a non-risk participation basis.
d) The third party issuers should adhere to the relevant regulatory
guidelines applicable to them.
e) While offering referral services, the bank should strictly adhere to the
relevant RBI guidelines.
(x) Underwriting of Corporate Shares and Debentures: Banks can undertake
underwriting of corporate shares and debentures within the ceiling
prescribed for the bank's exposure to capital markets and subject to the
provisions contained in the Section 19(2) and 19(3) of the Banking
Regulation Act, 1949. The guidelines contained in the SEBI (Underwriters)
Rules and Regulations, 1993 and those issued from time to time are also to
be complied with. Moreover, banks should not underwrite issue of
Commercial Paper by any Company or Primary Dealer and not extend
Revolving Underwriting Facility to short term Floating Rate Notes/Bonds or
debentures issued by corporate entities. However, with effect from April 16,
2008, banks may exclude their own underwriting commitments, as also the
underwriting commitments of their subsidiaries, through the book running
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process for the purpose of arriving at the capital market exposure both on a
solo and consolidated basis.
(xi) Underwriting of bonds of Public Sector Undertakings: Banks can play a
supportive role in relation to issue of bonds by Public Sector Undertakings
(PSUs) by underwriting a part of these issues. They may also subscribe
outright initially but sell them later to the public with the aid of their wide
branch network. It should, however, be ensured that the increase in the
holdings of public sector bonds by banks arising out of their underwriting or
subscription is kept within reasonable limits. While undertaking the
underwriting of bonds of PSUs, banks should formulate their own internal
guidelines as approved by their Boards of Directors on investments in and
underwriting of PSU bonds, including norms to ensure that excessive
investment in any single PSU is avoided and that due attention is given to
the maturity structure of such investments.
(xii) Retailing of Government Securities: Banks are permitted to undertake the
business of retailing of Government securities with non-bank clients subject
to the following conditions:
a) Banks are free to buy and sell Government Securities on an outright
basis at prevailing market prices without any restriction on the period
between sale and purchase.
b) Banks shall not undertake ready forward transactions in Government
Securities with non-bank clients.
c) The retailing of Government Securities should be on the basis of
ongoing market rates / yields emerging out of secondary market
transactions.
d) No sale of Government Securities should be effected by banks unless
they hold the securities in their portfolio either in the form of physical
scrips or in the Subsidiary General Ledger (SGL) Account maintained
with the Reserve Bank of India.
e) Immediately on sale, the corresponding amount should be deducted
by the bank from its investment account and also from its (Statutory
Liquidity Ratio (SLR) assets.
f) Banks should put in place adequate internal control checks/
mechanism in this regard.
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g) These transactions should be subjected to concurrent audit as per
RBI's extant instructions and should also be looked into by the
auditors at the time of bank's statutory audit.
(xiii) Sponsors to Infrastructure Debt Funds (IDF) - In order to accelerate and
enhance the flow of long term funds to infrastructure projects for
undertaking the Government's ambitious programme of infrastructure
development, scheduled commercial banks have been allowed to act as
sponsors to Infrastructure Debt Funds (IDFs). IDFs can be set up either as
Mutual Funds (MFs) or as Non-Banking Finance Companies (NBFCs).
While IDF-MFs are regulated by SEBI, IDF-NBFCs are regulated by RBI.
Banks can sponsor IDF-MFs and IDF-NBFCs with prior approval from RBI
subject to the conditions given in the RBI Master Circular No.
DBR.No.FSD.BC.19/24.01.001/2015-16 dated July 1, 2015 on "Para -
Banking Activities".
(xiv) Membership of currency derivative segment of SEBI approved Stock
Exchanges: Scheduled commercial banks (AD Category I) have been
permitted to become trading / clearing members of the currency derivatives
segment to be set up by the Stock Exchanges recognized by SEBI, subject
to their fulfilling the following prudential requirements:-
a) Minimum net worth of Rs. 500 crores
b) Minimum CRAR of 10%
c) Net NPA not exceeding 3%
d) Net Profit for last 3 years
Banks which fulfill the conditions mentioned above should lay down detailed
guidelines with Board's approval for conduct of this activity and
management of risks. It should be ensured that the bank's position is kept
distinct from the clients' position. In case of supervisory discomfort with the
functioning of a bank, the Reserve Bank may impose restrictions on the
bank regarding the conduct of this business as it deems fit.
The banks which do not meet the above minimum prudential requirements
are permitted to participate in the currency futures market only as clients.
(xv) Partner in Financial Inclusion programme Pradhan Mantri Jan Dhan
Yojna: Pradhan Mantri Jan-Dhan Yojana (PMJDY) which was launched on
28th August 2014 is a National Mission for Financial Inclusion to ensure
access to financial services, namely, Banking/ Savings & Deposit Accounts,
Remittance, Credit, Insurance, Pension in an affordable manner. Bank
Account can be opened in any bank branch or Business Correspondent
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(Bank Mitr) outlet. PMJDY accounts are being opened with Zero balance
and certain other benefits.
(xvi) MUDRA Loans - Micro Units Development and Refinance Agency
(MUDRA) loans are extended by banks, NBFCs, MFIs and other eligible
financial intermediaries as notified by MUDRA Ltd. The Pradhan Mantri
MUDRA Yojana (PMMY) announced by the Hon'ble Prime Minister on 8th
April 2015, envisages providing MUDRA loan, upto Rs. 10 lakh, to income
generating micro enterprises engaged in manufacturing, trading and
services sectors. The overdraft amount of Rs. 5000 sanctioned under
PMJDY has been also classified as MUDRA loans under Prime Minister
MUDRA Yojana (PMMY). The MUDRA loans are extended under different
categories. During the Financial Year 2017-18, 4,81,30,593 Pradhan Mantri
MUDRA Yojana (PMMY) has been sanctioned. The total amount
sanctioned is 2,53,677.10 Crore out of which 2,46,437.40 was disbursed.
According to finance ministry data Mudra Yojana had a gross NPA ratio of
only 4 per cent as of December 2017 - much lower than average 10 per
cent for other loans in the case public sector lenders. However, some of the
experts have calculated the Mudra Yojana NPA figures at over 14,350 crore
in the short span of three years. In Financial year 2018-19, till 10th October
2018 2,08,83,896 MUDRA Loans has been sanctioned amounting to
Rs.110576.98 Crore.
According to finance ministry data Mudra Yojana had a gross NPA ratio of
only 4 per cent as of December 2017 - much lower than average 10 per
cent for other loans in the case public sector lenders. Since almost all the
Mudra Loans are without collaterals and Unsecured, Banks need to monitor
the same carefully to ensure end use of funds and recovery to avoid NPA
classification.
(b) Regional Rural Banks (RRBs)
13. These banks have been established "with a view to developing the rural
economy by providing, for the purpose of development of agriculture, trade,
commerce, industry and other productive activities in the rural areas, credit and
other facilities, particularly to the small and marginal farmers, agricultural
labourers and artisans and small entrepreneurs" (Preamble to the Regional Rural
Banks Act, 1976). While regional rural banks can carry on any business in which
a bank is legally permitted to engage, section 18 of the Regional Rural Banks
Act, 1976, specifically lists the following businesses which such a bank may
undertake:
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(a) the granting of loans and advances, particularly to small and marginal
farmers and agricultural labourers, whether individually or in groups, and to
co-operative societies, including agricultural marketing societies,
agricultural processing societies, co-operative farming societies, primary
agricultural credit societies or farmers' service societies, for agricultural
purposes or agricultural operations or for other purposes connected
therewith;
(b) the granting of loans and advances, particularly to artisans, small
entrepreneurs and persons of small means engaged in trade, commerce or
industry or other productive activities, within the notified area in relation to
the RRB.
14. In order to strengthen and consolidate RRBs, the government in 2005
initiated the process of amalgamation of RRBs in a phased manner.
Consequently, the total number of RRBs has reduced from 196 to 563. Further,
the Government of India has issued a notification dated May 17, 2007 specifying
`Regional Rural Bank' as `bank' for the purpose of the Securitization and
Reconstruction of Financial Assets and Enforcement of Security Interest
(SARFAESI) Act, 2002.
15. In the recent years, in an attempt to strengthen the regional rural banks,
several measures have been taken by the Central Government and the RBI.
These banks are no longer required to confine their lending to the weaker
sections and are permitted to lend to non-target groups also up to specified
limits. They can also undertake various types of business such as issuance of
guarantees, demand drafts, travellers' cheques, etc. Moreover, RRBs are no
longer required to confine their operations only within local limits notified by the
Central Government; they are now permitted, subject to fulfilling service area
obligations, to lend monies outside their service area. In the wake of these
developments, the distinction between commercial banks and RRBs has become
somewhat blurred.
16. Each RRB has a public sector bank as its `sponsor bank'. Capital in each
such bank is contributed by the Central Government, the sponsor bank and the
State Government concerned in proportion of 50, 35 and 15 per cent,
respectively.
17. Apart from subscribing to the share capital of a RRB sponsored by it, the
sponsor bank is also required to train personnel of the RRB as also to provide
managerial and financial assistance to such bank during the first five years of the
3As per the information available from the website of the Reserve Bank of India at the following
URL: http://www.rbi.org.in/scripts/AboutUsDisplay.aspx?pg=RegionalRuralBanks.htm.
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Guidance Note on Audit of Banks (Revised 2019)
latter's functioning (this period can, however, be extended by the Central
Government).
18. Like commercial banks, regional rural banks also function under the overall
supervision and control of the RBI. Some of the regulatory functions of the RBI in
relation to RRBs have been delegated to the National Bank for Agriculture and
Rural Development (NABARD).
(c) Co-operative Banks
19. These are banks in the co-operative sector which cater primarily to the credit
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. Of these, primary co-operative banks operate in
metropolitan cities, urban and semi-urban centres to cater principally to the credit
needs of small industrial units, retail traders, etc. Due to their existence primarily
in urban areas, primary co-operative banks are more commonly known as `Urban
Co-operative Banks' (UCB). Land development banks provide long-term finance
for agriculture and have a two-tier structure State Land Development Banks
and the Primary Land Development Banks, the latter being at District or Block
level. In a few states, however, the structure is unitary where the State Land
Development Bank directly carries out activities through its own branches at
district level.
20. Each co-operative bank operates within a specific geographic jurisdiction as
determined by its bye-laws. Co-operative banks can lend monies only to their
members or to registered societies. The single most important regulatory and
supervisory feature in the co-operative banking sector is the prevalence of dual
control. While incorporation/registration and management-related activities are
regulated in the states by the Registrar of Co-operative Societies or the Central
Registrar of Co-operative Societies (for multi-state co-operative banks), banking
related activities are under the regulatory/supervisory purview of the Reserve
Bank of India or NABARD (in the case of rural co-operatives).
(d) Development Banks
21. Development banks also known as `term-lending institutions' are specialized
financial institutions that provide medium and long-term finance to the industrial,
agricultural, housing, and export-import sectors. As multipurpose financial
institutions, they provide financial assistance to both private and public sectors.
Development banking was started primarily to provide financial assistance to
war-ravaged industries essentially to reconstruct their buildings and equipment
which were destroyed in the war.
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22. In India, development banks are classified into four groups such as Industrial
Development Banks which include Industrial Finance Corporation of India (IFCI)
set up in 1948, Industrial Development Bank of India (IDBI) set up in 1964, and
Small Industries Development Bank of India (SIDBI) set up in 1990, Agricultural
Development Banks which include National Bank for Agriculture & Rural
Development (NABARD) set up in 1982, Export-Import Development Banks
which include Export-Import Bank of India (EXIM Bank) set up in 1982 and
Housing Development Banks which include National Housing Bank (NHB). In
addition, the Industrial Investment Bank of India (IIBI) which was set up in
1991and the MUDRA Bank which was set up in 2015 are also in existence apart
from State Industrial Development Corporations (SIDCs) and State Financial
Corporation (SFC) which function as part of `development banks'.
23. Development Banks came to be established to with the objective of providing
financial assistance to entrepreneurs to establish and expand their businesses
and helping companies to raise money from the capital market. Major functions
of Development Banks include raising capital for the companies, providing loans
and advances, performing underwriting of new issues, providing guarantee for
loans, etc.
24. The major difference between Development Bank and Commercial Bank is
that development Banks's main emphasis lies on development through various
promotional activities while commercial banks are mere credit suppliers.
Similarly, development banks do not accept deposits from public while
commercial banks accept deposits. Further, it is also important to note that
development banks are normally viewed to provide medium and long-term
finance while commercial banks provide short term finance.
25. Two development institutions viz.: ICICI and IDBI have been since converted
in to full-fledged commercial banks whereas IFCI is now categorised as a NBFC,
SIDBI, NHB and EXIM Bank are the existing term lending institutions.
(e) Foreign Banks
26. Foreign banks operate in India through a network of branches and do not
have a separate legal entity existence in India. However, for all practical
purposes, the RBI regulates the functioning of these banks in India, with regards
to scale and nature of business they undertake in India. Foreign banks functions
with a CEO or a Country Head as the highest decision making authority based in
India. This position generally reports to the regional management Board or the
global Board of the bank as the case may be. In comparison to a locally
incorporated bank, the management structure of foreign banks is not very `top'
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Guidance Note on Audit of Banks (Revised 2019)
concentrated, i.e., the various boards and committees stipulated by RBI for
Indian banks are not mandatory.
27. Foreign banks operate with limited branch network in the country and in a
structure wherein most of their operations are centralized. Bank branches
operate as customer relationship windows and do not record substantial financial
statements impacting transactions. Almost all foreign banks are technologically
advanced and use a high level of IT integration into their operations. These
systems, in most instances, are similar to those being used by their branches
globally. Due to cost-benefit and other considerations, in some instances, foreign
banks, get certain financial or other information processed at one of their global
centres. This processing of data out of the country is generally with specific
consent from the RBI. Due to their existence in global financial centres and their
expertise, banks undertake complex treasury transactions (to the extent allowed
by RBI regulations). In most cases these transactions are undertaken back to
back with their foreign branches and would be hedged from a local risk
perspective. Additionally, banks also undertake and participate in international
advisory and syndication transactions, in partnership with their international
branches, which in effect generates fee revenue for the bank.
28. In the aftermath of the global financial crisis and building on the lessons
therefrom, RBI issued a Discussion Paper in January 2011 on the mode of
presence of foreign banks in India. Taking into account the feedback received on
the Discussion Paper, a Scheme for setting up of locally incorporated Wholly
Owned Subsidiary (WOS) by foreign banks in India was finalized in November
2013. The scheme provided, as hitherto, allowing foreign banks to operate in
India either through branch presence or setting up a wholly owned subsidiary
(WOS) with near national treatment. The foreign banks in India have to choose
one of the above two modes of presence and shall be governed by the principle
of single mode of presence. The policy is guided by the two cardinal principles of
(i) reciprocity and (ii) single mode of presence. As a locally incorporated bank,
the WOS will be given near national treatment which will enable them to open
branches anywhere in the country at par with Indian banks (except in certain
sensitive areas where RBI's prior approval would be required). They would also
be able to participate fully in the development of the Indian financial sector. The
policy incentivizes the existing foreign bank branches which operate within the
framework of India's commitment to the World Trade Organisation (WTO) to
convert into WOS due to the attractiveness of near national treatment. Such
conversion is also desirable from the financial stability perspective. To provide
safeguards against the possibility of the Indian banking system being dominated
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Banking in India
by foreign banks, the framework has certain measures to contain their expansion
if the share of foreign banks exceeds a critical size. Certain measures from
corporate governance perspective have also been built in so as to ensure that
the public interest is safeguarded.
(f) Payment Banks
29. On 27th November Payment Banks have been introduced in the Indian
financial system, with the basic objective of furthering financial inclusion by
providing (i) small savings accounts and (ii) payments/ remittance services to
migrant labour workforce, low income households, small businesses, other
unorganised sector entities and other users. Their scope of activities include the
acceptance of demand deposits, presently restricted to holding a maximum
balance of Rs. 100,000 per individual customer, payments and remittance
services through various channels, acting as Business Correspondents (BC) of
another bank etc. Payments Banks cannot undertake any lending activities. Apart
from amounts maintained as Cash Reserve Ratio (CRR) with RBI on its outside
demand and time liabilities, they are required to invest a minimum of 75 per cent
of their "demand deposit balances" in Statutory Liquidity Ratio (SLR) eligible
Government securities/treasury bills with maturity up to one year and hold
maximum 25 per cent in current and time/fixed deposits with other scheduled
commercial banks for operational purposes and liquidity management.
30. Payments banks are new model of banks conceptualized by Reserve Bank of
India (RBI) to meet government's financial inclusion target. They are being set up
as differentiated bank and its activities are confined to acceptance of demand
deposits, remittance services, internet banking and other specified services but
not lending services.
31. This differentiated banking model allows mobile firms, supermarket chains
and others to cater to banking requirements of individuals and small businesses.
32. Payments banks can accept deposits upto Rs. 1 lakh per account from
individuals and small businesses. They can issue ATM/debit cards but not credit
cards. They can also issue other prepaid payment instruments. They can also
distribute non-risk sharing simple financial products like mutual funds and
insurance products.
33. Operating guidelines have been issued vide Circular No. RBI/2016-17/80
DBR. NBD. No.25/16.13.218/2016-17 Dated October 6, 2016.
34. Recently, the Union Government has announced that India Post Payments
Bank (IPPB) will become operational in all 650 districts of the country by April
2018 to facilitate financial inclusion.
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Guidance Note on Audit of Banks (Revised 2019)
35. This bank will be linked to 1.55 lakh rural post offices for its operations and
carry out banking services. This will be largest banking network in the country.
36. IPPB has been set up as a Public Limited Company under Department of
Posts with 100% Government of India (GOI) equity. It leverages DoP's network,
resources and reach to make low-cost, quality and simple financial services
easily accessible to customers in the country. Its purpose is to further cause of
financial inclusion by providing basic banking, remittance services and payments
services to customers. It will facilitate spread of financial services like insurance,
pensions, mutual funds to customers especially from rural areas and the
unbanked and under-banked segments.
It will also generate opportunities for propagating financial literacy across the
country by using state of the art banking and payments technology. It will also
generate new employment opportunities for skilled banking professionals. It will
encourage citizens to move towards a cashless economy.
37. RBI has approved for 11 provisional Payments Bank Licenses which are
as follows-
a) Aditya Birla Nuvo Limited
b) Airtel M Commerce Service Limited
c) Cholamandalam Distribution Services Limited
d) India Department of Posts
e) Fino PayTech Limited
f) National Securities Depository Limited
g) Reliance Industries Limited
h) Shri Dilip Shantilal Shanghvi
i) Shri Vijay Shekhar Sharma
j) Tech Mahindra Limited
k) Vodafone m-pesa Limited
Of these 11 licenses, 6 Banks have already commenced banking operations.
(g) Small Finance Banks
38. Small Finance Banks have also been introduced in the Indian financial
system since November 2014, with the basic objective of furthering financial
inclusion by (a) provision of savings vehicles, and (b) supply of credit to small
business units; small and marginal farmers; micro and small industries; and other
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Banking in India
unorganised sector entities, through high technology-low cost operations. Their
scope of activities primarily include undertaking basic banking activities of
acceptance of deposits and lending to unserved and under-served sections
including small business units, small and marginal farmers, micro and small
industries and unorganized sector entities.
39. Operating guidelines have been issued vide Circular No. RBI/2016-17/81
DBR. NBD.No.26/16.13.218/2016-17 dated October 6, 2016. Guidelines w.r.t.
Investment Classification, Restrictions on Loan and Advances, Income
Recognition and Asset Classification as applicable to Scheduled Bank will be
applicable to Small Finance Banks. In addition to it, specific guidelines have been
issued for Capital Adequacy Framework, Leverage Ratio, Liquidity Coverage
Ratio and Net Stable Funding Ratio, etc.
40. On 17th September 2015, The RBI announced that it had given licenses to
10 entities namely Au Small Finance Bank, Capital Small Finance Bank, Jana
Small Finance Bank, Ujjwan Small Finance Bank, Equitas Small Finance Bank,
Fincare Small Finance Bank, ESAF Small Finance Bank, North East Small
Finance Bank, Suryoday Small Finance Bank, Utkarsh Small Finance Bank.
(h) EXIM Bank
41. EXIM Bank (Export Import Bank of India) was set up by the Government of
India under Export-Import Bank of India Act, 1981 and it started its functioning in
January 1982. It was established with the objective of providing financial
assistance to exporters and importers, functioning as the principal financial
institution for coordinating the working of institutions engaged in financing export
and import of goods and services with a view to promoting the country's
international trade.
42. It also provides refinance facilities to the commercial banks and financial
institutions against their export-import financing activities.
43. As on 31st march 2018, the net funded loan assets of the bank stood at Rs.
10753.20 Crore and non- funded advances were Rs. 1324Crore.
44. Functions of EXIM Bank:
1. Financing of export and import of goods and services both of India and of
outside India.
2. Undertaking merchant banking functions of companies engaged in foreign
trade.
3. Providing finance for joint ventures in foreign countries.
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Guidance Note on Audit of Banks (Revised 2019)
4. Offering buyers' credit and lines of credit to the foreign governments and
banks.
5. Providing technical and administrative support to the parties engaged in
export and import business.
6. Providing business information and advisory services to Indian exports in
respect of multilaterally funded projects overseas.
C. Organizational Structure of Banks
45. While the exact organizational structure may differ from one bank to another,
most large-sized public sector banks have a four-tier structure head office,
zonal offices, regional offices and branches (the nomenclature may, however,
vary among banks) each tier of the structure being responsible for performing
the functions specified by the Head Office.
46. At the apex level is the head office of the bank whose main functions are:
Laying down policies and procedures for smooth and efficient functioning of
the bank and to review them periodically.
Deciding on the extent of powers financial and administrative which may
be vested in various functionaries of the bank.
Planning and performance budgeting.
Asset-liability management.
Laying down lending policy of the bank, the risk management guidelines and
the rehabilitation and recovery guidelines including policies for compromise,
settlement and write-off.
Deciding about the interest rates on both deposits and the loans as well as
about charges for various services and review interest rates and charges
periodically.
Treasury and investment management (usually handled by the head office,
though in some cases, select large branches may also be involved in this
function).
Monitoring and controlling the functioning of various offices of the bank.
47. Periodic inspections and internal audit are important constituents of such
monitoring and control mechanism.
Reconciling the transactions among various offices of the bank
Introducing new products and services and reviewing the existing ones.
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Banking in India
Issuing instructions to branches and other offices from time to time on
matters deserving their attention or requiring compliance by them.
48. At the second level are the zonal offices which are responsible for overall
working of the branches in their areas of operation. Zonal offices act as a link
between the branches and the head office, either directly or through regional
offices.
49. Below the zonal offices are the regional offices which are the immediate
controllers of the branches under their jurisdiction. They are responsible for
business development, compliance with the laid down systems and procedures,
satisfactory customer service, quick redressal of complaints and submissions of
the required statements/reports/returns by branches under their jurisdiction. They
are also responsible for smooth functioning of the branches under them.
50. Branches are lowest in the hierarchy of the banking organization structure. In
fact, the banking operations (i.e., accepting deposits and making loans) actually
take place at the branch level. Their jobs are numerous, practically everything in
relation to banking, except the pricing of products/services and the policy
formulation.
51. Some branches have extension counters and sub-offices functioning under
them. The extension counters/sub-offices are meant for specific locations like
airports, large institutions, large project sites, etc., and cater exclusively to the
banking needs (either all or limited ) of the concerned locality.
D. Role of the Reserve Bank of India as the Central Bank
52. The Reserve Bank of India (hereinafter referred to as RBI) acts as the
monetary authority and the central bank of the country. In an effort to bring
greater coordination among financial regulators, the Government of India has
constituted an over-arching body - the Financial Stability and Development
Council ("FSDC" or "Council") in December 2010. The Council is headed by the
Honorable Finance Minister and composed of the Governor of the RBI, the chairs
of the SEBI, the IRDA and the PFRDA, and other Ministry of Finance ("MoF")
officials. It envisages strengthening and institutionalizing the mechanism of
maintaining financial stability, financial sector development, inter-regulatory
coordination along with monitoring macro-prudential regulation of the Indian
economy. On February 20, 2015 the RBI and Government signed the Monetary
Policy Framework Agreement. In addition to it after amendment in RBI Act, the
Monetary Policy Committee (MPC) headed by Governor was setup. The MPC is
entrusted with the task of fixing the benchmark policy interest rate (repo rate) to
contain inflation within the target level.
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53. The RBI is the central bank of our country. As such, RBI is responsible for
development and supervision of the constituents of the Indian financial system
(which comprises banks and non-banking financial institutions) as well as for
determining, in conjunction with the Central Government, the monetary and credit
policies keeping in with the need of the hour. Among its important functions are
issuance of currency; regulation of currency issue; acting as banker to the central
and state governments; and acting as banker to commercial and other types of
banks including term-lending institutions. Besides, RBI has also been entrusted
with the responsibility of regulating the activities of commercial and other banks.
Banks can commence business by opening the branches as per branch opening
policy of RBI. The RBI also has the power to inspect any bank. The Banking
Regulation Act, 1949 provides the legal framework for regulation and supervision
of banks. This statute, together with some provisions in the Reserve Bank of
India Act, 1934, State Bank of India Act, 1955, State Bank of India (Subsidiary
Banks) Act, 1959 and Banking Companies (Acquisition and Transfer of
Undertakings) Acts, 1970 & 1980, empowers the RBI to prescribe standards and
monitor liquidity, solvency and soundness of banks, so as to ensure that
depositors' interests are protected at all times.
54. Periodic inspections of banks under section 35 of the Banking Regulation
Act, 1949 are undertaken as a follow-up of the bank licensing regulation and
objectives as laid down in section 22 of the Banking Regulation Act, 1949. The
substantive objective of the statutory inspections has been to verify whether the
conditions subject to which the bank has been issued license to undertake
banking business in terms of sub-section (3) of section 22 [including sub-section
(3A) for foreign banks] continue to be fulfilled by it. The conditions include:
(a) the bank "is or will be in a position to pay its present or future depositors in
full as their claims accrue" (i.e. it is solvent and has adequate liquidity);
(b) the bank "has adequate capital structure and earning prospects";
(c) "the affairs of the (banking) company are not being, or are not likely to be,
conducted in a manner detrimental to the interests of its present or future
depositors"; and
(d) "the general character of the management of the bank is not prejudicial to
the public interest or the interest of its depositors" (i.e. it has sound
operational systems and adequate controls operated by a prudent
management).
Section 22(4) of the Banking Regulation Act, 1949 authorizes the RBI to
cancel the banking license "if at any time, any of the conditions referred to
in sub-section (3) and sub-section (3A) is not fulfilled".
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55. Based on the recommendations of a High Level Steering Committee (HLSC)
for Review of Supervisory Processes of Commercial Banks, the Reserve Bank of
India had in September 2012, introduced a Supervisory Program for Assessment
of Risk and Capital (SPARC) for commercial banks under RBS. This Risk Based
Supervision (RBS) approach, helps the regulator in focusing on evaluating both
present and future risks, identifying incipient issues and facilitating prompt
intervention/ early corrective action - as against the earlier compliance-based and
transaction testing approach (CAMELS) which was more in the nature of a `point
in time' assessment. The RBS approach also benefits the regulator by optimizing
its use of supervisory resources and assisting the regulated entities in improving
their risk management systems, oversight and controls.
56. RBI is empowered under section 21 of the Banking Regulation Act, 1949, to
control advances by banks in general or by any bank in particular. Among the
measures that the RBI can adopt for this purpose are to prescribe purposes and
extent of advances, margin requirements, maximum exposure to a single
borrower, rate of interest and other terms and conditions, etc. Besides these
measures (which are usually called `selective credit control' measures), RBI also
controls the total volume of bank credit by varying bank rate through open market
operations or by varying cash reserve and similar requirements.
57. Bank rate refers to the rate of interest at which the RBI re-discounts the first
class bills of exchange or other eligible instruments from banks. Variations in
bank rate affect the interest rates charged by banks generally, interest rates of
banks move up or down in tandem with movements in bank rate.
58. Under Base Rate system which came into effect from July 1, 2010, all
categories of domestic rupee loans of banks are priced only with reference to the
Base Rate, subject to certain conditions. For monetary transmission to occur,
lending rates have to be sensitive to the policy rate. At present, banks follow
different methodologies for computing their Base Rate like average cost of funds
method, marginal cost of funds, blended cost of funds (liabilities) etc.
59. Open market operations involve sale or purchase of government securities in
the open market. When RBI buys government securities from banks in the open
market, the funds in the hands of selling banks increase, enabling them to
expand credit, and vice versa.
60. Banks are required to maintain at least a prescribed minimum percentage of
their demand and time liabilities in India in the form of cash and/or current
account balances with the RBI (called `cash reserve ratio'). Additionally, they are
required to maintain a further percentage in the form of cash and/or other liquid
assets (called `statutory liquidity ratio'). Varying the cash reserve ratio and/or
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statutory liquidity ratio enables the RBI to increase or decrease (as the case may
be) the funds available to banks for lending and other similar purposes.
61. A major development that has implications for banks throughout the world is
the "International Convergence of Capital Measurement and Capital Standards"
generally known as the Basel Accord. Basel III ensures better quality of capital
and robust liquidity risk management.
62. The smooth functioning of the payment and settlement systems is a
prerequisite for stability of the financial system. In order to have focused attention
on payment and settlement systems, a Board for Regulation and Supervision of
Payment Systems (BPSS) was set up in March, 2005. The launch of the Real
Time Gross Settlement System (RTGS) and NEFT (National Electronic Funds
Transfer) has led to a reduction of settlement risk in large-value payments in the
country. Similarly, IMPS (Inter bank Mobile Payment Service/Immediate Payment
Service) is a mobile based payment mechanism introduced by the National
Payments Corporation of India to allow customers to transfer money instantly,
facilitating instant remittance across multiple platforms. The setting up of NSDL
and CDSL for the capital market settlements and CCIL for G-sec, forex and
money market settlements have improved efficiency in market transactions and
settlement processes. A series of legal reforms to enhance the stability of the
payment systems have been carried out. With the introduction of the Payments
and Settlement Act in 2008, the Reserve Bank has the legislative authority to
regulate and supervise payment and settlement systems in the country.
63. In India, deposit insurance is provided by the Deposit Insurance and Credit
Guarantee Corporation (DICGC), a wholly owned subsidiary of the Reserve Bank
of India. Deposit insurance in India is mandatory for all banks
(commercial/cooperative/ RRBs/LABs). It covers all kinds of deposits except
those of foreign governments, Central/State Governments, inter-bank, deposits
received abroad and those specifically exempted by DICGC with prior approval
of the Reserve Bank. The premium charged for deposit insurance is on a flat rate
basis, which is currently 10 paise per Rs.100 of assessable deposits with a
statutory ceiling on premium at 15 paise. The premia to be paid by the insured
banks are computed on the basis of their assessable deposits. Insured banks
pay advance insurance premia to the Corporation semi-annually within two
months from the beginning of each financial half year, based on their deposits as
at the end of previous half year. The amount of coverage is presently limited to
Rs.1 lakh per depositor and extends to deposits held in the same right and in the
same capacity.
64. Banks and financial institutions (FIs) have also been advised by RBI to follow
certain customer identification procedure for opening of accounts and monitor
transactions of suspicious nature for the purpose of reporting the same to
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appropriate authority. These `Know Your Customer' (KYC) guidelines have been
revisited in the context of the recommendations made by the Financial Action
Task Force (FATF) on Anti Money Laundering (AML) standards and on
Combating Financing of Terrorism (CFT). Detailed guidelines based on the
recommendations of FATF and the paper issued on Customer Due Diligence
(CDD) for banks by the Basel Committee on Banking Supervision (BCBS), with
suggestions wherever considered necessary, have been issued. Banks/FIs have
been advised by RBI to ensure that a proper policy framework on `Know Your
Customer' and Anti-Money Laundering measures is formulated and put in place
with the approval of their Boards. The objective of KYC/AML/CFT guidelines is to
prevent banks/FIs from being used, intentionally or unintentionally, by criminal
elements for money laundering or terrorist financing activities. KYC procedures
also enable banks/FIs to know/understand their customers and their financial
dealings better and manage their risks prudently. Foreign Account Tax
Compliance Act (FATCA) is a US law, which was enacted in March 2010 by the
US Government which was aimed at preventing tax evasion through off shore
assets by US citizens and US residents. Foreign Financial Institutions (FFIs)
such as the Bank that enter into a FATCA FFI agreement with the US
government are required to conduct certain due-diligence to identify its US clients
(individual and entity) and report on their accounts to the US Internal Revenue
Service (IRS).
65. India has signed the Inter-Governmental Agreement (IGA) with USA for
improving international tax compliance and implementing the Foreign Account
Tax Compliance Act (FATCA). India has also signed a multilateral agreement on
June 3, 2015, to automatically exchange information based on Article 6 of the
Convention on Mutual Administrative Assistance in Tax Matters under the
Common Reporting Standard (CRS), formally referred to as the Standard for
Automatic Exchange of Financial Account Information (AEoI). In this regard, On
August 7, 2015 Government of India has notified the amendments to Income Tax
Rules (Rules) and have added Rule 114F (definitions), 114G (Information to be
maintained and reported) and 114H (due diligence requirement) for
operationalization of IGA and CRS. This information regarding US reportable
persons and other reportable persons have to be furnished in a form 61B.
Banks have modified their account opening forms to include FATCA Compliance
Declarations. Banks are internally monitoring transactions over the defined
thresholds to verify if any transactions need reporting as per the guidelines.
Auditors also review whether the Bank has ensured compliance with the FATCA
guidelines.
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66. Apart from directions relating to operational matters, RBI also issues, from
time to time, guidelines on accounting matters to be followed by banks. These
guidelines have a profound effect on annual accounts of banks. The text of the
notifications/circulars/guidelines, etc., issued by RBI are normally also available
on its website www.rbi.org.in.
Prompt Corrective Action (PCA) framework for NPAs
67. Reserve Bank of India under its supervisory frame work uses various
measures/ tools to maintain sound financial health of the bank. PCA frame work
is one of such supervisory tools which involve monitoring of certain performance
indicators of the banks as early warning exercise and is initiated once such
thresh holds as relating to capital, asset quality etc. are breached.
68. Its objective is to facilitate the banks to take corrective measures including
those prescribed by RBI, in a timely manner to realize financial health of the
bank.
69. PCA frame work is in operations since December 2002 & the guidelines have
been issued from time to time and on 13th April 2017, revised frame work was
issued by the RBI.
70. RBI has come up with a notification titled "Revised Prompt Corrective Action
(PCA) framework for banks." The revised framework would apply to all banks
operating in India including small and foreign banks. The new set of provisions
will be effective from April 1 based on the financials of banks as of March 2017.
The revised framework will override the existing PCA framework. The revised
framework will be again reviewed after three years.
In 2018, 11 PSU Banks were under PCA Framework which were Dena Bank,
Allahabad Bank, United Bank of India, Corporation Bank, IDBI Bank, UCO Bank,
Bank of India, Central Bank of India, Indian Overseas Bank, Oriental Bank of
Commerce and Bank of Maharashtra.
Salient guidelines of revised PCA
71. Capital, Asset Quality and profitability would be the basis on which the banks
would be monitored. Banks would be placed under PCA framework depending
upon the audited annual financial results and RBI's supervisory assessment. RBI
may also impose PCA on any bank including migration from one threshold to
another if circumstances so warrants. RBI has defined three kinds of risk
thresholds and the PCA will depend upon the type of risk threshold that was
breached
72. If a bank breaches the risk threshold, then mandatory actions include the
restriction on dividend payment/remittance of profits, restriction on branch
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expansion, higher provisions, restriction on management compensation and
director's fees. Specifically, the breach of `Risk Threshold 3' of CET1 (common
equity tier 1) by a bank would call for resolution through tools like amalgamation,
reconstruction, winding up among others.
73. RBI in its discretion can also carry out the following actions:
Recommend the bank owner be it government/promoters/parent of foreign
bank branch to bring in new management/board.
Advise bank's board to activate the recovery plan as approved by the
supervisor.
Advise bank's board to carry out a detailed review of business model, the
profitability of business lines and activities, assessment of medium and long
term viability, balance sheet projections among others.
Review short term strategies and medium-term business plans and carry out
any other corrective actions like the removal of officials and supersession or
suppression of the board.
Legal Entity Identifier (LEI) mandatory for all large corporate
borrowers
74. On 2nd November, 2017, RBI vide notification
DBR.No.BP.BC.92/21.04.048/2017-1 has made 20-digit Legal Entity Identifier
(LEI) compulsory for companies having aggregate fund-based and non-fund
based exposure over Rs. 5 crore.
75. The move is aimed at improving risk management in wake of huge stressed
assets in banking system. Before this, RBI had made LEI mandatory for
transactions in interest rate, forex and credit derivative market
76. LEI mechanism will help banks to effectively monitor debt exposure of
corporate borrowers. It will also enable banks in preventing multiple loans to
companies against the same collateral.
77. LEI is a 20-digit unique code to identify parties to financial transactions
worldwide. It is a global reference number that uniquely identifies every legal
entity or structure that is party to a financial transaction, in any jurisdiction. It is
defined by ISO 17442. LEI code has been conceived as key measure to improve
quality and accuracy of financial data systems for better risk management post
the global financial crisis.
78. The LEI system was developed by G20 in response to inability of financial
Institutions to identify organizations uniquely, so that their financial transactions
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in different national jurisdictions can be fully tracked. The first LEIs were issued in
December 2012.
79. Legal Entity Identifier India Limited (LEIL), a wholly-owned subsidiary of
Clearing Corporation of India (CCI), acts as a local operating unit (LOU) for
issuing globally compatible legal entity identifiers (LEIs) in India. Besides, entities
can also obtain LEI from any of local operating units (LOUs) accredited by Global
Legal Entity Identifier Foundation (GLEIF) the entity tasked to support
implementation and use of LEI.
80. Borrowers with fund and non-fund exposure of Rs 1,000 crore and above will
have to get LEI by March 2018. Those having exposure between Rs 500 crore
and Rs. 1,000 crore have to obtain LEI code by June 2018 and those having
between Rs. 100 crore and Rs 500 crore by March 2019.
E. Role of the Union Government for strengthening and
improving the Banking Sector in India
81. The Union Government is also initiating various measures from time to time
in order to strengthen the Banking Sector in India.
82. As a part of measure, Union Government has launched a seven pronged
plan called Indradhanush Mission in August 2015 to revamp functioning of public
sector banks (PSBs). The plan envisaged inter alia, infusion of capital in PSB's
by the Government to the tune of Rs. 70,000 crore over a period of four financial
years to meet their capital requirement in line with global risk Basel-III norms to
keep these banks fully solvent. Government has so far infused capital of Rs.
59,435 crore in PSB under Indradhanush.
83. The seven shades of Indradhanush mission include appointments, de-
stressing PSBs, capitalisation, empowerment, framework of accountability Bank
Board Bureau and governance reforms.
84. It seeks to achieve the objective of economic growth revival through
improving credit and minimising the political interference in the functioning of
PSBs.
85. One of the shed of mission Indradhanush, Bank Board Bureau (BBB) was
earlier announced in the 2015-16 budgets and which was implemented with the
announcement of the Indradhanush Mission. It is the first step used to make
bank as a full fledged bank holding company.
BBB replaced all the earlier procedure of appointment of whole time
directors and non executive chairman of Public Sector Banks and formalized
the appointment procedures by comprising the eminent professionals and
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officials, who will follows the proper election methodology for appointment of
CEO and MD for the required posts in banks.
BBB consists of a chairman and six members team in which three officials
and three experts, who will constantly involve themselves with the Board of
Directors of the other Public Sector Banks to formulate the growth and
development strategies
86. The Bank Board Bureau (BBB) has recommended that Government should
bring in reforms in the compensation process in public sector banks (PSBs) on
the lines of Central Public Sector Enterprises (CPSEs).
87. BBB has suggested compensation reforms in PSBs so that best practices
can be introduced `on the lines already prevalent in CPSEs.
88. It will play important role in attracting high-quality talent for non-executive
directors and chairmen. It will also maintain a level-playing field with the private
sector with respect to role, responsibility and remuneration.
BBB is the super authority (autonomous body) of eminent professionals and
officials for public sector banks (PSBs). It had replaced the Appointments of
Board of Government.
It is set up in April 2016 as part of seven point Indradhanush Mission to
revamp the Public Sector Banks (PSBs).
Functions: Give recommendations to Government for appointment of fulltime
Directors as well as non-Executive Chairman of PSBs.
Give advice to PSBs in developing strategies for raising funds through
innovative financial methods and instruments to deal with stressed assets.
Guide banks on mergers and consolidations and also ways to address the
bad loans problem and among other issues.
Bank Recapitalization Plan
89. Indian PSBs are saddled with high, non-performing assets (NPAs) and facing
prospect of having to take haircuts on loans stuck in insolvency proceedings.
Due to this, PSBs were unable to give fresh loans.
90. The Union Government has announced Bank Recapitalization Plan to infuse
Rs. 2,11,000 crore ($32.4 billion) capital over next two years into public sector
banks (PSBs) and prioritized financing support for MSMEs in 50 clusters. The
capital infusion will be accompanied by a series of banking sector reforms that
will be revealed in the coming months. Key Facts Under this plan, PSBs will get
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Guidance Note on Audit of Banks (Revised 2019)
Rs 1,35,000 crore from Recapitalization Bonds, Rs. 18,139 crore from Budgetary
support and remaining Rs 57,861 crore will be raised through sale of share of
banks. The nature of recapitalization bonds will be decided in coming months
and these bonds will be frontloaded over next four quarters with maximum
timeframe of two years.
91. It will increase lending capacity of PSBs which will in turn boost economy and
improve private sector investment especially when International Monetary Fund
(IMF) projected growth to 5.7% which is lowest in three-year and create jobs. The
supply of money to PSBs will enable banks lend lower interest rates. Depending
on nature of recapitalization bonds, their issuance can also impact the
government's fiscal deficit target i.e. government's total expenditures may
exceed the revenue that it generates (apart from money from borrowings).
Consolidation of Banks
92. During the year, era of consolidation of banks started with merger of 6
association of State Bank of India, namely State Bank of Bikaner and Jaipur,
State Bank of Hyderabad, State Bank of Mysore, State Bank of Patiala and State
Bank of Travancore & Bharatiya Mahila Bank. With this merger, SBI joined the
league of top 50 banks globally in terms of assets.
93. On September 17th, 2018, The government had announced the merger of
Bank of Baroda, Vijaya Bank and Dena Bank, to create the country's third largest
lender. The boards of all the three banks have approved (the merger proposal)
and sent the recommendations to the government. The next step would be the
government approving formally the merger process, and then the swap ratio. The
merger is expected to take four to six months to complete. More Banks are
expected to merge and consolidate going forward.
94. BOM has already announced closure of 51 Branches wef from 1st October
2018 all in Urban Center across India which have been identified for the cost
cutting action
95. The idea of bank mergers was around since 1991, when former Reserve
Bank of India (RBI) governor M. Narasimham had recommended the government
to merge banks into three-tiered structure, with three large banks with an
international presence at top. In 2014, PJ Nayak Committee also had suggested
that government either merge or privatize state-owned banks.
96. Significance of PSBs consolidation
Reduce their dependence on government for capital.
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Open up more capital generation avenues, both internally and from market,
for the merged entity.
From a government point of view, it will increase stream of dividends which
forms part of their non-tax revenue.
Increase the role of internal and market resources and thus reduce
dependence of merged bank on government for the future capital infusion
It will lead to greater concentration of payment and settlement flows as there
will be fewer parties in the financial sector.
Operational risks could increase post-merger as size of operations grows
and distance between management and operational personnel is greater as
the administrative systems become more complex.
It will help to deal better with their credit portfolio, including stressed assets.
Consolidation will also prevent multiplicity of resources being spent in the
same area and strengthens banks to deal with shocks.
97. With the merger, SBI's market share has increased to 22.5-23% from 17%
with total business of over 37 lakh crore rupees. The merged entity now has a
deposit base of more than Rs. 26 lakh-crore and advances level of Rs 18.50 lakh
crore accounting for one-fourth of the deposit and loan market in the country. SBI
now has 2.77 lakh employees, 50 crore customers and more than 25,000
branches and 58,000 ATMs. Its total customer base has reached to 37 crore
across the country and these all customers will enjoy the benefits of a wide array
of digital products and services offered by SBI.
98. Thereupon the Union Government has constituted Alternative Mechanism
Panel headed by Union Finance Minister Shri Arun Jaitley to oversee merger
proposals of public sector banks (PSBs). The other members of the panel include
Railway and Coal Minister Shri Piyush Goyal and Defence Minister Smt. Nirmala
Sitharaman.
99. This alternative mechanism has been set up by the government to fast-track
consolidation among public sector banks to create strong lenders. The
mechanism will oversee the proposals coming from boards of PSBs for
consolidation.
Alternative mechanism being created to give in-principle approval to
proposals of banks to prepare schemes of amalgamations.
After in-principle approval, the banks will take steps in accordance the law
and SEBI's requirements.
The final scheme will be notified by Central Govt. in consultation with
Reserve Bank of India.
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Alternative mechanism aims to create strong and competitive banks in public
sector space to meet the credit needs of a growing economy, absorb shocks
and have the capacity to raise resources without depending unduly on the
state exchequer.
The decision regarding creating strong and competitive banks would be
solely based on commercial consideration.
Amendments in the Banking Regulation Act, 1949
100. The banking sector in India is saddled with non-performing assets. The
Union Government in May 2017 had promulgated an ordinance authorizing the
RBI to issue directions to banks to initiate insolvency resolution process under
the Insolvency and Bankruptcy Code, 2016. The RBI in June 2017 had identified
12 accounts each having more than Rs. 5000 crore of outstanding loans and
accounting for 25% of total NPAs of banks for immediate referral for resolution
under the bankruptcy law. Further in August, 2017, the RBI identified 28
accounts those were materially NPA as on June 30, 2017, i.e. where more than
60 percent of the total outstanding was classified as NPA on CRILC, shall be
given time till December 13, 2017 for resolution outside IBC. In the event that a
viable resolution plan is not finalized and implemented before that said date,
insolvency proceedings under the provisions of the IBC may be initiated before
December 31, 2017, unless already initiated. The bulk of the NPAs are in certain
sectors including power, steel, road infrastructure and textiles.
101. The Union Government has notified the Banking Regulation (Amendment)
Act, 2017. The Parliament had approved the Banking Regulation (Amendment)
Bill, 2017 which replaced an ordinance in this regard.
102. It amended the Banking Regulation Act, 1949 by adding provisions for
handling cases related to stressed assets or non-performing assets (NPAs) of
banks.
103. The Act empowers the Central government to authorize the Reserve Bank
of India (RBI) to direct banking companies to resolve specific stressed assets by
initiating insolvency resolution process under the Insolvency and Bankruptcy
Code, 2016.
104. The RBI can specify authorities or committees to advise banks on resolution
of stressed assets. The members on the committees will be appointed or
approved by the RBI. The Act also makes these provisions applicable to the SBI
and its subsidiaries and also Regional Rural Banks (RRBs).
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Accounting and Auditing
Framework
01. The guidance note is based on DBOD and other circulars issued by RBI
which are applicable to scheduled commercial banks. Thus, this guidance note is
to be referred to in the context of audit of Scheduled Commercial Bank only and
not for the purpose of Urban Co-operative Banks, Regional Rural Banks and
District Central and State Apex Co-operative Bank. This Chapter discusses the
statutory provisions and regulatory requirements affecting the accounts and audit
of banks.
Form and Content of Financial Statements
02. Sub-sections (1) and (2) of section 29 of the Banking Regulation Act,
1949, deal with the form and content of financial statements of a banking
company and their authentication. These sub-sections are also applicable to
nationalised banks, State Bank of India, subsidiaries of the State Bank of India,
and Regional Rural Banks.
03. Sub-section (1) of section 29 requires every banking company to
prepare a balance sheet and a profit and loss account in the forms set out in the
Third Schedule to the Act or as near thereto as the circumstances admit. These
financial statements have to be prepared as on the last working day of each
financial year (i.e., 31st March) in respect of all business transacted during the
year. A foreign banking company (i.e., a banking company incorporated outside
India and having a place of business in India) has to similarly prepare a balance
sheet and a profit and loss account every year in respect of all business
transacted through its branches in India. As per Accounting Standard 3, the bank
should prepare the cash flow statement also. Hence the financial statements of
the bank shall include the cash flow statement along with the balance sheet and
profit and loss account as well.
Salient Features of the Third Schedule
04. Form A of the Third Schedule to the Banking Regulation Act, 1949,
contains the form of balance sheet and Form B contains the form of profit and
loss account. The text of the Third Schedule to the Banking Regulation Act,
1949 is given in Appendix II of this Guidance Note.
Guidance Note on Audit of Banks (Revised 2019)
05. The balance sheet as well as the profit and loss account are required to
be presented in vertical form. Capital and liabilities are to be presented under the
following five broad heads:
Capital
Reserves and Surplus
Deposits
Borrowings
Other liabilities and provisions
06. Assets are required to be presented under the following six broad
heads:
Cash and Balances with Reserve Bank of India
Balances with Banks and Money at call and short notice
Investments
Advances
Fixed assets
Other assets
07. Details of items of capital, liabilities and assets are required to be
presented in the prescribed form in various schedules.
08. The aggregate amounts of contingent liabilities and bills for collection
are to be presented on the face of the balance sheet. While details of contingent
liabilities are to be presented by way of a schedule.
09. The following items are required to be presented on the face of the profit
and loss account.
I. Income
Interest earned
Other income
II. Expenditure
Interest expended
Operating expenses
Provisions and contingencies
III. Profit (Loss)
Net profit (loss) for the year
Profit/loss brought forward
IV. Appropriations
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Transfer to statutory reserves
Transfer to other reserves
Transfer to Government/Proposed Dividend
Balance carried over to balance sheet
10. Prescribed details of interest earned, other income, interest expended
and operating expenses are required to be given by way of schedules to the
profit and loss account.
Disclosures Prescribed by RBI
11. In addition to the disclosures to be made in the balance sheet and profit
and loss account in pursuance of the requirements of the Third Schedule to the
Act, the RBI has, vide its Master Circular no. DBR.BP.BC No 23/21.04.018/2015-
16 dated July 1, 2015 on "Disclosure in Financial Statements `Notes to
Accounts'", prescribes disclosures to be made in the Notes to Accounts in
respect of certain significant aspects of the items of financial statements of
banks. Further the RBI vide its Circular No. DBR.BP.BC.No.63/21.04.018/2016-
17 has prescribed an additional disclosure to be made in the Notes to Accounts
from the Financial Year 2016-17 with respect to divergences observed by the
RBI in the asset classification and provisioning. The disclosures in connection
with Accounting Standards as mentioned in the circular is only the minimum
required and other disclosures as prescribed by the Accounting Standards is
mandatory to the extent they are not inconsistent with RBI circular.
Disclosures Required Under Accounting Standards
12. The disclosure requirements under the various Accounting Standards,
as specified under Section 133 of the Companies Act, 2013, read with Rule 7 of
the Companies (Accounts) Rules 2014, in so far as they apply to banking
companies or Accounting Standards issued by the ICAI are also to be complied
with.
Requirements of the Banking Regulation Act, 1949, vis-a-vis
Companies Act, 2013
13. The requirements of the Companies Act, 2013, relating to the balance
sheet, profit and loss account and cash flow statement of a company, in so far as
they are not inconsistent with the Banking Regulation Act, 1949, also apply to the
financial statements, as the case may be, of a banking company [sub-section (3)
of section 29 of the Act].It may be noted that this provision does not apply to
nationalised banks, State Bank of India, its subsidiaries and regional rural banks.
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14. The Union Budget for 2014-15 emphasised the urgent need for
convergence of the current Indian accounting standards with International
Financial Reporting Standards (IFRS). The Ministry of Corporate Affairs (MCA),
Government of India notified the rules for IFRS converged Indian Accounting
Standards (Ind AS) along with its implementation road map for corporates in a
phased manner from 2016-17 onwards. Pursuant to Companies (Indian
Accounting Standards) (Amendment) Rules, 2016 the following roadmap for Ind
AS implementation in case of insurance companies, banking companies and
non-banking financial companies (NBFCs) has also been announced:
"Roadmap drawn-up for implementation of Indian Accounting Standards (Ind AS)
converged with International Financial Reporting Standards (IFRS) for Scheduled
Commercial Banks (Excluding RRBs), Insurers/Insurance Companies and Non-
Banking Financial Companies (NBFCs)"
15. In pursuance to the Budget Announcement by the Union Finance Minister
Shri Arun Jaitley, after consultations with Reserve Bank of India (RBI), Insurance
Regulatory and Development Authority (IRDA) and Pension Fund Regulatory and
Development Authority (PFRDA), the following roadmap for implementation of
Indian Accounting Standards (Ind AS) converged with International Financial
Reporting Standards (IFRS) for Scheduled commercial banks (excluding RRBs),
insurers/insurance companies and Non-Banking Financial Companies (NBFCs)
has been drawn up. The RBI has issued a Press Release on April 05, 2018
specifying deferment of Ind AS implementation for Scheduled Commercial Banks
excluding RRBs by one year. The aforesaid Press Release provides that
Scheduled Commercial Banks (SCBs), excluding Regional Rural Banks (RRBs),
were required to implement Indian Accounting Standards (Ind AS) from April 1,
2018 vide our Circular dated February 11, 2016. However, necessary legislative
amendments - to make the format of financial statements, prescribed in the Third
Schedule to Banking Regulation Act 1949, compatible with accounts under Ind
AS - are under consideration of the Government. In view of this, as also the level
of preparedness of many banks, it has been decided to defer implementation of
Ind AS by one year by when the necessary legislative changes are expected.
Scheduled commercial banks (excluding RRBs)/NBFCs/insurance
companies/insurers shall apply Indian Accounting Standards (Ind AS) only if they
meet the specified criteria, they shall not be allowed to voluntarily adopt Indian
Accounting Standards (Ind AS). This, however, does not preclude an
insurer/insurance company/NBFC from providing Ind AS compliant financial
statement data for the purposes of preparation of consolidated financial
statements by its parent/investor, as required by the parent/investor to comply
with the existing requirements of law.
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Banks Listed on a Stock Exchange
16. Banks listed on a stock exchange have to also comply with the
requirements of listing as amended from time to time. In respect of securities
issued and traded on foreign bourses, if any, the issuer bank has to comply with
the applicable regulations of that jurisdiction.
Consolidated Financial Statements in case of one or more
Subsidiaries
17. Banks are required to prepare Consolidated Financial Statements
incorporating the Financial Statements of all the subsidiaries in the same form
and manner as that of its own. In case the Bank is a Company, then such
Consolidated Financial Statements shall also be laid before the annual general
meeting of the company along with the laying of its financial statement by virtue
of sub section (3) of section 129 of Companies Act, 2013.
Further a separate statement containing the salient feature of the financial
statement of its subsidiary or subsidiaries in such form as may be prescribed
shall also be attached along with its financial statement.
Notes and Instructions Issued by RBI
18. The RBI has issued notes and instructions for compilation of balance
sheet and profit and loss account. These notes and instructions provide an
authoritative interpretation of the requirements of the Third Schedule to the Act
and are thus useful in preparation of financial statements of banks.
Signatures
19. Sub-section (2) of section 29 of the Act requires that the financial
statements of banking companies incorporated in India should be signed by the
manager or principal officer of the banking company and by at least three
directors (or all the directors in case the number is less than three). The financial
statements of a foreign banking company are to be signed by the manager or
agent of the principal office in India. It may be noted that the accounts of a
branch are usually signed by the manager of the branch and/or the accountant.
The provisions of sub-section (2) of section 29 are also applicable to nationalised
banks, State Bank of India, its subsidiaries, and regional rural banks.
Auditor's Report
20. In the case of a nationalised bank, the auditor is required to make a
report to the Central Government in which the auditor has to state the following:
(a) whether, in his opinion, the balance sheet is a full and fair balance sheet
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containing all the necessary particulars and is properly drawn up so as to
exhibit a true and fair view of the affairs of the bank, and in case he had
called for any explanation or information, whether it has been given and
whether it is satisfactory;
(b) whether or not the transactions of the bank, which have come to his notice,
have been within the powers of that bank;
(c) whether or not the returns received from the offices and branches of the
bank have been found adequate for the purpose of his audit;
(d) whether the profit and loss account shows a true balance of profit or loss for
the period covered by such account; and
(e) any other matter which he considers should be brought to the notice of the
Central Government.
21. The report of auditors of State Bank of India is also to be made to the
Central Government and is almost identical to the auditor's report in the case of a
nationalised bank.
22. The auditor's report in the case of subsidiaries of State Bank of India is
identical to the auditor's report in the case of a nationalised bank, except that all
references to Central Government have to be construed instead as references to
the State Bank of India. Similar is the position in the case of regional rural banks,
except that the references are instead to the bank concerned.
Format of Audit Report
23. The auditors, central as well as branch, should also ensure that the
audit report issued by them complies with the requirements of SA 700 (Revised),
"Forming an Opinion and Reporting on Financial Statements", SA 701,
"Communicating Key Audit Matters in the Independent Auditor's Report" and
where required with the SA 705 (Revised), "Modifications to the Opinion in the
Independent Auditor's Report" and/or SA 706 (Revised), "Emphasis of Matter
Paragraphs and Other Matter Paragraphs in the Independent Auditor's Report",
as may be applicable. ICAI has revised SA 700, 701, 705 and 706 on 17th May,
2016 which will be effective for audits of financial statements for periods
beginning on or after 1st April, 2018. SA 701 "Communicating Key Audit Matters
in the Auditor's Report", this SA deals with auditor's responsibility to
communicate key audit matters in the auditor's report. Communicating key audit
matters provides additional information to intended users of the financial
statements to assist them in understanding those matters that, in the auditor's
professional judgment, were of most significance in the audit of the financial
statements of the current period. These matters are selected from matters
communicated with those charged with governance. The auditor shall describe
each key audit matter, using an appropriate subheading, in a separate section of
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the auditor's report under the heading "Key Audit Matters," The auditor should
ensure that not only information relating to number of unaudited branches is
given but quantification of advances, deposits, interest income and interest
expense for such unaudited branches has also been disclosed in the audit report.
Such disclosure in the audit report is not only in accordance with the best
international trends but also provides useful information to users of financial
statements, for example, though the absolute number of unaudited branches
might be quite large but in relation to overall operations of the bank such
unaudited branches are quite miniscule and thus, not material. Therefore, the
auditor should ensure that the complete information in respect of unaudited
branches is collected and disclosed in the audit report.
24. Further, in accordance with the Announcement issued by the Institute of
Chartered Accountants of India, the bank branch auditors need to mention the
total number of debits/ credits and amounts in the Memorandum of Changes
submitted by them, under the Other Matters Paragraph in the their audit report.
This would help in ensuring that all adjustments suggested by the branch
auditors in the Memorandum of Changes, including those which have not per se
been accepted by the bank branch managements, have been duly brought to the
knowledge of the statutory central auditors. It may be noted that the information
in respect of Memorandum of Changes under the "Other Matters Paragraph"
would include both such MoCs which have been accepted as well as those not
accepted by the bank branch management, though this distinction need not per
se be brought out in the audit report..
25. The auditor of a banking company is required to state in his report the
followings in terms of provisions of Section 30(3) of The Banking Regulation Act,
1949:
(a) whether or not the information and explanations required by the auditor
have been found to be satisfactory;
(b) whether or not the transactions of the company which have come to the
notice of the auditor have been within the powers of the Bank;
(c) whether or not the returns received from the branch offices of the Bank
have been found adequate for the purpose of audit;
(d) whether the profit and loss account shows a true balance of profit or loss for
the period covered by such account; and
(e) any other matter which the auditor considers should be brought to the
notice of the shareholders of the company.
In addition to the aforesaid, the auditor of a banking company is also required to
state in his report in respect of matters covered by Section 143(2) & (3) of the
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Companies Act, 2013.
26. As per reporting requirements cast through Rule 11 of the Companies
(Audit and Auditors) Rules, 2014 the auditor's report shall also include their views
and comments on the following matters, namely:
i) whether the bank has disclosed the impact, if any, of the pending litigations
on its financial position in its financial statements
ii) whether the bank has made provision, as required under the law or
accounting standards, for material foreseeable losses, if any, on long term
contracts including derivative contracts
iii) whether there has been any delay in transferring amounts, required to be
transferred to the Investment Education and Protection Fund by the bank.
Long Form Audit Report
27. Besides the audit report as per the statutory requirements discussed
above, the terms of appointment of auditors of public sector banks, private sector
banks and foreign banks (as well as their branches), require the auditors to also
furnish a long form audit report (LFAR). The matters which the banks require
their auditors to deal with in the long form audit report have been specified by the
RBI.
28. The LFAR is to be submitted before 30th June every year. To ensure
timely submission of LFAR, proper planning for completion of the LFAR is
required. While the format of LFAR does not require an executive summary to be
given, members may consider providing the same to bring out the key
observations from the whole document.
Reporting to RBI
29. The RBI issued a Circular No. DBS.FGV.(F).No. BC/ 23.08.001/2001-02
dated May 3, 2002 relating to implementation of recommendations of the
Committee on Legal Aspects of Bank Frauds (Mitra Committee) and the
recommendations of the High Level Group set-up by the Central Vigilance
Commission applicable to all scheduled commercial banks (excluding
RRBs).Regarding liability of accounting and auditing profession, the said circular
provided as under:
"If an accounting professional, whether in the course of internal or
external audit or in the process of institutional audit finds anything
susceptible to be fraud or fraudulent activity or act of excess power or
smell any foul play in any transaction, he should refer the matter to the
regulator. Any deliberate failure on the part of the auditor should render
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Accounting and Auditing Framework
himself liable for action".
30. As per the above requirement, the member shall be required to report
the kind of matters stated in the circular to regulator, i.e., RBI. In this regard,
attention of the members is also invited to Clause 1 of Part I of the Second
Schedule to the Chartered Accountants Act, 1949, which states that:
"A chartered accountant in practice shall be deemed guilty of
professional misconduct, if he discloses information acquired in the
course of his professional engagement to any person other than his
client, without the consent of his client or otherwise than as required by
any law for the time being in force."
31. Under the said provision, if a member of the Institute suo motu discloses
any information regarding any actual or possible fraud or foul play to the RBI, the
member would be liable for disciplinary action by the Institute. However, a
member is not held guilty under the said clause if the client explicitly permits the
auditor to disclose the information to a third party. If the above mentioned
requirement of the Circular is included in the letter of appointment (which
constitutes the terms of audit engagement) then it would amount to the explicit
permission by the concerned bank (client) to disclose information to the third
party, i.e., the RBI.
32. Thus, auditors while reporting such a matter to the bank should also
report the matter simultaneously to the Department of Banking Supervision, RBI
provided the terms of audit engagement require him to do so.
33. Auditor should also consider the provisions of SA 250, "Consideration of
Laws and Regulations in an Audit of Financial Statements". Para A19 of the said
Standard explains that the duty of confidentiality may be over-ridden by statute,
law or by courts (For example, the auditor is required to report certain matters of
non-compliance to RBI as per the requirements of the Non-Banking Financial
Companies Auditor's report (Reserve Bank) Directions, 1988, issued by the RBI).
34. RBI has issued a Master Direction on Fraud no.
DBS.CO.CFMC.BC.No.1/23.04.001/2016-17 dated July 1, 2016 (updated July
03, 2017) on "Frauds Classification and Reporting by Commercial banks and
select FIs" on the matters relating to classification and reporting of frauds and
laying down a suitable reporting system. As per the said direction, the primary
responsibility for preventing frauds is that of bank management. Banks are
required to report frauds to the board of directors and also to the RBI.
35. In the aforesaid context, it may be emphasised that such a requirement
does not extend the responsibilities of an auditor in any manner whatsoever as
far as conducting the audit is concerned. The requirement has only extended the
reporting responsibilities of the auditor. As far as conduct of audit is concerned,
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Guidance Note on Audit of Banks (Revised 2019)
the auditor is expected to follow the Standards on Auditing issued by the ICAI
and perform his functions within that framework. SA 240, "The Auditor's
Responsibilities Relating to Fraud in an Audit of Financial Statements" states that
an auditor conducting an audit in accordance with SAs is responsible for
obtaining reasonable assurance that the financial statements taken as a whole
are free from material misstatement, whether caused by fraud or error. Members'
attention is invited to audit procedures as dealt in Chapter 2, "Risk Assessment
and Internal Control" of Part II of the Guidance Note.
36. There are several reporting requirements relating to frauds, if detected,
in LFAR and Ghosh Committee recommendations. The auditor should also refer
to reports of internal auditors, concurrent auditors, inspectors, etc., which may
point out significant weaknesses in the internal control system. Such an
evaluation would also provide the auditor about the likelihood of occurrence of
transaction involving exercise of powers much beyond entrusted to an official. It
must be noted that auditor is not expected to look into each and every
transaction but to evaluate the system as a whole. Therefore, if the auditor while
performing his normal duties comes across any instance, he should report the
matter to the RBI in addition to Chairman/Managing Director/Chief Executive of
the concerned bank.
Reporting of Frauds to Central Government under the
Companies Act, 2013
37. In case of a banking company, in term of provision of section 143(12) of
the Companies Act, 2013:
"Notwithstanding anything contained in this section, if an auditor of a
company in the course of the performance of his duties as auditor, has
reason to believe that an offence of fraud involving such amount or amounts
as may be prescribed, is being or has been committed in the company by its
officers or employees, the auditor shall report the matter to the Central
Government within such time and in such manner as may be prescribed:
Provided that in case of a fraud involving lesser than the specified amount,
the auditor shall report the matter to the audit committee constituted under
section 177 or to the Board in other cases within such time and in such
manner as may be prescribed:
Provided further that the companies, whose auditors have reported frauds
under this sub-section to the audit committee or the Board but not reported to
the Central Government, shall disclose the details about such frauds in the
Board's report in such manner as may be prescribed".
The audit procedure in this regard would be guided by the Guidance Note on
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Reporting on Fraud under Section 143(12) of the Companies Act, 2013,
issued by ICAI.
Audit of Branches
38. Audit of branches of banking companies is required under sub-section
(8) of section 143 of the Companies Act, 2013. It is thus obligatory for a banking
company to get the financial statements of each of its branch offices audited
except where exemption from audit is obtained in respect of certain branches
under the guidelines of the RBI issued from time to time.
39. The branch auditor has the same powers and duties in respect of audit
of financial statements of the branch as those of the central auditors in relation to
audit of head office. The branch auditor's report on the financial statements
examined by him is forwarded to the central auditors with a copy to the
management of the bank. An illustrative format of report of the branch auditor
of a Nationalised Bank is given in the Appendix III of this Guidance Note. The
branch auditor of a public sector bank, private sector bank or foreign bank is also
required to furnish a long form audit report to the bank management and to send
a copy thereof to the central auditors. The central auditors, in preparing their
report on the financial statements of the bank, deal with the branch audit reports
in such manner as they consider necessary. An illustrative format of report of
the branch auditor of a Banking Company is given in the Appendix IV of this
Guidance Note.
40. Some Indian banks also have overseas branches. The audit of financial
statements of these branches is usually carried out by an accountant duly
qualified to act as an auditor of the branch in accordance with the laws and
regulations of the country concerned. The form of audit report is usually
governed by the laws and regulations of the country in which the branch is
situated.
Branch Audit vis-à-vis Audit at Head Office Level
41. There is a significant difference in the scope of audit at a branch of a
bank (conducted by branch auditors) and at head office (conducted by central
auditors) as well as other controlling offices such as zonal offices and regional
offices (usually conducted by central auditors). This difference stems from the
fact that the banking business receiving deposits and making loans and
advances as well as most other banking services take place at the branch
level; in the normal course, the head office and the regional/zonal offices do not
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Guidance Note on Audit of Banks (Revised 2019)
conduct any banking business. They are generally responsible for administrative
and policy decisions which are executed at the branch level. However,
accounting for certain transactions, for example, those relating to treasury
functions (viz., investments, funds management, bill re-discounting) is usually
centralised, i.e., carried out at the head office. Specialised activities like merchant
banking are carried on by separate divisions which operate at the head office
and/or at the large designated branches.
42. The branch auditors furnish their audit reports on the branch financial
statements to central auditors. Branch returns (comprising balance sheet, profit
and loss account and other information relevant for preparation of financial
statements of the bank such as particulars of advances) are also received at the
head office from un-audited branches. Audited as well as un-audited branch
returns are consolidated at the head office. (In some banks, returns pertaining to
a region/zone are sent by the branches to the region/zone concerned and are
consolidated there. The returns received from various regions/ zones are then
consolidated at the head office.)
43. The central auditors, apart from examining consolidation of branch
returns, look into specific matters which are normally not dealt with at the branch
level. These generally include the following:
Depreciation on assets like premises, furniture, fixture, computer assets,
UPS etc., where the recording of the relevant fixed assets is centralised at
the head office.
Valuation of investments, and provisions for depreciation in value thereof.
Provisions in respect of non-performing advances and doubtful elements of
other current assets.
Provision for restructured assets, MTM for fair value etc.
Provisions for gratuity, pension and other retirement benefits.
Provision for payment of bonus or ex-gratia in lieu of bonus.
Provision for Standard Assets.
Provision for interest on overdue term deposits.
Provision for interest on saving bank deposits beyond the date upto which
interest has been provided at the branch level. [For expeditious finalisation
of financial statements of branches, some banks follow the practice of
requiring the branches to provide for interest on savings bank deposits
based on balances therein as at a cut-off (say, 25th March). The interest for
the remaining period is provided at the head office level on an estimated
basis.]
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Provision in respect of losses arising from frauds discovered.
Provision for taxation.
Provision for audit fee.
Provisions to meet any other specific liabilities or contingencies, the amount
of which is material, for example, provision for revision in pay-scales of
employees, provision for foreign exchange fluctuations, etc.
Transfers to reserves.
Dividends.
Any other matter dealt with at the head office.
44. Another area which is of utmost importance for the central auditors in
the present-day context is that related to inter-office reconciliation. Such
reconciliation is mostly centralised at the head office. Each bank has laid down
methods and procedures for reconciling the transactions among the various
offices of the bank.
45. SA 600, `Using the Work of Another Auditor', states that the principal
auditor should consider the significant findings of the other auditor. The central
auditors have to judge whether the observations appearing in the branch
auditor's reports, though considered material at the branch level are material in
the context of the financial statements of the bank as a whole.
46. Generally, in case of private sector banks there are no separate branch
auditors. The statutory auditors appointed are supposed to carry out the entire
audit. RBI requires the auditors to mention about the number of branches visited
and the coverage of business in the audit report.
Other Important Provisions Relating to Accounts and Audit
47. Section 31 of the Banking Regulation Act, 1949 requires publication of
annual accounts (balance sheet and profit and loss account) and auditor's report
thereon in the prescribed manner. It is further required that three copies of the
above-referred documents should be furnished as returns to the RBI within three
months from the end of the period to which they relate. The RBI can extend the
aforesaid period by a further period not exceeding three months. These
requirements are applicable to banking companies, nationalised banks, State
Bank of India, its subsidiaries, and regional rural banks. The regional rural banks
are, however, required to furnish the aforesaid returns to NABARD also.
48. Section 32 of the Act requires a banking company (but not other types
of banks) to furnish three copies of its annual accounts and auditor's report
thereon to the Registrar of Companies at the same time when it furnishes these
documents to the RBI. This is considered compliance with section 137 of the
Companies Act, 2013 also.
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49. Every banking company incorporated outside India is required by
section 33 of the Act, to display, not later than the first Monday in August every
year, in a conspicuous place in its principal office and every branch office in India
a copy of its last audited annual accounts. It has to also similarly display its
complete audited balance sheet and profit and loss account relating to its
banking business as soon as they are available. The aforesaid documents have
to be kept displayed until replaced by subsequent corresponding documents.
Accounting Policies
50. The term `accounting policies' refers to the specific accounting
principles and the methods of applying those principles adopted by an
enterprise in the preparation and presentation of financial statements.
51. The view presented in the financial statements of an enterprise of its
state of affairs and of the profit or loss can be significantly affected by the
accounting policies followed in the preparation and presentation of the
financial statements. The accounting policies followed vary from enterprise
to enterprise. An accounting policy may be significant because of the nature
of the entity's operations even if amounts for current and prior periods are not
material. The principle consideration should be whether disclosure of an
accounting policy would assist users in understanding how transactions,
other events and conditions are reflected in the balance sheet and
profits/loss account.
52. Recognising the need for disclosure of accounting policies by banks,
the RBI has required all scheduled banks to disclose their significant
accounting policies. The accounting policies are required to be disclosed at
one place along with the notes on accounts. A specimen form in which
accounting policies may be disclosed has also been given by the RBI. The
specimen indicates broadly the areas in respect of which the accounting
policies followed by a bank should be disclosed. Banks can, however, make
necessary modifications to suit their individual needs.
53. The specimen form given by the RBI recommends the disclosure of
the fact that the financial statements are prepared on the historical cost basis
and conform to the statutory provisions and practices prevailing in the
country. Besides, disclosure of accounting policies relating to the following
areas is recommended in the specimen form:
a) Transactions involving foreign exchange, viz., monetary assets and
liabilities, non-monetary assets, income and expenditure of Indian
branches in foreign currency and of overseas branches, and profit/loss
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on pending forward contracts.
b) Investments.
c) Provisions in respect of doubtful advances.
d) Fixed assets and depreciation.
e) Staff benefits.
f) Significant provisions deducted in computing net profit, e.g., provision for
income-tax, provision for doubtful advances, etc.
g) Grouping of contingency funds in presenting balance sheet.
54. The specimen form of accounting policies was issued by the RBI in
1991. Since then, the RBI has issued a number of guidelines relating to
income recognition, asset classification, provisioning and investments.
These guidelines have a profound impact on the accounting policies of banks
in the relevant areas. Disclosure of accounting policies formulated by banks
to comply with these guidelines is essential to enable the users to properly
understand the financial statements. Besides, in the case of banks having
overseas branches, the methodology adopted for translating the financial
statements of such branches may also constitute a significant accounting
policy.
Conformity of Accounting Policies with Accounting
Standards
55. The Institute of Chartered Accountants of India (ICAI) issues, from
time to time, Accounting Standards for use in the preparation of general
purpose financial statements issued to the public by such commercial,
industrial or business enterprises as may be specified by the Institute from
time to time and subject to the attest function of its members. The Central
Government has notified the Accounting Standards issued by the Institute of
Chartered Accountants of India under the Companies (Accounting Standards)
Rules, 20064 and Companies (Accounting Standards)Amendment Rules,
2016. Reference may be made to the Announcement "Harmonisation of
various differences between the Accounting Standards issued by the ICAI
and the Accounting Standards notified by the Central Government" issued by
the ICAI. The following is the list of Accounting Standards issued by ICAI and
notified by the Central Government as on 30.10.2017:
4Rule 7(2) of Companies (Accounts) Rule 2014 has clarified that to facilitate proper administration
of the notified sections of the Companies Act 2013, in respect of the Section 133, "Till the
Standards of Accounting or any addendum thereto are prescribed by Central Government in
consultation and recommendation of the National Financial Reporting Authority, the existing
Accounting Standards, notified under the Companies Act, 1956 shall continue to apply."
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Guidance Note on Audit of Banks (Revised 2019)
AS 1 Disclosure of Accounting Policies
AS 2(R) Valuation of Inventories
AS 3 Cash Flow Statements
AS 4(R) Contingencies and Events Occurring After the Balance Sheet
Date
AS 5 Net Profit or Loss for the Period, Prior Period Items and
Changes in Accounting Policies
AS 7 Construction Contracts (Revised-2002)
AS 9 Revenue Recognition
AS 10 (R) Property, Plant and Equipment
AS 11 The Effects of Changes in Foreign Exchange Rates
(Revised-2003)
AS 12 Accounting for Government Grants
AS 13 Accounting for Investments
AS 14(R) Accounting for Amalgamations
AS 15 Employee Benefits(Revised-2005)
AS 16 Borrowing Costs
AS 17 Segment Reporting
AS 18 Related Party Disclosures
AS 19 Leases
AS 20 Earnings Per Share
AS 21(R) Consolidated Financial Statements
AS 22 Accounting for Taxes on Income
AS 23 Accounting for Investments in Associates in Consolidated
Financial Statements
AS 24 Discontinuing Operations
AS 25 Interim Financial Reporting
AS 26 Intangible Assets
AS 27 Financial Reporting of Interests in Joint Ventures
AS 28 Impairment of Assets
AS 29 (R) Provisions, Contingent Liabilities and Contingent Assets
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56. Of the above Standards notified under the Companies (Accounting
Standards) Rules, 20065, presently, the following standards are not
applicable to banks to the extent specified.
(a) AS 13, "Accounting for Investments", does not apply to investments of
banks.
(b) AS 11, "The Effects of Changes in Foreign Exchange Rates", does not
apply to accounting of exchange difference arising on a forward exchange
contract entered to hedge the foreign currency risk of a firm commitment or
a highly probable forecast transaction. However, it shall apply to exchange
differences in respect of all other forward exchange contracts.
57. RBI has issued Circular no. DBOD.No.BP.BC.76/ 21.04.018/2004-05
dated March 15, 2005 and Circular no. DBOD.BP.BC.76/21.04.018/2005-06
dated April 5, 2006, containing the guidelines on compliance with AS 11 (Revised
2003). Further the RBI has issued Circular No.DBR.BP.
BC.No.61/21.04.018/2016-17 which clarifies the accounting treatment for
recognizing gains in profit & loss account from Foreign Currency Translation
Reserve (FCTR) on repatriation of accumulated profits / retained earnings from
overseas branch(es).
Audit of Accounts
58. Sub-section (1) of section 30 of the Banking Regulation Act, 1949
requires that the balance sheet and profit and loss account of a banking
company should be audited by a person duly qualified under any law for the
time being in force to be an auditor of companies. Similar provisions are
contained in the enactments governing nationalised banks [Section 10 of the
Banking Companies (Acquisition and Transfer of Undertakings) Act of
1970/1980], State Bank of India [section 41 of the State Bank of India Act,
1955], subsidiaries of State Bank of India [section 41 of the State Bank of
India (Subsidiary Banks) Act, 1959], and regional rural banks [section 19 of
the Regional Rural Banks Act, 1976]. It is important to note that section 41 of
the State Bank of India Act, 1955, specifically provides that the affairs of the
bank shall be audited by "two or more auditors".
59. Banks operate through a network of branches. The financial
statements of branches (comprising branch's profit and loss account, balance
5Rule 7(2) of Companies (Accounts) Rule 2014 has clarified that to facilitate proper administration
of the notified sections of the Companies Act 2013, in respect of the Section 133, "Till the
Standards of Accounting or any addendum thereto are prescribed by Central Government in
consultation and recommendation of the National Financial Reporting Authority, the existing
Accounting Standards, notified under the Companies Act, 1956 shall continue to apply."
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sheet and various returns to head office) are incorporated in preparing the
financial statements of the bank as a whole. The requirements of section 30
of the Act and the corresponding requirements of other enactments
governing different types of banks, referred above, relate to audit of financial
statements of the bank as a whole and not to audit of financial statements of
branches. The discussion in paragraphs 61 to 67 below & paragraphs 20 to
37 above is also in the context of audit of financial statements of the bank as
a whole. The provisions relating to audit of financial statements of branches
are discussed in paragraphs 38 to 46 above.
60. Further, the members, while carrying out audit of a bank (head office
or branches) are required to comply with the Engagement and Quality
Control Standards issued by the ICAI.
Qualifications of Auditor
61. According to sub-section (1) of section 141 of the Companies Act,
2013, a chartered accountant or a firm whereof majority of partner practicing
in India are qualified for appointment as chartered accountants with their firm
name may be appointed as an auditor of a company. Sub-section (2) of
aforesaid Act provides where a firm including a limited liability partnership is
appointed as an auditor of a company, only the partners who are chartered
accountants shall be authorised to act and sign on behalf of the firm.
However, the following persons shall not be eligible for appointment as an
auditor of a company, namely:
(a) a body corporate other than limited liability partnership;
(b) an officer or employee of the company;
(c) a person who is a partner, or who is in the employment of an officer or
employee of the company;
(d) a person who or his relative or partner-
i. is holding any security of or interest in the company or its subsidiary,
or of its holding or associate company or a subsidiary of such
holding company:
ii. Provided that the relative may hold security or interest in the
company of face value not exceeding one thousand rupees or such
sum as may be prescribed;
iii. is indebted to the company, or its subsidiary, or its holding or
associate company or a subsidiary of such holding company, in
excess of such amount as may be prescribed; or
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iv. has given a guarantee or provided any security in connection with
the indebtedness of any third person to the company, or its
subsidiary, or its holding or associate company or a subsidiary of
such holding company, for such amount as may be prescribed;
(e) a person or a firm who, whether directly or indirectly, has business
relationship with the company, or its subsidiary, or its holding or
associate company or subsidiary of such holding company or associate
company of such nature as may be prescribed;
(f) a person whose relative is a director or is in the employment of the
company as a director or key managerial personnel;
(g) a person who is in full time employment elsewhere or a person or a
partner of a firm holding appointment as its auditor, if such persons or
partner is at the date of such appointment or reappointment holding
appointment as auditor of more than twenty companies;
(h) a person who has been convicted by a court of an offence involving
fraud and a period of ten years has not elapsed from the date of such
conviction;
(i) any person whose subsidiary or associate company or any other form of
entity, is engaged as on the date of appointment in consulting and
specialised services as provided in section 144.
As per sub-section (4) of section 141 of Companies Act, 2013 where a
person appointed as an auditor of a company incurs any of the
disqualifications mentioned in sub-section (3) after his appointment, he shall
vacate his office as such auditor and such vacation shall be deemed to be a
casual vacancy in the office of the auditor.
62. The qualification for appointment as an auditor as prescribed in law
are the minimum qualifications and a regulatory authority (or an individual
bank) may lay down further conditions to determine the eligibility of a
chartered accountant or a firm of chartered accountants for appointment as
an auditor. The further conditions (which, of course, must be reasonable)
may relate to such matters as experience of the chartered accountant
/firm/partners of the firm, staff strength, etc. and may be laid down to ensure
that the chartered accountants/firms of chartered accountants appointed as
auditors possess the requisite skills and resources to carry out the audit
effectively.
Appointment of Auditor
63. As per the provisions of the relevant enactments, the auditor of a
banking company is to be appointed at the annual general meeting of the
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shareholders, whereas the auditor of a nationalised bank is to be appointed
by the bank concerned acting through its Board of Directors. In either case,
approval of the RBI is required before the appointment is made. The auditors
of the State Bank of India are to be appointed by the Comptroller and Auditor
General of India in consultation with the Central Government. The auditors of
the subsidiaries of the State Bank of India are to be appointed by the State
Bank of India. The auditors of regional rural banks are to be appointed by the
bank concerned with the approval of the Central Government.
64. As mentioned earlier, the State Bank of India Act, 1955, specifically
provides for appointment of two or more auditors. Besides, nationalised
banks and subsidiaries of State Bank of India also generally appoint two or
more firms as joint auditors.
Remuneration of Auditor
65. The remuneration of auditor of a banking company is to be fixed in
accordance with the provisions of sub-section (1) & (2) of section 142 of the
Companies Act, 2013 (i.e., by the company in general meeting or in such
manner as the company in general meeting may determine). As per proviso
of sub section (1) of section 142 remuneration of the first auditor may be
fixed by the Board. Further remuneration under sub-section (1) shall, in
addition to the fee payable to an auditor, included the expenses, if any,
incurred by the auditor in connection with the audit of the company and any
facility extended to him but does not include any remuneration paid to him for
any other service rendered by him at the request of the company. The
remuneration of auditors of nationalised banks and State Bank of India is to
be fixed by the RBI in consultation with the Central Government. The
remuneration of auditors of subsidiaries of State Bank of India is to be fixed
by the latter. In the case of regional rural banks, the auditors' remuneration is
to be determined by the bank concerned with the approval of the Central
Government.
Powers of Auditor
66. The auditor of a banking company or of a nationalised bank, State
Bank of India, a subsidiary of State Bank of India, or a regional rural bank
has the same powers as those of a company auditor in the matter of access
to the books, accounts, documents and vouchers. He is also entitled to
require from the officers of the bank such information and explanations as he
may think necessary for the performance of his duties. In the case of a
banking company, he is entitled to receive notice relating to any general
meeting. He is also entitled to attend any general meeting and to be heard
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thereat on any part of the business, which concerns him as an auditor.
67. It is important to note that under section 10 of the Banking
Companies (Acquisition and Transfer of Undertakings) Act, 1970/1980, the
auditor of a nationalised bank may employ accountants or other persons at
the expense of the bank to assist him in audit of accounts. Similar provisions
exist in section 41 of the State Bank of India Act, 1955 and the State Bank of
India (Subsidiary Banks) Act, 1959. These provisions are aimed at facilitating
the work of auditors of these banks by empowering them to appoint the
auditors of branches and are particularly important in the context of the fact
that the above enactments do not contain any specific provisions for audit of
branches of these banks. This is unlike banking companies where audit of
branches is required under sub-section (8) of section 143 of the Companies
Act, 2013. It may be noted that the Regional Rural Banks Act, 1976, does
not contain any provisions relating to audit of branches. Accordingly, in the
case of such banks, audit of branches is also carried out by the auditors
appointed for the bank as a whole.
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3
Accounting Systems
01. An accounting information system (AIS) is a system of collecting, storing
and processing financial and accounting data. Accounting information systems
are designed to support all accounting functions and activities including auditing,
financial accounting & reporting. The accounting systems of different banks vary
in terms of hardware configuration, software capabilities, levels of hardware and
software security, and nature of transactions processed. It is, therefore, not
possible to identify a single accounting system that would describe all the
features of such systems in operation in different banks.
02. SA 315, "Identifying and Assessing the Risks of Material Misstatement
Through Understanding the Entity and Its Environment" lays down that the use of
Information Technology (IT) affects the way control activities are implemented.
From the auditor's perspective, controls over IT system are effective when they
maintain the integrity of the information and the security of the data such systems
process, and includes effective IT controls and application controls. In recent
years, many banks have moved towards computerisation of their operations. The
degree of computerisation, however, varies among different banks and also
among various branches of the same bank. While some branches have been
fully computerised, some others have been partly computerised while many
others are non-computerised.
03. The auditor of a bank needs to obtain an adequate understanding of the
accounting system of the bank to assess the relevance and reliability of the
accounting records and other source data underlying the financial statements. He
should gain an understanding of the books of account and other related records
maintained by the auditee including an understanding of the flow of various kinds
of transactions. He can gain such understanding through enquiries of appropriate
personnel, corroborated by making reference to documents such as accounting
and procedures manual, flow charts, underlying documentary evidence and by
observing the actual conduct of operations.
Salient Features of Accounting Systems of Banks
04. Banks, like most other large-sized entities, follows the mercantile
system of accounting. Thus, the system of recording, classifying and
summarising the transactions in a bank is in substance, no different from that
followed in other entities having similar volume of operations. However, in the
Accounting Systems
case of banks, the need for the ledger accounts, especially those of customers,
being accurate and up-to-date on a real time basis is much stronger than in most
other types of enterprises. A bank cannot afford to ignore its ledgers particularly
those containing the accounts of its customers and has to enter each and every
transaction in its ledgers as soon as it takes place.
05. Banks follow the accounting procedure of `voucher posting' under which
the vouchers are straightaway posted to the individual accounts in the subsidiary
ledgers. Simultaneously, the debit and credit vouchers relating to particular type
of transactions (e.g., savings bank accounts, current accounts, demand loans,
cash credit accounts, etc.)get posted to the respective control account in the
General Ledger. The trial balance of the general ledger is prepared every day.
06. It is imperative to note that most of the banks in the private and public
sector have now networked all or most of their branches in the country which has
over a period of time led to operational and financial efficiencies. Accordingly the
traditional practice of maintaining manual records has largely been discontinued
by online processing of transactions.
07. The accounting system in an enterprise is designed keeping in view the
nature and volume of operations and information needs of management,
regulators and third parties with whom the enterprise has dealings. With the
advent of technology every big bank has customized banking software as per its
own requirement and as such, the accounting systems differ amongst different
banks. The following discussion should, therefore, be construed, as generic in
nature and the auditor should ascertain the exact design of the accounting
system in each auditing situation.
Accounting and Financial Control Manual (`AFCM')
08. The General Ledger (`GL') is the comprehensive repository of the
Bank's financial information and prime source of data for internal and external
reporting. It is imperative that the GL be complete, accurate and all its data valid.
Banks should be encouraged to frame and adopt an AFCM, the primary objective
of which should be to set out comprehensive, unified and standardised GL
controls, standard accounting and financial operating procedures, accounting
policies with the ultimate objective of strengthening the financial reporting and
monitoring processes.
09. The manual should be reviewed centrally at the Head office level on an
on-going basis at-least annually.
10. The salient features of the AFCM should include:
Defining roles and responsibilities for the accounting and finance reporting
team across key departments/ branches;
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Guidance Note on Audit of Banks (Revised 2019)
Laying out the process controls to be applied to processes, procedures and
practices followed by accounting and finance teams; and
Outlining escalation requirements for reconciliations and process
exceptions.
Reconciliation of sub-systems and suspense accounts
11. A Bank uses multiple sub-systems managing certain instruments,
products and offerings for recording business transactions. These subsystems
are electronically interfaced and need to be reconciled with the GL on a daily
basis. There has to be adequate process to review the reconciliation between GL
and the sub-systems highlighting significant unreconciled items, if any, to the
Head office.
12. A sundry suspense account is an account in the general ledger in which
amounts are temporarily recorded. All Sundry Suspense accounts should also be
tracked by the Bank on a regular basis. The Bank should have defined
procedures for reconciling and monitoring sundry/suspense accounts at
periodical intervals and escalating issues, if any, to the concerned departments/
branches for speedy resolution of open items. Suspense account should be
cleared at some point, because they are for temporary use. Suspense accounts
are a control risk which could lead to frauds, errors, issues, etc.
Regulatory reporting to the Reserve Bank of India (`RBI')
13. Large banks generally have a dedicated regulatory reporting team for
the purpose of ensuring appropriate reporting to the RBI. The information for the
purpose of regulatory reporting is sourced from the GL and other subsystems of
the Bank. In case of specific disclosure requirement, information is sourced from
the respective business divisions. The reporting team should maintain an RBI
reporting schedule based on which various reports are compiled and submitted
to the RBI daily, fortnightly, monthly, quarterly and annually after being subject to
a maker-checker process.
Audit Considerations
Information Produced by the Entity (`IPE') and used as Audit
Evidence
14. Audit evidence is all the information used by the auditor in arriving at the
conclusions on which the audit opinion is based and includes the information
contained in the accounting records underlying the financial statements and other
information. Accounting records generally include the records of initial entries
and supporting records, such as cheques and records of electronic fund
transfers; invoices; contracts; the general and subsidiary ledgers, journal entries,
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and other adjustments to the financial statements that are not reflected in formal
journal entries; and records such as worksheets and spreadsheets supporting
cost allocations, computations, reconciliations, and disclosures. The entries in
the accounting records are often initiated, authorized, recorded, processed, and
reported in electronic form. In addition, the accounting records may be part of
integrated systems that share data and support all aspects of the entity's
financial reporting, operations, and compliance objectives.
15. Management is responsible for the preparation of the financial
statements based on the accounting records of the entity. The auditor should
obtain audit evidence by testing the accounting records, for example, through
analysis and review, reperforming procedures followed in the financial reporting
process, and reconciling related types and applications of the same information.
Through the performance of such audit procedures, the auditor may determine
that the accounting records are internally consistent and agree to the financial
statements. However, because accounting records alone do not provide
sufficient appropriate audit evidence on which to base an audit opinion on the
financial statements, the auditor should obtain other audit evidence. Other
information that the auditor may use as audit evidence includes minutes of
meetings; confirmations from third parties; industry analysts' reports; information
obtained by the auditor from such audit procedures as inquiry, observation, and
inspection; and other information developed by or available to the auditor that
permits the auditor to reach conclusions through valid reasoning.
16. IPE is not only used for testing controls relating to assertions on
material classes of transactions, account balances and disclosures but is also
used when performing procedures to evaluate the operating effectiveness of
general IT controls. When evaluating the IPE, it is important to first obtain an
appropriate understanding of the IPE. The auditor should begin with
understanding what the IPE is, how the IPE is generated, and how it is intended
to use as audit evidence. This allows the auditor to design the most appropriate
testing approach to determine whether the IPE is sufficient and appropriate for
purposes of the audit. The auditor should also consider the matters referred in
SA 500 Audit Evidence while testing IPE.
Elements of IPE
17. Information Produced by the Entity (IPE) typically consists of three
elements:
(1) Source data: The information from which the IPE is created. This may
include data maintained in the IT system (e.g., within an application system
or database) or external to the system (e.g., data maintained in an Excel
spreadsheet or manually maintained), which may or may not be subject to
general IT controls.
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(2) Report logic: The computer code, algorithms, or formulas for transforming,
extracting or loading the relevant source data and creating the report.
Report logic may include standardized report programs, user-operated tools
(e.g., query tools and report writers) or Excel spreadsheets, which may or
may not be subject to the general IT controls.
For example, for the Advances Aging report, the report logic is typically a
program in the advances application that contains the code and algorithms
for creating the advances Aging (report) from the individual advances
accounts detail (source data).
(3) Report parameters: Report parameters allow the user to look at only the
information that is of interest to them. Common uses of report parameters
including defining the report structure, specifying or filtering data used in a
report or connecting related reports (data or output) together. Depending on
the report structure, report parameters may be created manually by the
user (user-entered parameters) or they may be pre-set (there is significant
flexibility in the configuration of parameters, depending on the application
system), and they may or may not be subject to the general IT controls.
Understanding the IPE
18. The following questions may assist the auditor in understanding the IPE:
What is the purpose of the IPE?
o If in connection with the operation of a control, does the user depend on
the accuracy and completeness of the information? If not, how is the
user able to validate that the information is accurate and complete?
What is the nature of the IPE?
o Is it a standard or custom report?
o Is the IPE system-generated or manually created? If manually created,
what is the process for creating it?
How is it created?
o What is the relevant source data and where does the source date
reside? Is the source data subject to the general IT controls (e.g.,
access controls)?
o Where does the report logic reside? If system-generated, is the report
logic subject to the general IT controls (e.g. access and program
change controls)?
o Is the report generated through a report writer tool? Is the report writer
tool subject to the general IT controls (e.g. access and program change
controls)?
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Accounting Systems
o What functions are being performed by the report logic, including:
How is the data extracted, transformed or loaded?
Are algorithms or calculations performed on the source data?
Is the information further manipulated after the IPE is generated by
the system?
Is there additional information that is manually added to the report?
o Does the user enter parameters when the IPE is generated? If so what
are the user-entered parameters?
Have any errors been identified in the IPE? If so, what type of errors?
19. When using information produced by the entity the auditor has to
evaluate whether the information is sufficiently reliable for audit purposes,
including as necessary in the circumstances obtaining audit evidence about the
accuracy and completeness of the information. Obtaining audit evidence about
the accuracy and completeness of such information may be performed
concurrently with the actual audit procedure applied to the information when
obtaining such audit evidence is an integral part of the audit procedure itself. In
other situations, the auditor may have obtained audit evidence of the accuracy
and completeness of such information by testing controls over the preparation
and maintenance of the information. In some situations, however, the auditor
may determine that additional audit procedures are needed.
Segregation of Duties
20. A standard approach for preventing fraud and effective control
governance mechanism is to separate employee responsibilities in such a way
that the opportunity to commit fraudulent activities is not available. For
particularly vulnerable functions, it is common to require at least two employees
participate in the functions of initiating, authorizing, recording, processing, and
reporting of transactions. Application owners are responsible for determining who
should have access, and what access privileges are granted. When determining
a user's access privileges, the application owner should validate that segregation
of duties is maintained and that job requirements are fulfilled.
21. The bank may use procedures such as a manual review of access
listings and spreadsheets to compare the access rights granted to users, or
alternatively, may use complex application systems and databases built to
extract, analyse, and identify potential segregation of duties conflicts within the
organization. When new users are added or when current users' change
responsibilities within the organization, these procedures and/or application
systems should be used to evaluate that the user's new access capabilities do
not include the combination of two or more job functions that should be
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Guidance Note on Audit of Banks (Revised 2019)
segregated (representing a segregation of duties conflict).The configuration of
the access privileges within segregation of duties applications and spreadsheets,
and any changes to these privileges, should be approved by management.
Management should periodically review access to these applications. Any issues
noted during the review should be remediated on a timely basis.
22. The auditor can obtain the System Access Report, for each of the
responsibilities defined for the General Ledger module to identify the functions,
menus, and sub-functions by responsibility. The segregation of duties for a
specific client should be determined by obtaining an understanding of the entity's
business processes, including related manual processes and controls.
Journal Entry Testing
23. The term `journal entry' usually refers to "journal entries recorded in the
general ledger and other adjustments made in the preparation of the financial
statements". Journal entry testing is frequently associated with tests for
management override. SA 240 "The Auditor's Responsibilities Relating to Fraud
in an Audit of Financial Statements" requires testing for management override,
which includes:
Testing appropriateness of journal entries.
Reviewing accounting estimates for biases.
Understanding the business rationale for significant transactions that are
outside the normal course of business for the entity.
24. Journal entries may be tested as part of tests of controls or substantive
procedures at assertion level or as part of audit procedures relating to financial
closing process.
25. The auditor should use professional judgment to determine the nature,
timing, and extent of testing of journal entries and other adjustments.
26. For the purposes of identifying and selecting journal entries and other
adjustments for testing and determining the appropriate method of examining the
underlying support for the items selected, the following matters are relevant:
The assessment of the risks of material misstatement due to fraud.
Controls that have been implemented over journal entries and other
adjustments.
The entity's financial reporting process and the nature of evidence that can
be obtained.
The characteristics of fraudulent journal entries or other adjustments.
The nature and complexity of the accounts.
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Accounting Systems
Journal entries or other adjustments processed outside the normal course of
business.
27. SA 315, "Identifying and Assessing the Risks of Material Misstatement
Through Understanding the Entity and Its Environment" lays down that the use of
Information Technology (IT) affects the way control activities are implemented.
From the auditor's perspective, controls over IT system are effective when they
maintain the integrity of the information and the security of the data such systems
process, and includes effective IT controls and application controls. Chapter 3,
"Special Considerations in a CIS Environment" of Part II contains further
guidance on this.
Principal Books of Account
28. The principal books of account, subsidiary books and statistical
records generally maintained by banks are described in the following
paragraphs. It may, however, be emphasised that the exact nature of such
books may differ from one bank to another, depending upon the individual
requirements of each bank.
General Ledger
29. The general ledger contains control accounts of all personal ledgers,
the profit and loss account and different asset and liability accounts. There
are certain additional accounts also (known as contra accounts) which are
kept with a view to keeping control over transactions which have no direct
effect on the assets and liabilities of the bank, and represent the agency
business handled by the bank on which it earns service charges, e.g., letters
of credit opened, bills received or sent for collection, guarantees given, etc.
Profit and Loss Ledger
30. For managerial purposes, the account heads in the profit and loss
ledgers are more detailed than those shown in the published profit and loss
accounts of banks. For example, there are separate accounts for basic
salary, dearness allowance and various other allowances, which are grouped
together in the published accounts. Similarly, various accounts comprising
general charges, interest paid, interest received, etc., are maintained
separately in the profit and loss ledgers.
Subsidiary Books
Personal Ledgers
31. Each control account in the general ledger is supported by a
subsidiary ledger. Thus, in respect of control accounts relating to accounts of
customers, subsidiary ledgers are maintained for:
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Guidance Note on Audit of Banks (Revised 2019)
(a) Various types of deposit accounts (savings bank, current account,
recurring deposits, etc.) which contains accounts of individual customers.
Each account holder is allotted a separate folio in the ledger;
(b) Various types of loan and related accounts (cash credit, term loans,
demand loans, bills purchased and discounted, letters of credit opened,
bank guarantees issued) wherein the liability of each customer is
reflected.
32. Separate registers are maintained to record the particulars of term
deposits (including derivatives like call deposits, certificates of deposits, etc.).
Banks generally do not allot separate folios to each customer. The register is
divided into various sections, each section for a particular period of deposit
and/or the rate of interest payable on deposits. As mentioned earlier,
postings to these registers are made directly from vouchers and all the
vouchers entered in each ledger/register in a day are summarised into
voucher summary sheets. The voucher summary sheets are prepared in the
department which originates the transactions, by persons other than those
who write the ledgers. They are subsequently checked with the vouchers by
persons generally unconnected with the writing of ledgers/registers or the
voucher summary sheets. However, most of the banks are now under Core
Banking and, hence, all the deposits received are automatically recorded in
the respective registers.
Bills Registers
33. Details of different types of bills are kept in separate registers which
have suitable columns. For example, bills purchased, inward bills for
collection, outward bills for collection etc., are entered serially on a daily
basis in separate registers. In the case of bills purchased or discounted,
party-wise details are also kept in normal ledger form. This is done to ensure
that the sanctioned limits of parties are not exceeded.
34. Entries in these registers are made with reference to the original
documents. A voucher for the total amount of the transactions of each day is
prepared in respect of each register. This voucher is entered in the day book.
When a bill is realised or returned, its original entry in the register is marked
off. A daily summary of such realisations or returns is prepared in separate
registers whose totals are taken to vouchers which are posted in the day
book.
35. In respect of bills for collection, contra vouchers reflecting both
sides, i.e., debit and credit, are prepared at the time of the original entry, and
this entry is reversed on realisation.
36. Outstanding entries are summarised at stipulated intervals and their
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Accounting Systems
totals agreed with the balances of the respective control accounts in the
general ledger.
Other Registers/Records
37. There are different registers/records to record detailed particulars of
various types of transactions. These registers/records do not form part of
books of account but support the entries/balances in the various accounts.
Some of the important registers/records relate to the following:
(a) Drafts issued (separate registers may be maintained for drafts issued by
the branch on other branches of the same bank and those on the branches
of its correspondents in India or abroad).
(b) Drafts paid (separate registers may be maintained on the same pattern as
in the case of drafts issued).
(c) Issue and payment of
(i) Telegraphic transfers.
(ii) Mail transfers.
(iii) Bankers' cheques/pay orders/Traveller's cheques/gift cheques
(d) Letters of credit.
(e) Letters of guarantee.
38. Entries in these registers are made from original documents which
are also summarised on vouchers every day. These vouchers are posted into
the day book.
39. Outstanding entries are summarised at stipulated intervals and their
totals agreed with the respective control accounts in the general ledger.
40. There are frequent transactions amongst the branches of the bank
which are settled through the mechanism of inter-office accounts. The
examples of such transactions include payment/realisation of bills/cheques,
etc., sent for collection by one branch to the other, movement of cash
between them, transfer of funds where one branch acts as an agent of the
other, e.g., for governmentrelated business. All such transfers of funds are
channelised through a nodal account (this account has different names in
different banks, e.g., Head Office Account, Inter-office Account, and so on).
This is a crucial account both for banks as well as the auditors for two
reasons first, many frauds have been perpetrated on banks through this
account and second, banks are now required to make provision for entries
routed through this account which remain unreconciled beyond a time period
specified by the RBI.
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41. Banks maintain a Suspense Ledger to record various suspense
accounts. Sometimes, transactions of a transitory nature, e.g., travel
advances to employees, are recorded in a suspense account pending their
adjustment in the related expense/income account. Some banks maintain
separate ledgers for suspense accounts and sundry deposits accounts. The
amounts lying in these accounts need regular monitoring to clear them.
42. Suitable registers with back-up registers to record classification
under numerous sub-heads are maintained for:
(a) Establishment expenses.
(b) Interest and discount income.
(c) Incomes by way of commission.
(d) Interest expenditure.
(e) Provision for interest accrued but not due on deposits.
(f) Fixed assets.
(g) Stationery consumed/in hand.
(h) Interest payable to, and receivable from head office, in respect of
advances and deposits respectively. A peculiar feature of accounting
systems of banks is that the branches, notionally, have no funds of their
own. All deposits accepted at the branch are deemed to have been
passed on to the bank's head office and all loans made at the branch are
deemed to have been made out of funds received from the head office.
The head office pays interest to the branch for its deposits and charges
interest from the branch for its advances. The rates of such interest
charged and paid by head office are decided by the head office during the
course of the year and are an important factor in calculating the profit or
loss of a branch. The mechanism may be known by different names in
different banks. All calculations in this regard are done at the branches
only and suitable entries are passed, generally at the year-end. These
entries, however, get offset in the process of consolidation of accounts
and have no effect on the financial statements of the bank as a whole.
(i) Instruments received from customers for payment/collection by the branch.
Clearing of locally payable instruments is an important function of banks.
Some banks maintain separate registers to record details of various types
of instruments lodged by customers whereas some other banks use a
common book to record all kinds of instruments lodged by customers.
43. Separate registers are maintained to record and summarise the
transactions relating to a particular head of account like Current Account,
Savings Bank, Cash Credit, and Term Loans. Such books may be called Log
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Books, Day Books, etc. The totals in this book are carried over to the Cash
Book.
Departmental Journals
44. Each department of a bank maintains a journal to note the transfer
entries passed by it. These journals are memoranda books only, as all the
entries made there are also made in the day book through voucher summary
sheets. The purpose of such a journal is to maintain a record of all the
transfer entries originated by the department. For example, the loans and
overdrafts department will pass transfer entries for interest charged on
various accounts every month, and as all these entries will be posted in the
journal of that department, the officer concerned can easily find out the
accounts in respect of which the interest entry has been passed. Since all the
vouchers passed during the day are entered into the day book only in a
summary form, it may not be possible to get this information from the day
book without looking into the individual vouchers.
45. As has been mentioned earlier, a `composite voucher' (or two
separate vouchers for debit and credit) is generally prepared for each
transfer entry. The composite voucher is generally prepared by and entered
into the journal of the department which is accordingly credited to the other
department. For example, if any amount is to be transferred from current
account of a customer to his savings bank account, the voucher will be
prepared by the current accounts department and entered in the journal of
that department.
46. Besides the books mentioned above, various departments of a bank
have to maintain a number of books to facilitate their work. Some of the
important departmental books are described below.
Cash Department
47. The following books are usually maintained by the cash department:
(a) Receiving cashiers' cash book
(b) Paying cashiers' cash book
(c) Head cashier's book
(d) Cash balance book
48. Cash Book may have one column, or two or three columns,
depending upon the system adopted by the bank to record cash, transfer and
clearing transactions separately or to treat all of them as cash transactions.
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Guidance Note on Audit of Banks (Revised 2019)
Two points may be noted here:
(a) `Transfer' relates to only those transactions where both debit and credit
transactions are made in the accounts at the same branch and includes
operations on non-customer accounts also. Clearing transactions
essentially relate to customer accounts and the branch handles either
payment or receipt of the underlying amount.
(b) Banks generally maintain a register (commonly called Transfer Scroll)
wherein brief particulars of the debit and credit sides of a transaction are
entered. At the end of the day, the register shows the total value of transfer
transactions handled which has to agree with the `Transfer' column of the
Cash Book, if there is such a system. In the case of a single-column Cash
Book, the total of the day's transactions must agree with the total of cash
and transfer transactions, as per the cash and transfer scrolls of the branch.
49. Banks have introduced different systems to facilitate quick payments
to customers. The most prevalent system is the teller system. Under this
system, the tellers keep both cash as well as ledger cards and the specimen
signature cards of each customer in respect of current and savings bank
accounts. The teller is authorised to make payment up to a particular amount.
On receipt of the cheque, he checks it, passes it for payment, enters in the
ledger card and makes the payment to the customer.
Outward Clearing Department
50. The following books are usually maintained by the outward clearing
department:
(a) Clearing cheques received book for entering cheques received from
customers for clearing;
(b) Bank-wise list of the above cheques, one copy of which is sent to the
clearing house along with the cheques.
Inward Clearing Department
51. The inward clearing department maintains a memorandum book to
record the number of cheques given to each department. Most of the banks
have centralised debiting of inward clearing cheques at the respective
service branches. In such cases, the inward cheques will be retained at the
service branch itself.
Loans and Overdrafts Department
52. The Loans and Overdrafts Department usually maintains the
following books:
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(a) Registers to record details of documents executed by the borrowers and
guarantors in respect of credit facilities
(b) Securities registers for recording details of securities in respect of credit
facilities
(c) Pending documents and document deficiency register
(d) Godown registers maintained by the godown-keepers of the bank
(e) Price register giving the wholesale prices of commodities pledged with the
bank
(f) Overdraft sanction register
(g) Drawing power book
(h) Delivery order books
(i) Storage books
(j) Stock statements registers for loan accounts
(k) Suit filed register
(l) Inspection register for loan accounts
Deposits Department
53. The Deposits Department usually maintains the following books:
(a) Account opening and closing register
(b) Fixed Deposits, Rate Register giving analysis of fixed deposits rates
(c) Due date diary
(d) Specimen signature cards, containing specimen signatures of deposit
account holders.
Establishment Department
54. The Establishment Department usually maintains the following
books:
(a) Salary and allied registers, such as, attendance register, leave register,
overtime register, etc.
(b) Register of fixed assets, e.g., furniture and fixtures, vehicles, etc.
(c) Registers to record receipt, issue and balance of stationery including
security papers, e.g., draft forms, cheque books, etc.
(d) Old records registers.
General
55. Besides the above, banks also maintain the following books:
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(a) Specimen signature book (of the bank's officers).
(b) Private telegraphic code and cyphers.
(c) Back up registers for various types of returns/statements.
(d) Safe Deposit Lockers / Safe Custody registers.
(e) Registers to record particulars of lost instruments (drafts, cheques, etc.)
based on details received from the head office.
(f) Transit books through which instruments are sent to the cash department
for payment by the official authorising such payment.
(g) Registers to record particulars of outstanding inter-office entries received
from the reconciliation department of the bank which are to be responded
to by the branch.
(h) Cheque books issued register.
(i) Token register.
(j) Stop payment register.
Flow of Transactions
56. The books of account and other books and records maintained by
banks have been described above. It is necessary for the auditor to
understand how various kinds of transactions executed by a bank get
reflected in various books. The following paragraphs accordingly provide a
brief overview of the flow of transactions commonly carried out by banks. The
emphasis is on transactions carried out at the branch level since it is at this
level that banking business and most other types of transactions usually take
place.
Customers' Accounts
57. Transactions with customers (both depositors as well as borrowers)
generally account for a substantial proportion of the total transactions at the
branch level. These transactions involve either a credit or a debit to the
respective customer accounts.
Credits to Customers' Accounts
58. The customers may deposit cash, instruments payable at the branch
itself (e.g., cheques issued by other customers of the branch/drafts issued by
another branch of the bank or another bank as per approved arrangement,
which is payable at the branch), or instruments drawn on other branches of
the bank/other banks located within the area of the clearing house of which
the branch is a member. Generally, clearing houses are managed by the RBI
or branches of State Bank of India having currency chest. In some cases, the
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clearing house may be managed by other banks also. Besides, there may be
separate clearing houses managed by the same or by different banks for
MICR (Magnetic Ink Character Recognition) and non-MICR instruments.
Deposits in a customer's account can be made by any other person also
(besides the customer himself).
59. All deposits are made by filling-in the relevant pay-in-slips. All pay-
in-slips have two portions one becomes the voucher for the bank and the
other (the counterfoil) is returned to the depositor as acknowledgement of
deposit.
60. For deposit of cash, the amount is deposited with the cashier
authorised to receive cash who puts a scroll number and his initials on the
voucher as also on the counterfoil. The counterfoil, duly signed and stamped,
is handed over to the depositor and the voucher is eventually sent to the
official responsible for maintaining the customer's account. The official enters
the voucher in the account and puts his initials on it in token of having posted
it in the customer's account. After posting, the voucher is sent to the cash
book section or other section, as per the bank's procedure, which supervises
the work relating to Day Books, at the end of the day.
61. For deposits of `transfer' instruments, there is a designated counter
which receives the pay-in-slips6, tallies the particulars filled in the slip with
the enclosed instruments, returns the duly signed, stamped and dated
counterfoil to the depositor and records the particulars of the customer's
account and the instrument in a register maintained for the purpose. This
register is generally supervised by an official who sends both the pay-in-slip
and the instrument to the desk where the instrument is to be handled, against
the acknowledgement of the receiving official. (It may be clarified that a
number of instruments can be tendered with one pay-in-slip provided they are
all `transfer' transactions, i.e., payable at the branch). The debit instrument is
6 The concept of having cheque drop boxes has also come into vogue wherein banks have almost
done away with the system of having a separate counter for receiving cheques. Instead banks now
maintain a locked cheque drop box in their premises alongwith a receiving acknowledgment stamp
of the bank. The customers now fill up the cheque deposit slip and themselves put the bank's
cheque receiving acknowledgement stamp on the bank's copy of the deposit slip as well as their
own counterfoil and drop the cheque in the box. However, both the options are available to the
customer as RBI Circular No. RPCD.CO.RF.BC.NO./40/07.40.06/2006-07 dated December 26,
2006 on "Cheque Drop Box Facility and the facility for acknowledgement of cheques" requires the
banks to invariably display on the Cheque Drop-Box itself that "Customers can also tender the
cheques at the counter and obtain acknowledgement on the pay-slips". Further, RBI vide its circular
no.DPSS.CO.CHD.No. 485 / 03.06.01 / 2010-11 dated September 1, 2010 on "Dishonour / Return
of Cheques - Need to Mention the 'Date of Return'in the Cheque Return Memo" mandates the
banks to indicate the 'date of return' in the Cheque Return Memo.
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Guidance Note on Audit of Banks (Revised 2019)
posted in the account concerned by the official handling the desk who then
marks it with a `Transfer' stamp with date and sends both the debit and the
credit vouchers to the passing officer. The officer puts his initials or
signatures (as per the procedure in the bank) on both the vouchers.
Thereafter, the credit voucher is sent to the Transfer Scroll in-charge who
records brief particulars of both the debit and the credit vouchers in the scroll
and sends the credit voucher to the desk where the customer's account is
handled. Only the credit voucher `passed' by the competent official is posted
in the account. In case the debit instrument cannot be paid for some reasons
(insufficient funds/post-dated/different signatures/stale/ payment stopped by
the drawer, etc.), the counter clerk records the particulars in a register,
usually called `Cheques Returned' register and seeks instructions from the
branch manager or officer designated by the bank to deal with such matters.
The competent official records his decision (to either pay or return the
instrument) on the register. Normally, in case of payment of such
instruments, the official records `Pay' on the instruments also. If unpaid, the
instrument is returned to the customer.
62. It is possible that there is more than one instrument along with a
single pay-in-slip and these instruments are handled at different desks. In
such cases, though the procedure outlined above is followed for passing the
debit vouchers, the credit voucher may be authenticated, generally, by the
official who passes the last debit voucher. Besides, it is also possible that out
of many debit instruments, only a few are paid and the others returned. This
would mean that the customers' account cannot be credited with the amount
shown in the pay-in-slip. In such cases, banks generally credit the account
with the amount mentioned in the slip and separately raise a debit for the
amount of instruments returned. This is because the banks, on their own,
cannot change the amount in the slip after having given the counterfoil to the
depositor.
63. The customer can also deposit the `clearing' instruments with the
bank. When a customer deposits a clearing instrument with his bank, the
designated desk in-charge checks the voucher and the instruments, gives
stamped, signed and dated counterfoil to the depositor, enters the particulars
in a register maintained for recording the pay-in-slips received from the
customers, and sends the credit voucher along with the instrument to the
clearing section in the branch. Once the clearing section receives
confirmation of payment of an instrument lodged by it in the clearing house
(local clearing usually takes 1-4 days and an instrument is generally deemed
to be cleared if it is not received back within a certain time stipulated for the
purpose, by the clearing house rules), its in-charge passes the credit
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Accounting Systems
vouchers which are sent to the section where the customer's account is
handled, for posting in the customer's account. As regards the instruments
received back unpaid, there are two ways of dealing with them. One is to
credit the customer's account with the amount of pay-in-slip and then to debit
the account with the amount of instruments returned. The other method is not
to post the credit voucher at all and treat it as cancelled; this is, however,
done only in cases where all the instruments lodged along with a particular
pay-in-slip are returned unpaid. Credits also may come from RTGS (Real
Time Gross Settlement), NEFT (National Electronic Fund Transfer) or ECS
(Electronic Clearing System) which do not involve physical movement of
cheques/payment instruments.
64. The customers also deposit various kinds of bills (including
cheques), as under, payable in India or abroad:
Bills for collection (against which the bank does not grant any advance to
the customer).
Bills for negotiation (against which the bank provides advance to the
customers) purchase of demand bills and discounting of usance bills.
65. Bills for collection are generally tendered along with a pay-in-slip
whereas those for negotiation are tendered along with a letter from the
customer. Where the instruments are for collection, these are handled by the
Bills Collection Section. This section or any other designated desk in the
branch accepts the pay-in-slip and the enclosed bills and gives
acknowledgement (counterfoil) to the depositor. The details of the bills are
entered in a Bill Collection Register. Each bill is allotted a distinctive number
which is recorded on all vouchers/documents pertaining to the transaction. A
forwarding schedule (or collection schedule) is prepared giving details of the
instruments like drawee, date of instrument, any special instructions given by
the drawer, etc. The bill is enclosed to this schedule and sent to the branch
which has to collect the proceeds from the drawee. On receipt of the advice
of the payment of the bill, the originating branch credits the customer's
account with the amount of the bill paid (less any charges deducted by the
collecting branch) and simultaneously recovers its own commission for
handling the transaction by debit to the customer's account. The procedure
stated above is common to both the demand and usance bills, though
nomenclature of the registers and the forwarding schedules used for the
purpose may be different.
66. As regards the bills tendered for negotiation, the transaction may
relate to either the customers who have been granted regular limits for the
facility or those who need this facility only occasionally. In the latter case, the
bank would have prescribed an authority to approve the negotiation.
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Guidance Note on Audit of Banks (Revised 2019)
Generally, bills are submitted by customers along with a forwarding letter
while the cheques are submitted with a pay-in-slip, along with a request to
negotiate the same. The cases of regular limits are handled by the Loan
Section and the official dealing with the accounts or other designated
authority approves the bills for negotiation after ensuring that the limit can
accommodate the bills or that, in case of any overdrawing, these have been
permitted by a competent authority. The bills negotiated are entered in the
Purchase/Discount registers and the customer's bill account. Like the
collection schedule, the Purchase/ Discount schedules are prepared and sent
along with the bills to the branch concerned for realisation. The amount of the
bills negotiated is immediately credited to the customer's account, after
deducting the prescribed bank charges. In due course, on receipt of payment
of the bills, along with overdue interest (if the bills are paid by the drawees
after the due dates) or on return of the bills, if unpaid, the entry in the
customer's account is reversed. In case of return, the amount of the bill,
together with overdue interest at the rates prescribed by the bank, is
recovered from the customer. The negotiation of the bills can also be done
under the letters of credit (LCs) issued by a bank in favour of the customer.
The accounting procedure in case of negotiation under LC is the same as
explained above, however, the recording of such bills may be done in a
separate set of registers. The negotiating branch also maintains a record of
the due dates of bills negotiated and follows up with the realising branches if
the proceeds are not received in time.
67. The accounting procedure for export bills whether for collection or
for negotiation is essentially the same as that for domestic bills as
discussed above; the books and registers may, however, have different
names and columns, as these transactions involve conversion of a foreign
currency into Indian rupees.
68. Some credits are made in customers' accounts by the bank itself,
the most common example being the periodic interest on a deposit account
and refund of any excess recoveries made earlier. In such cases, the bank
may prepare either the pay-in-slip or the plain credit voucher. These
vouchers also follow the same route as for those tendered by the customers
except that such vouchers are not entered in the register meant for recording
the instruments lodged by customers.
69. The cardinal principle followed by banks is that the credit is given to
the customer only after the corresponding debit has been approved by an
authorised official at the branch.
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Accounting Systems
Debits to Customers' Accounts
70. In respect of a running account (mainly current/savings bank/cash
credit), the most common source of debit is the cheque (or withdrawal form in
the case of a savings bank account) or a letter of authority signed by the
customer or RTGS/NEFT. In case the customer or the holder of the
instrument wants to withdraw cash against this instrument, he presents it to
the designated counter which maintains the ledger containing the drawer's
account and, in acknowledgement, is given a token bearing a distinctive
number. The counter staff records the token number on the instrument and
obtains the presenter's signatures on the reverse of the instrument. He then
verifies the balance in the account (credit balance in deposit accounts and
limit sanctioned in advances accounts). If it is sufficient to meet the amount
mentioned in the instrument, he posts it in the account, puts his initials on the
instrument in token of having posted it and marks it with a `pay cash' stamp.
The instrument is then sent to the official in charge of that particular counter
for authorising the payment. He authorises the payment of the instrument by
signing it which serves as an instruction to the cash department to pay the
amount to the presenter of the instrument. Each passing official maintains a
payment scroll in which he records the account no., token no. and amount of
the instrument passed by him. The serial number at which a particular
instrument is noted in the official's scroll is recorded on the instrument also.
Thereafter, duly passed instrument is sent for payment to the cash
department in a `passed voucher book' or `transit voucher book'. The paying
cashier acknowledges the receipt of the instrument by initialling the relative
entry in the book which is returned to the passing official. The cashier obtains
the token from the presenter as also his signatures on the reverse of the
instrument which is an acknowledgement of receipt of amount by the
presenter and makes payment to him. The particulars of payment including
the denomination of notes/coins given in payment are recorded in the
cashier's scroll. The serial number in the scroll at which the payment is
entered is also recorded on the instrument and the `cash paid' stamp affixed
on it under signatures or initials of the cashier.
71. The customer may want to purchase an instrument/receipt like
Demand Draft, Mail Transfer, Telegraphic Transfer, Pay Order, Banker's
cheque, Term Deposit, Call Deposit, Travellers' cheque, Gift cheque, or any
other similar product of the bank, or make any payment to the government.
For the purpose, he tenders the debit instrument (cheque/authority letter,
etc.) at the counter where his account is maintained, along with the
appropriate credit voucher duly filled in (application form, pay-in-slip, challan,
etc.). The counter staff verifies that the vouchers are in order and that
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Guidance Note on Audit of Banks (Revised 2019)
sufficient balance is available in the account. He then posts the instrument in
the account and the same procedure, as in case of cash payments, is
followed upto the stage of authorisation by the official concerned except that
instead of a `Pay Cash' stamp, a `Transfer' stamp is put by the counter staff
on both the instrument and the credit voucher there against. After passing the
debit and the credit vouchers, the official sends all the vouchers to the
transfer scroll desk where the particulars of all the debit and credit vouchers
are recorded and the credit vouchers sent to the respective desks which
handle those products.
72. Customer's accounts are debited on account of instruments received
in clearing also. All the instruments received through the clearing house,
which are payable at the branch, are received by the clearing section and
handed over to the desks concerned against acknowledgement. Subsequent
procedure is the same as for transfer instruments except that there is no
credit voucher with the instrument. The passing official has only to pass the
debit instruments which bear the clearing stamp of the bank presenting them.
The consolidated credit voucher is passed by the clearing section in-charge.
73. In case the counter staff notices that the balance in the account is
inadequate to pay the instrument or the instrument is defective, he has to
seek the instructions of the designated authority through the Cheques
Returned Register.
74. Paragraphs 70 to 72 above deal with cases where the customer's
account is debited on account of the instruments signed by him. In addition,
there are cases in which the bank raises the debits to the customer's account
on its own (though, of course, under intimation to the customer). The
examples of such debits are:
Carrying out the standing instructions received from the customer
(including charges for executing these instructions).
Payment of bills under letters of credit opened by the branch on behalf of
the customer.
Payment for guarantees issued at the request of the customer, which are
duly invoked by the beneficiary.
Periodic interest on loan accounts.
Rectification of any erroneous entry in the account.
Recovery of bank charges for which the bank holds an express or implied
authority like loan application processing charges, ledger fees, inspection
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Accounting Systems
charges, locker rent, ATM annual charges, bill handling charges, issue of
duplicate drafts etc., noting of `stop payment instructions' given by the
customer, return of cheques issued by the customer due to insufficiency of
funds in the account, and so on.
75. A separate mention deserves to be made of the bills received by the
branch for collection from its customer (being the drawee of the bill). On
receipt of such a bill, the branch sends intimation to the drawee giving the
details of the bill. The drawee presents a debit instrument for the amount to
be paid (bill amount plus bank charges plus overdue interest, if applicable) to
the Bills Section at the branch, along with the intimation received by him from
the branch. He does not submit any credit voucher to the branch in such
cases. The credit vouchers are internal to the branch and are prepared by
the branch itself. The debit instrument given by the customer is processed
like any other `transfer' instrument, as discussed above.
76. Two points should be kept in view with regard to debits to the
customers' account:
Only the customers or their duly constituted attorneys can authorise a
debit to the account (unlike a credit which can be made by any person).
Debit instrument has to be passed first and the credit voucher only
thereafter.
Issue of Drafts
77. Each bank has its own standard application form which has to be
filled in by the applicant. Many banks have opened service branches at
important centres. Wherever such branches exist, the outstation branches
are instructed to draw the drafts only on them. In some cases, the drafts may
be made payable on other banks also if there is such an arrangement
between the issuing bank and the paying bank. Such type of transactions are
quite common in international banking area.
78. If the customer wants to tender cash for purchase of the draft, he
tenders the draft application and the required amount of cash (amount of
draft and the bank commission) to the cashier concerned. The cashier, after
making necessary entries in his books, releases the voucher which is sent to
the drafts issue desk. The counter staff prepares the draft as per the
customer's instructions, enters it in the Drafts Issued register, gets it signed
by an authorised official, and hands it over to the applicant against his
acknowledgement.
79. If the customer wants a draft against a transfer transaction
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Guidance Note on Audit of Banks (Revised 2019)
(generally, a cheque drawn on his account), the voucher is prepared after the
customer's account has been debited.
80. The branch may, at times, need to issue drafts (or banker's cheque
or pay order) on its own account, e.g., for remittance of proceeds of a bill
received for collection directly from the drawer of the bill. In such cases, the
draft application is signed on behalf of the bank, giving particulars of the Bill
No. paid; the remaining procedure is the same as described above.
81. In respect of drafts issued, an advice is generally sent to the drawee
branch. Besides, some banks have a system whereby issue of drafts above
a prescribed amount is also confirmed to the drawee branch by a coded
telegram/by telephone or in any other mode.
82. Some important points to be noted with regard to issue of drafts are
as follows:
For drafts of small value (based on the cut-off level fixed by the bank), the
advice regarding issue of draft may not be sent to the drawee branch.
Some banks also fix a ceiling upto which the draft may be signed by a
single official. Beyond this level, normally two officials have to sign the
draft. Besides, the specimen signature, number of the official(s) signing the
draft has to be mentioned on the draft.
There is generally a ceiling (fixed by the RBI in consultation with the
Central Government) upto which the drafts can be issued against deposit
of cash. The ceiling may undergo revision from time to time.
83. At the end of the day, the counter staff works out the total amount of
drafts issued on that day and the commission earned thereon. This figure is
carried over to the Cash Book.
Issue of Mail Transfer/Telegraphic Transfer
84. These are two other modes of remittance of funds from one place to
the other. The difference between the two is in the manner of transmission.
Mail Transfer (MT) is sent by post to the paying branch whereas Telegraphic
Transfer (TT) is sent by telegram (these days, some banks use fax also).
MTs and TTs differ from drafts only in one respect. MTs/TTs are sent to the
paying centre by the branch itself (under intimation to the customer) whereas
draft is handed over to the customer who arranges to send it to the
beneficiary. In terms of procedure, MTs/TTs are similar to draft.
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Issue of Pay Orders/Banker's Cheques
85. These instruments are normally issued for local payments including
local payments to be made by the issuing branch itself. The procedure is
basically the same as for issue of drafts except that no advice is required.
Issue of Term Deposit/Call Deposits and Receipts and Similar
Instruments
86. These instruments are issued in favour of the customers only and
are akin to other accounts of the customers except that these are not running
accounts (these days, however, some banks have developed hybrid products
which contain features of term deposit, saving bank account and current
account. For example, many banks have now started offering a facility of
automatic transfer of the amount standing to the credit of the savings account
of a customer to a fixed deposit account, subject to a certain minimum
balance left therein. As and when the customer needs to withdraw an
amount or issues an instrument of a value higher than the minimum balance
in his account, the bank automatically transfers amount from the fixed deposit
account to his savings account). Upto the point of receipt of credit voucher in
the TDFR section, the procedure is same as that for credit to any other
account of a customer. After receipt of the credit voucher, the procedure is
generally on the following lines:
(a) The receipt is prepared in the bank's pre-printed standard format and
contains the name of the account holder, the mode of payment of
proceeds on maturity, the term of deposit, the interest rate, and the due
date.
(b) In case the amount has been deposited under Re-investment Scheme,
this fact is mentioned on the receipt. The maturity amount is also
mentioned.
(c) Banks normally have separate sections in their Term Deposit registers,
interest rate-wise and/or maturity period-wise, to record the issue of term
deposit receipts in a chronological order.
(d) The official in charge of the term deposit section verifies the particulars on
the receipt with reference to the deposit voucher, and signs the receipt
which is then delivered to the depositor against acknowledgement.
(e) The banks maintain a Daily List to record the due dates of deposits as
also the dates of payment of periodic interest on deposits, wherever
applicable. Necessary entries are made in the list upon issuance of a term
deposit receipt.
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87. Instruments other than term deposit receipts (e.g., cash certificates)
are entered in the relevant register in a similar manner.
Opening of Letters of Credit
88. Generally, this facility is provided by banks to their regular borrowers
but there is no bar on extending this facility to other applicants also. The
procedure for opening of letters of credit in either case is generally on the
following lines:
(a) The applicant submits an application in the prescribed format to the
branch wherein he mentions the name of the beneficiary, documents
required from the beneficiary, and the expiry date of the validity of the
letter of credit (LC) for the purpose of shipment as well as negotiation of
documents by a bank.
(b) In case the bank agrees and issues the LC, it makes contra entries in its
books. Necessary vouchers are prepared by the LC section. Normally, a
composite voucher is used for these entries.
(c) The transaction is recorded in the LC Issued Register. In the case of
customers who have been sanctioned regular LC limits (like a cash credit
limit), to ensure that the outstanding LCs do not exceed the sanctioned
limit, all issues of LCs are debited to the account (all payments or
cancellations of LC are credited).
(d) LC opening charges are recovered from the customer, either by debit to
his account or in cash.
(e) Banks generally maintain margin for each LC. It may be retained in any
form in current account, term deposit, lien on drawing power, etc.
(f) LC is prepared by the bank on pre-printed formats of the bank. Each LC
has a distinctive number. The original (which is a negotiable copy) and
one or two non-negotiable copies of the LC are sent to a bank (known as
`advising bank') for transmitting it to the beneficiary. Copies of the LC are
given to the applicant also and at least one copy is retained on the branch
records.
(g) The number of officials who have to sign the LC may differ from bank to
bank.
89. In terms of issue procedure, there is hardly any difference between
an inland LC and a foreign LC. However, foreign LCs can be issued only by
branches authorised to undertake foreign exchange transactions. Also,
foreign LCs outstanding at the year-end require re-statement in rupee terms.
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90. On 13th March, 2018 RBI vide Notification RBI/2017-18/139 A.P. (DIR
Series) Circular No. 20 decided to discontinue the practice of issuance of
LOU's/ LoCs/guarantees for Trade Credit for imports into India by AD-
Category Banks with immediate effect. Letters of Credit and Bank
Guarantees for Trade Credits for imports into India may continue to be issued
subject to compliance with the provisions contained in Department of Banking
Regulation Master Circular No. DBR. No. Dir. BC.11/13.03.00/2015-16 dated
July 1, 2015 on "Guarantees and Co-acceptances", as amended from time to
time.
Issue of Bank Guarantees
91. In terms of procedure, bank guarantees are similar to LCs. However,
the original guarantee is also handed over to the applicant who submits it to
the beneficiary. Also, bank guarantees are issued on non-judicial stamp
papers whereas LCs are issued in bank's pre-printed formats.
Issue of Traveller's Cheques/Gift Cheques
92. There are prescribed application forms for these cheques and the
procedure for issue is similar to issue of banker's cheques. However, in the
case of Traveller's Cheques, the applicant has to sign on the cheque once in
the presence of the bank's authorised official. The branch may issue
Travellers' Cheques of its own bank and/or those of its correspondents in
terms of an approved arrangement.
93. In each bank, there is a nodal office for Traveller's Cheques.
Particulars of all cheques issued by the branch are required to be advised by
the branch to the nodal office through the inter-office accounting system. The
Branches do not normally have a Traveller's Cheques account in their
General Ledger as they act merely as agent of the nodal office in issuing
(and paying) Traveller's Cheques.
94. Gift cheques are payable by the issuing branch only. Each branch
maintains a Gift Cheques account. All issues are credited to the account and
details of the cheques entered in a register. Payments are debited to this
account. For the sake of operational convenience, the Gift Cheques register
is divided into separate sections, denomination-wise.
Payment of Drafts
95. The drafts issued by banks are invariably payable `to order' and
never `to bearer' since the issuance of drafts as `payable to bearer' would
tantamount to issuing currency, which banks are not authorised to do.
96. When a draft is presented to the branch on which it is made payable
(whether for payment in cash or transfer to an account at the same branch or
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through the clearing house), the instrument is sent to the Drafts Payment
Section. The section usually maintains two kinds of Drafts Paid Registers:
(a) To record payment of drafts for which no advice is required from the
issuing branch as per the bank's procedure.
(b) To record payment of drafts for which the aforesaid advice is required.
97. The counter staff enters the particulars in the relevant register after
ensuring the prima facie correctness of the draft, particularly the drawee
branch code number. In respect of drafts falling in category (b) above, though
the advice from the issuing branch is required, the branch has to make
payment of the draft even if it has not received its advice from the issuing
branch till the time of payment. The advices received are marked off in the
drafts paid register at the time of payment if advice has been received, or
later, on receipt of the advice. For those entries in the register in respect of
which the advice is not received, the matter is followed up with the issuing
branch. After recording the particulars of the draft in the register, it is sent to
the official in-charge along with the draft for verification of the correctness
and for authorising the payment (in cash or by credit to the customer's
account). The subsequent procedure is the same as that for other payment
instruments. It may be mentioned here that separate registers are maintained
for payment of drafts drawn by the correspondent banks.
98. Banks generally have a Drafts account to which all drafts issued are
credited and all payments debited. Some banks have separate accounts for
`Drafts Issued' and `Drafts Paid'.
99. Sometimes, the buyer of the draft may want to have it cancelled.
This can be done only by the issuing branch. In addition to the usual
procedures for payment of drafts, the following steps are also required to be
taken:
(a) The fact that it is a case of cancellation is mentioned in the Drafts Paid
Register and against the relative entry in the Drafts Issued Register.
(b) It is a common practice amongst banks to obtain a receipt from the buyer
of the draft by endorsement on its reverse.
100. At the end of the day, a summary of the total drafts paid is prepared.
This figure is carried over to the Cash Book.
Payment of MTs/TTs
101. As soon as the MTs are received by the branch, these are paid by
crediting the account mentioned in the MT. These are entered in an MT paid
register and the day's total of the register is debited to an inter-office
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account. The treatment of TTs is slightly different. The advice of remittance
sent by telegram is followed by a written advice signed by the authorised
officials of the issuing branch. Payment of TTs is also routed through the
inter-office account. As the signed advices are generally not available when
the telegraphic advice reaches the paying branch, the payment may be
effected by debit to the Suspense Account or an Items in-Transit Account and
the account of the beneficiary, stated in the TT, credited. Besides the above,
the transaction is also recorded in TTs Paid Register. All entries in this
register show the date of receipt of the signed advice from the issuing
branch.
102. MTs and TTs are not paid in cash; they are credited to the accounts
of the payees maintained at the branch; in case the payee does not maintain
account with the branch, a Pay Order is issued in his favour.
103 The entry in Suspense Account/Items in-Transit Account is adjusted
on receipt of advice from the issuing branch.
Payment of Banker's Cheques/Pay Orders
104. The procedure followed is similar to payment of any other cheque
drawn on the branch, except that the date of payment is recorded against the
original issue entry.
Payment of Term Deposit Receipts and Similar Instruments
105. These instruments are `Not Transferable' and have to be paid strictly
in accordance with the mandate of the deposit-holder received at the time of
acceptance of the deposit or as modified subsequently by the deposit-holder.
The deposit may be repaid before maturity (at the request of the account
holder), on the date of maturity, or after the date of maturity. The salient
features of the payment procedure are as under:
(a) The deposit receipt, duly discharged, has to be presented for payment. In
case the receipt is in the custody of the branch (under lien for any loan or
as margin for any facility), it is withdrawn by making necessary entries in
the Safe Custody Ledger/Register.
(b) The deposit may be repaid in cash (subject to any ceiling on such cash
payments, under statutory or regulatory requirements) or by way of a
`transfer' transaction. As these receipts are not negotiable, these are not
routed through the clearing house but sent to the issuing branch for
collection of proceeds.
(c) The `transfer' transaction is either for renewal of the deposit or for credit in
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full or part to any account maintained at the branch, or for issue of draft
/MT/TT/Pay order, etc.
(d) The payment is recorded as a debit to the relevant deposit account and
the date of payment recorded against the original entry of issue. The
principal amount of the deposit is debited to the deposit account to which
it was credited at the time of issue. Interest paid is debited to the
concerned provision account for the deposit if such an account is created
by the bank or to the account in which such provision is held (amount of
interest paid is net of TDS, if applicable). In this regard, it may be noted
that generally, the branches create an Interest Provision Account for all
interest-bearing deposits to which the amounts calculated at the rates
advised by the Head Office are credited every month. This is done to
arrive at the profit/loss of the branch and to calculate the bank's liability
on an ongoing basis. All payments during the day are totalled and carried
over to the Cash Book.
(e) Banks generally do not hold the matured deposits in their regular deposit
accounts. On the due dates, those deposits which remain unpaid are
transferred in a separate account, usually called as `Overdue Deposits
Account'. These deposits are eventually paid or renewed.
(f) For deposits paid before their scheduled maturity, interest is paid only for
the actual period of deposit and not the contracted period. Also, banks
may decide to levy some penalty for premature payment.
(g) Normally, for each renewal of the original deposit, banks issue a fresh
deposit receipt. Of late, however, some banks have started the facility of
automatic renewal of deposits on the due dates and may not issue any
fresh receipt but just record the fact of renewal on the original receipt.
(h) The deposits are freely transferable at the request of the depositors from one
branch of the bank to another. In such cases, the issuing branch transfers the
deposit amount, together with the accrued interest amount held in its books,
to the transferee branch along with an advice of transfer (the funds may be
remitted by draft/TT/any other mode as per the Bank's procedure).
Payment of Recurring Deposits
106. Banks provide a Pass Book to the depositor wherein entries are
made at the time of deposit or later, as demanded by the account holder. At
the time of payment (before/on/after maturity), the depositor has to produce
this Pass Book to the branch to record the fact of closure of the account.
Generally, banks have a provision to recover from the interest payable on the
deposit a specified sum for late deposit of any instalment under the scheme.
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At the time of payment, the principal amount deposited is debited to the
Recurring Deposit Account and the interest paid is debited to the concerned
interest provision account. The procedure for payment in cash/by transfer is
the same as in the case of Term Deposits.
Payment of Call Deposits
107. Most of the call deposits are required by the customers for
submission to various authorities like Excise & Customs, PWD, Railways,
etc., in connection with their tenders/orders. The deposits are in the names of
these authorities only and not in the names of the customers. For payment of
such deposits to the customers, the banks demand a release letter or an
authority letter from the authority in whose favour the deposit was issued.
These deposits are, generally, non-interest bearing. The procedure for
payment is the same as in the case of Term Deposits.
Payments under Letters of Credit
108. Payments under letters of credit involve:
(a) Payment of the bills by the branch named in the LC as the `negotiating
bank'. Such payment may be made even in a case where no such name
is mentioned in the LC.
(b) Eventual payment of the bills by the LC opening branch to the negotiating
bank.
109. In some cases, the same branch may act as both the LC opening
bank and the negotiating bank, i.e., it opens the LC for customer `A' in favour
of `B' and also negotiates bills under the same LC when presented by `B' who
may or may not be an existing customer of the branch. The procedure for
payment of the bills, described below, is equally applicable to both the cases.
However, for the sake of clear understanding, the terms `Opening Bank' (OB)
and the `Negotiating Bank' (NB) have been used though it is recognised that
in some cases, the same branch may perform the functions of both of them.
(a) The original LC is in the custody of the customer, i.e., the beneficiary of
the LC. He may approach any bank to negotiate the documents if there is
no NB designated in the LC. The bank may agree to the request or may
refuse it. In case the NB has been designated, the customer has to
approach that bank only. This bank cannot generally refuse negotiation
because its name would have been mentioned only in accordance with an
approved arrangement.
(b) The customer has to produce the original LC and all the documents
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stipulated in the LC to the NB.
(c) NB examines all the documents and compares them with what has been
stipulated in the LC. NB also ensures that the shipment took place within
the validity mentioned in the LC and that the documents have been
presented for negotiation within the validity stipulated in the LC. If there is
any difference in compliance with the terms and conditions mentioned in
the LC, the OB may refuse to make payment to NB.
(d) In case NB observes certain discrepancies in the documents submitted by
the customer, it may still decide to negotiate them at the risk of the
customer. Such negotiations are referred to as `negotiations under
reserve' in the banking parlance. In such cases, NB obtains a written
undertaking from the customer to make good the amount (together with
bank charges) if payment is ultimately refused by OB. Another common
practice for such bills is that before negotiation, NB brings the
discrepancies to the notice of OB and seeks instructions. In turn, OB
seeks the customer's instructions which are conveyed to NB.
(e) Once a decision to negotiate has been taken by the branch, it enters the
particulars of the bills in a Bill Negotiation Register (generally, banks
maintain a separate register for negotiation under LCs). A distinctive
number is allotted to each negotiation which is recorded on each
document of the bill. The date and amount of negotiation are mentioned
on the reverse of the LC and signed by an authorised official. Charges on
negotiation are to be borne by the party mentioned in the LC it may be
either the beneficiary or the opener of the LC. In case the beneficiary has
to bear the charges, the bank will deduct these charges from the bill
amount and pay only the net amount to the customer. In case the charges
are to the opener's account, the NB will pay the bill amount to the
customer and claim the bill amount plus the negotiation charges from OB.
The account to be debited by NB at the time of negotiation is different in
different situations, as under:
(i) In case of demand LCs, where OB and NB are the same bank, the
LC would generally state that NB should debit the OB through the
inter-office account on negotiation. For usance LCs in this situation,
the LCs normally authorise NB to debit the OB, through the inter-
office account, on due date of the bill. In the latter case, the NB
normally debits its own Bills account (may be called Bills Discounted
account) at the time of negotiation the entry is reversed on the due
date by debiting OB through the inter-office account.
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(ii) In case of LCs (both demand and usance) where OB and NB are
different banks, the LC itself states the manner in which the NB
should obtain reimbursement of the bills negotiated from the OB.
The NB acts accordingly. Pending receipt of reimbursement, the NB
generally keeps the debit in its own Bills Account.
110. After negotiation, the documents are sent by NB to OB for final
payment. When the documents are received at the OB, the procedure
followed is on the following lines:
(a) The designated section at the branch records receipt of bills in a specified
register.
(b) The documents received from NB are compared with the terms of the LC.
In case of any discrepancy, it is immediately brought to the notice of the
NB as well as the opener. The branch seeks instructions of the customer
whether he wants to accept the documents despite these discrepancies or
not.
(c) In case the documents are discrepant and are not acceptable to the
customer, OB returns the entire set of documents unpaid to NB. In turn,
NB recovers the amount of bill, its own charges as also the charges levied
by OB, if any, from the beneficiary of the LC. The fact of return is
recorded by the OB in its registers.
(d) In case the bill is in order or the discrepancies are acceptable to the
customer, OB recovers the amount of bill and the other charges, if any,
from the customer.
(e) In addition to the above debit and credit entries, the contra entries made
at the time of issue of LC are also reversed by the amount of LC utilised
on payment of bills. This is done by way of a composite voucher. Besides,
the amount and date of payment are recorded in the LC register and the
Bill register.
(f) On expiry of the validity of the LC, the OB waits for a reasonable period
from that date for receipt of negotiated documents from NB. In case no
documents are received, the OB reverses the amount of unutilised LC in
its contra accounts.
(g) In case the beneficiary does not want the bills to be negotiated and
instead, wants these to be sent for collection by his bank, he may do so.
The accounting procedure at OB in this case is broadly similar to
negotiated bills.
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Payments Under Bank Guarantees
111. The following procedure is followed where the customer fails to
discharge his contractual obligations and the beneficiary invokes the
guarantee:
(a) The section handling the guarantees business at the branch examines the
notice of invocation to ascertain that it is strictly in accordance with the
terms of the guarantee. The branches generally seek legal opinion on the
issue either from inside or outside.
(b) In case the invocation is not in order, suitable reply is sent to the
beneficiary.
(c) In case the invocation is in order, the amount demanded by the
beneficiary, not exceeding the amount guaranteed, is remitted to the
beneficiary. The contra entry in the Bank Guarantee Account, made at the
time of issue of the guarantee, is reversed by the total amount of the
guarantee if the guarantee has been treated as fully discharged by the
beneficiary, notwithstanding that the amount actually paid is different. The
branch, in turn, recovers the amount from the customer.
(d) In case the beneficiary does not want the bills to be negotiated and
instead, wants these to be sent for collection by his bank, he may do so.
The accounting procedure at OB in this case is broadly similar to that
followed in the case of negotiated bills.
Payments Under Deferred Payment Guarantees
112. On due dates of instalments, the bank remits the principal and the
interest due to the beneficiary. Procedurally, payments under deferred
payment guarantees are similar to payments under the bank guarantees or
under LC. One distinctive feature is that the bank's liability to the beneficiary
and the corresponding liability of the customer to the bank get reduced with
each payment. On each such payment, the contra entries are reversed by the
amount paid.
Payment of Gift Cheques
113. These cheques are honoured by all branches of a bank irrespective
of the branch which has issued them. In case the cheque is presented to the
issuing branch for payment, the branch records the payment in its Gift
Cheques Register. The date of payment is mentioned against the relative
issue entry also. The other procedures are the same for as payment of any
other cheque. The amount of gift cheques paid during a day is debited to the
Gift Cheques Account.
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114. In case the cheque is presented to any other branch of the bank, it is
paid by that branch by way of a debit to the issuing branch through the inter-
office account.
Payment of Traveller's Cheques
115. Mostly, these cheques are presented for payment in cash by the
purchaser of the cheque. In some cases, where the hotels, merchant
establishments, etc., accept these cheques in payment of their bills, they
obtain signatures along with date from the customers and then deposit these
cheques with their bank for payment.
116. When presented for payment in cash, these are presented to the
paying cashier in whose presence the customer has to put his signatures with
date. The cashier tallies these signatures with the first signatures appearing
on the cheque (which were obtained in the issuing branch) and, on being
satisfied about the genuineness of the transaction, makes the payment. In
the process, he may also refer to the list of lost/stolen Traveller's Cheques
available at the branch, which is received from the head office. The amount
of all cheques paid during the day is debited to the nodal office designated
for these cheques. In case payment of cheques is by way of a transfer
transaction, the desk concerned records the particulars of payment in a
register and the official in-charge authorises the credit voucher; the debit
voucher is normally prepared at the end of the day for all Traveller's Cheques
paid on that day.
117. It is possible in some cases that the customer may deposit the
unused Traveller's Cheques with the issuing branch itself. In such cases
also, the procedure is similar to that for other `transfer' transactions.
Cash Transactions
118. Many of the transactions described above involve receipt or payment
of cash by the bank. In describing such transactions above, the emphasis
has been on the other aspect of each transaction rather than on cash
receipt/payment. The following paragraphs deal with flow of cash
transactions receipts as well as payments primarily from the angle of
accounting for, and controls over, cash receipts and payments irrespective of
the nature of transaction giving rise to cash receipt or cash payment.
119. `Receipt' and `payment' of currency are two of the most important
functions of a bank. `Cashiers' and `tellers' perform these functions. The
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tellers provide only limited services (types of services and monetary ceiling
may differ from bank to bank) while cashiers have no such limitations. The
tellers do not generally make payments out of loan accounts. Cash and other
valuable items like security forms are kept in the strong room and held in the
joint custody of two or more officials of the branch, one of whom is the Head
Cashier and the other, normally, the Accountant.
120. Currency notes are packed in packets of 100 pieces each,
irrespective of the denomination. A slip is put on each packet which carries
the initials or signatures of the staff members who have verified and re-
verified the quality and quantity of the notes, along with the date of such
checking (the procedure may vary slightly among different banks). Coins are
stocked in bags. These are weighed and then valued according to a specific
weight-value ratio for each type of coin.
121. Depending upon the possession and ownership of cash, branches
are divided into three categories:
(a) Currency Chest Branches: These branches hold cash as an agent of RBI.
Each chest branch is linked to a currency office of RBI through a link
branch of its own bank. Loose packets are not kept in the chest. Every
day, the branch withdraws cash from and deposits cash into the chest
according to its requirements. At the end of the day, the branch works out
the net position as compared to the previous day's closing balance in the
chest and sends an advice to link branch (the position of the repository
branches is also included, as explained later). The balances in the chest
are periodically verified by the bank's officials as well as by RBI officials.
Even in a currency chest, the branch will maintain some cash in hand on
its own account, though such balance may be nominal.
(b) Repository Branches: These branches carry smaller cash holding than the
chest branches but act as a part of the chest. They are linked to a chest
branch and report the net withdrawal/net deposit position each day to the
link branch.
(c) Hand Balance Branches: These branches carry cash only as their own
hand balances. The limit for peak holding at such branches on any day is
fixed by their controlling authorities. Whenever the branch has any
surplus cash, it deposits the amount with a currency chest branch.
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Receipts
122. The steps involved in physical receipt of cash and its accounting are
as follows:
(a) The cash tendered by the depositor is checked by the cashier for the
genuineness of the notes and to cross check the number of notes as
mentioned by the depositor in the pay-in-slip.
(b) If found in order, the cashier records the particulars of notes received and
the account to be credited in the book maintained by him (usually called
Cashier's Receipt Scroll). He then puts `Cash Received' stamp on the
pay-in-slip and the counterfoil and signs them; the counterfoil is returned
to the depositor.
(c) The pay-in-slips are sent from the cash department to a desk which notes
down all receipts of cash in the department in a jotting book. The total of
this book thus reflects the total cash received at the branch during the
day.
(d) After noting in the jotting book, the voucher is sent to the concerned desk
for credit to the relevant account.
(e) After the day's transactions are over, all the receiving cashiers hand over
the cash, which should agree with the total of cash receipt scroll, to the
Head Cashier.
(f) Banks also deposit cash with other banks, usually for credit to their
accounts. At times, the receiving branch is unable to cope up with the
volume of work and does not count all the notes on the same day. In such
circumstances, the uncounted amount is held as a `Bond' system in which
the depositing bank gives a written confirmation of the correctness of the
amount and undertakes to make good the shortage, if found during the
actual counting later. This amount may be counted at the convenience of
both the banks in due course.
123. The steps involved in making cash payments and their accounting
are as follows:
(a) All paying cashiers (including tellers) are given some amount of cash at
the start of the day by the Head Cashier against acknowledgement for
their expected requirements during the day. They may be given cash in
instalments also during the course of the day. They receive instruments
for payment either directly at the counter (for tellers) or instruments
authorised for payment through the voucher books (for cashiers). They
obtain the signatures/thumb impression of the person receiving the
payment. Each payment is recorded in a payment scroll maintained by
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each paying cashier and teller. The instruments paid by the tellers are
then sent to the concerned desks for debiting the relevant accounts and
authorisation by the officials' in-charge of the desks. The instruments paid
by cashiers are sent to the desk which carried out the Day Book related
work at the end of the day.
(b) After the day's transactions are over, the cashiers return the cash balance
with them to the Head Cashier. The balance should agree with the books,
i.e., cash received by the cashier less the total of his payment scroll.
124. The `receipts' and `payments' have been discussed above separately
for the sake of a clear understanding. In practice, a single cashier may
perform both the activities. Likewise, a single teller may receive cash, pay
cash, issue drafts, pay Traveller's Cheques, and so on.
125. After accounting for all the cash received from the cashiers, the
Head Cashier prepares a summary of the day's transactions and the cash
balance register and signs them. If any excess cash is found during counting,
the amount is held in a special account and is refunded to the genuine
claimant on demand or if there is no such claimant, the bank treats it as
income. However, shortage in cash has to be made good by the cashiers
concerned and the matter has to be reported to the higher authorities.
126. The currency chest branches meet their requirement of notes by
remittances from the RBI. They also send remittances of soiled notes in their
custody to RBI from time to time. In case RBI comes across any shortage in
the remittance sent to it during counting in the presence of a cashier from the
remitting branch, it informs the branch which has to make good the amount.
Incomplete Records
127. In some situations, the auditor may find that certain accounting and
other records are not up-to-date. In such a situation, the auditor should first
ascertain the extent of arrears in house-keeping, and the areas in which
accounting and other records are not up-to-date. In case it is found that the
General Ledger, the main cash book, or the trial balances are in arrears or
that they do not tally, the auditor should consider expressing a qualified
opinion, adverse opinion or disclaimer of opinion, as may be appropriate in
the circumstances. In case any subsidiary ledgers are in arrears, the auditor
should consider the impact of such arrears on the financial statements of the
bank. It may be pointed out that in the absence of balanced and up-to-date
subsidiary ledgers, verification of transactions or of year-end balances may
become difficult. In such cases also, the auditor should consider expressing a
qualified opinion, adverse opinion or disclaimer of opinion, as may be
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appropriate in the circumstances. It may also be noted that in Long Form
Audit Report (LFAR), the auditor has to make detailed observations on such
arrears of house-keeping. Therefore, from this point of view also, it is
important for the auditor to satisfy himself about the completeness of all
records before submitting his audit report.
CIS Systems in Banks
128. CIS(Computer Information Systems) systems of different banks differ
in terms of hardware configuration, software capabilities, levels of hardware
and software security, and nature of transactions processed. It is, therefore,
not possible to identify a single CIS system that would describe all the
features of such systems in operation in different banks. However, the
following description of the CIS system of a large bank illustrates the usual
manner of computerised information processing and the various controls built
into the CIS system. Auditor should check the accuracy, correctness of data
and also see that data has been correctly transferred from the previous years
audited statements and for this he need to go through the audit trail of
modifications/change made. Most of the Banks are working on Core banking
now a days and hence the accounting system under the same and the control
in place for the same are very important from the bank's perspective as well
as from auditors perspective.
Controls
129. The system provides for a number of controls which seek to ensure
that the system is not put to unauthorised use, the transactions entered in the
system are valid and accurate, and exceptional matters as well as other
significant matters are reported on a timely basis or preferably on a daily
basis to ensure early prevention of error and frauds. For example, the
following controls seek to ensure that the system is not put to unauthorised
use:
A valid login name and password are essential to enter the system.
A user can login from a specified workstation only.
A minimum password length is required.
The password needs to be changed at least once during a prescribed
period.
The maximum number of attempts to enter the system from a workstation
is specified. Thus, if an incorrect password(s) is entered from a
workstation, as soon as the number of attempts reaches the specified
limit, the user is locked out and a message to this effect, identifying the
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workstation, is flashed on the system administrator's console/other
workstations.
Access to the system is available only between stipulated hours and
specified days only.
Individual users can access only specified directories and files.
The access to various menus (such as opening of an account, closing of
an account, change in limit or drawing power in a cash credit account,
interest rate change, cheque book issue, etc.) is controlled through
passwords. Thus, while an operator may enter the system using his login
name and password, he cannot access the menus that have been
password protected for use by systems administrator only.
The access to systems software is restricted through password protection.
(The systems software contains several utilities such as copy, delete, etc.
that can be used for unauthorised copying or deletion of files.)
Exception situations such as limit excess, reactivating dormant accounts,
etc., can be handled only with a valid supervisory level password.
A user timeout is prescribed. If the keyboard of a workstation remains
inactive for the specified duration (say 30 seconds), the user has to re-
enter the system using his password. This control prevents any
unauthorised use when a workstation is left unattended.
Wherever any rectification or alteration is carried out by more than one
level of the officers, such alterations or changes are made as an additional
entry and not by changing or deleting an existing recorded entry.
Once the end-of-the-day process is over, the ledgers cannot be opened
without a supervisory level password.
The system maintains a record of all log-ins and log-outs. The access to
this record is not possible without the systems administrator's password.
130. Similarly, the following controls seek to ensure the validity and
accuracy of transactions entered in the system.
The operation instructions such as single operation, joint operation, either
or survivor operation, are flashed on the screen when the account is
accessed.
The system checks for cheque number range and stop payment
instructions before processing a transaction.
The system checks whether the amount to be withdrawn is within the
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drawing power.
The system flashes a message if the balance in a lien account would fall
below the lien amount after the processing of the transaction. The
transaction processing is halted and can be proceeded with only with a
supervisory password.
If the transaction is sought to be posted to a dormant (or inoperative)
account, the processing is halted and can be proceeded only with a
supervisory password.
131. The branch manager is required to send a certificate to the
controlling authority at stipulated intervals regarding the functioning of the
entire computerised system including compliance with prescribed procedures
and processes.
Structure
132. The system is multi-currency, on-line real time system which allows
accounts to be maintained in a number of currencies. A separate General
Ledger is maintained for each currency.
133. While the General Ledger (GL) provides the topmost level in
aggregation of transactions and balances, the lowest level is a detail account
which may be a customer's account or other account such as commission on
drafts, locker rent, bill handling charges, etc. The number of levels between
the GL and detail accounts is dependent on the requirements of the
management and may differ from system to system. In the system under
discussion, the GL (for each currency) is divided into a number of `controls'
each of which in turn is divided into a number of the `memos'. A `control' is
similar to a General Ledger Account in a manual system, with the difference
that unlike a GL account in the manual system to which debit and credit
transactions can be posted directly, a control is merely a sub-division of the
GL and is not an account. For example, `Current Account' is one of the
`controls'. `Memos' provide sub-divisions of a `control'. For example, separate
memos under `Current Accounts' may be maintained for commercial and
institutional customers' Current Accounts, agriculture-sector current
accounts, and so on. The number of `controls' that can be opened under
General Ledger for each currency and the number of memos that can be
opened under a control may differ from system to system (in the system
under discussion, the maximum number of controls is 36 while the maximum
number of memos under each control is 1296.). Detail accounts are opened
under a memo. For example, all current accounts of C & I will be opened
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under the memo `Current Account (C & I)'.
134. A transaction is posted to a detail account only. The detail account
balances are updated as the transactions take place, i.e., on a real-time
basis. The control and memo balances are updated only at the end of the
day. All the books are balanced every day.
`Start-of-the-Day' Process
135. Each computerised branch has one or two designated officials to
perform the role of the Systems Administrator. The computer operations
every day begins with a `start-of-the-day' (SOD) process carried out by the
System Administrator. Unless SOD is completed, the system cannot be used
for data entry. Among the major activities undertaken by the system as part
of SOD are changing the date, clearing the log files, diary processing interest
application in those accounts where it is due on that day, deposits due for
payment on the day, standing orders7, and list of stopped cheques/drafts8.
Recording of Transactions
136. As already stated, the transactions are processed on a real-time
based on vouchers. The debit and credit aspects of a transaction have to be
posted to the respective ledger accounts simultaneously in all cases. The
accounts to which the credit aspect of a transaction is to be posted get
updated simultaneously when the account to which the debit pertains is
posted.
Single Transaction Update of Multiple Computer Files
137. A single transaction input into a CIS system may automatically
update all records associated with the transaction. For example, if credit
voucher for issue of a Fixed Deposit is input, information in the following
types of records will get entered simultaneously and automatically:
FD day book
Customer's account (if a running account for issue of FDs is maintained in
7 Some customers give standing instructions to the bank to make certain remittances on pre-
determined dates. The system will generate a list of those standing instructions which are to be
carried out on that day.
8 In some cases, the customers may have advised the bank not to make payments of certain
cheques issued by them. These instructions are duly recorded in the system upon receipt from the
customers. Besides, it may happen that the bank itself may stop payment of certain instruments, in
particular drafts, if some draft forms are lost or stolen. Particulars of such instruments are entered
in the system and these are treated as stopped instruments.
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Accounting Systems
terms of the Bank's system)
Daily list (to record payment of periodic interest and repayment of
principal)
Classification of deposit into proper interest rate profile and maturity profile
FD interest account
138. Single transaction update of multiple files ensures that all relevant
records are kept up-to-date. However, it also implies that if one erroneous
input is made, many records will contain errors.
Vulnerability of Data and Program Storage Media
139. Floppy disks, magnetic tapes, hard disks, etc. the usual media on
which data and programs are stored are susceptible to intentional or
accidental destruction. Portable media are also particularly prone to theft,
loss, etc., as well as to computer virus. The vulnerability of CIS systems
requires extensive internal controls against thefts, loss, and destruction or
unauthorised alteration of programs and data.
On-line Checking
140. All transactions posted at a terminal by an operator need to be
checked by a supervisor on-line as soon as practicable after its entry to
ensure that the data has been correctly fed into the system. All checked
transactions are marked by the supervisory with his ID. (Usually, the
operator, while posting the voucher, indicates the ID of the supervisor who
has to authenticate the entry. When the supervisor opens the screen, he will
find `yes/no' command against the entry under a suitable heading for
authenticating it. If he presses `y' the entry is taken as passed.)
`End-of-the-Day' Process
141. After all the transactions for the day have been inputted and passed
by the supervisor concerned; the 'end-of-the-day' (EOD) process begins.
EOD involves the following major activities:
Verification of the integrity of all the transactions entered in the system by
comparing the total of balances in detail accounts under each memo with
the aggregate of the opening balance of memo and the transactions for the
day. Similar checking is done for integrity of memos by comparing the total
of all memos under a control with the updated balance of the control.
Diary processing.
Interest re-calculation and interest accrual.
Standing orders.
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Generating statements of account.
Generating various types of reports, including exception reports.
Printing of logs.
Daybook printing.
While the SOD or EOD processes are on, the system does not allow any data
entry.
Backups
142. After EOD, the stipulated numbers of backups are taken on the
prescribed media. The system provides for off-site backup of at least one
copy of the updated data. The backup is required to be retained as part of the
branch records as per the policy formulated by the bank for retention of
records.
Exception Reports and Other Reports
143. The generation of exception reports is an important aspect of the
system. These reports relate to cases which deserve the attention of
appropriate levels of branch management. While most of these reports relate
to operational aspects of transactions, some relate to the functioning of the
CIS system. Besides, some other reports are also generated for the purposes
of record. Some of the major reports generated by the system daily are:
Debit/credit balance change
Value dated before last rate change
Value dated before last interest application date
Maturity record deleted
Automatically generated accounts
Inactive accounts
Dormant accounts reactivated
Excess allowed over the limits/drawing power
Irregular term loan accounts with number of arrears of instalments and
interest with amounts
Debits to income head account
Debits to head office accounts
Overdue pre-shipment and post-shipment accounts
Overdue bills and bills returned
Withdrawals against clearings
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Time barred demand promissory notes
Unchecked transactions
Sign-on attempt from two terminals
Exit to operating system
Password errors
Sign-on report
Sign-off report
Deposit accounts debit balances
Zero balance and non-zero accrued interest accounts9
Debit balance accounts without interest rate
Loans and advances credit balances
Temporary overdrafts allowed beyond the sanction period.
Items pending in clearing.
Inter-branch transactions with age-wise details.10
Computerised Accounting and Core Banking Solutions
144. In the preceding paragraphs, the conventional book keeping and
manual accounting practises were discussed. The developments in the field
of user-friendly systems and solutions have brought a sea change in the
accounting atmosphere in the banking industry. Systems and solutions have
been developed to cater to the banking requirements without compromising
on the basic principle of integrity of information and recording of each and
every transaction at any stage. Banks cannot afford to have an error level of
even 0.0001% and hence the solutions have been developed to maintain the
sterile levels.
145. These systems and solutions are generally audited, reviewed and
9 This relates to closed advances account. Whenever an account is closed, it should be squared off
together with the interest due thereon till the date of closure. It may sometimes happen that the
account may be brought to nil balance but the accrued interest may remain unrealised. As the
system calculates the accrued interest everyday as part of the SOD process, it will show the
accounts of the above type as unusual.
10 Banks have an `inter-branch-items-in-transit' account wherein the entries are parked when a
telegraphic advice is received from the other branch. These entries are reversed in the IBIT
account by debit to `Branch Clearing General Account' when the normal advice in the bank's
prescribed format, duly signed, is received from the other branch by post. Such advices must be
received within a reasonable time after the telegraphic advice. The intention behind the report in
question is to keep a check on the receipt of written advices for such items kept in IBIT account.
The age-wise details will show whether the entry has been outstanding in the IBIT account for less
than 15 days, more than 30 days, more than 90 days or so on. Such entries require special
attention because non or delayed receipt of advices may indicate fraud or other malpractices.
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examined at frequent intervals by the banks to ensure correctness of the
data. The banks generally document such reviews and these documents
would throw light on the effectiveness of the accounting system of the bank
and reliability of its accounting data.
146. SA 315, "Identifying and Assessing the Risks of Material
Misstatement through Understanding the Entity and Its Environment" lays
down that the use of Information Technology (IT) affects the way control
activities are implemented. From the auditor's perspective, controls over IT
system are effective when they maintain the integrity of the information and
the security of the data such systems process, and includes effective IT
controls and application controls. In recent years, many banks have moved
towards computerisation of their operations. The degree of computerisation,
however, varies among different banks and also among various branches of
the same bank. While some branches have been fully computerised, some
others have been partly computerised while many others are non-
computerised. In fully computerised branches, all the customers' transactions
as well as internal transactions of the bank, which enter the books of the
account of the branch, are routed through a computer system, which may
comprise either a computer network or stand-alone personal computers.
147. It may be stated here that even in a fully computerised branch, some
work is presently carried out manually, e.g., preparation of vouchers,
preparation of letters of credit and guarantees, preparation of some returns and
statements, etc. In partly computerised branches, generally the back-office
work (i.e., the internal processing of transactions of the branch) is carried out
on computers whereas the customers' transactions (i.e., the front-office work)
are processed manually. Many of the banks in the private sector have
networked all or most of their branches in the country; this has given them the
capability of handling most of the transactions of their customers at any of the
branches.
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4
Legal Framework
01. There is an elaborate legal framework governing the functioning of
banks in India. The principal enactments which govern the functioning of various
types of banks are:
Banking Regulation Act, 1949.
State Bank of India Act, 1955.
Companies Act, 2013.
State Bank of India (Subsidiary Banks) Act, 1959.
Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970.
Regional Rural Banks Act, 1976.
Banking Companies (Acquisition and Transfer of Undertakings) Act, 1980.
Information Technology Act, 2000.
Prevention of Money Laundering Act, 2002.
Securitisation and Reconstruction of Financial Assets and Enforcement of
Security Interest Act, 2002.
Credit Information Companies Regulation Act, 2005.
Payment and Settlement Systems Act, 2007.
Insolvency and Bankruptcy Code, 2016.
02. Besides, the above enactments, the provisions of the Reserve Bank of
India Act, 1934, also affect the functioning of banks. The Act gives wide powers
to the RBI to give directions to banks which also have considerable effect on the
functioning of banks.
Guidance Note on Audit of Banks (Revised 2019)
Salient Provisions of the Banking Regulation Act, 194911
03. Of the above Acts, the Banking Regulation Act, 1949 (hereinafter referred
to as "the Act"), is the most important as it affects the functioning of all institutions
carrying on banking business whereas the other enactments relate only to certain
specific type(s) of banks. Some of the important provisions of the Act are briefly
described below, since familiarity with them is essential for the performance of the
duties of an auditor. It may, however, be emphasised that the ensuing discussion is
not an exhaustive discussion on all the relevant provisions of the Act. It may also
be noted that some of the provisions discussed hereunder are not applicable to
certain types of banks in view of there being specific provisions with regard to the
relevant matters in the respective principal statutes governing their functioning.
Sec 4: Power to Suspend Operation of the Act
04. On a representation made by the RBI in this behalf, the Central
Government may suspend the operation of the Act or of any provision thereof for
a period up to 60 days either generally or in relation to any specified banking
company. In case of a special emergency, the Governor of the RBI or, in his
absence, any authorised Deputy Governor may also, similarly, suspend such
operation for a period up to 30 days. In either case, the Central Government has
a power to extend the period of suspension, from time to time, but the said
extension should not exceed a period of 60 days at any one time. The total
period of suspension cannot, however, exceed one year.
Sec 5(b): Banking
05. `Banking' is defined as "the accepting, for the purpose of lending or
investment, of deposits of money from the public, repayable on demand or
otherwise, and withdrawable by cheque, draft, order or otherwise".
Sec 5(c): Banking Companies
06. A banking company means "any company which transacts the business
of banking in India". The term `company' for this purpose covers companies
registered in India as well as foreign companies. It has been clarified that any
company which is engaged in the manufacturing of goods or carries on any
11
RBI vide its Circular No. DBOD.NO.PSBD.BC.62/16.13.100/2013-14 on "Amendments to
Banking Regulation Act, 1949 Banking Laws (Amendment) Act, 2012- Applicability to private
sector banks" dated October 23, 2013 advised that amendments by Banking Laws (Amendment)
Act, 2012 are binding on banks notwithstanding any clauses to the contrary contained in the
Memorandum of Association (MoA) and Articles of Association (AoA) of the banks. Banks are
therefore, advised to make necessary amendments in the MoA and AoA.
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Legal Framework
trade, and which accepts deposits of money from the public merely for the
purpose of financing its business as such manufacturer or trader, shall not be
deemed to transact the business of banking [Explanation to section 5(c)].
Sec 6: Forms of Business
07. Section 6 of the Act permits a banking company to engage in certain
forms of business in addition to the business of banking. Besides the forms of
business specifically listed in clauses (a) of sub-section (1) of section 6, a
banking company may do "all such other things as are incidental or conducive to
the promotion or advancement of the business of the company" [clause (n) of
sub-section (1) of section 6]. Under clause (o), a banking company may engage
in any other form of business (besides those covered by other clauses), which
the Central Government may, by notification in the Official Gazette, specify as a
form of business in which it is lawful for a banking company to engage.
08. Under sub-section (2) of section 6, a banking company is prohibited
from entering into any form of business other than those covered by sub-section
(1) of the said section. Section 8 specifically prohibits a banking company from
buying, selling or bartering of goods except in connection with the realisation of a
security held by it. It also prohibits a banking company from engaging in any
trade of buying/selling or bartering of goods for others except in connection with
collecting or negotiating bills of exchange or in connection with undertaking the
administration of estates as executor, trustee or otherwise. However, the above
prohibitions are not applicable to any business specified by the Central
Government in pursuance of clause (o) of sub-section (1) of section 6.
Sec 11, 12 and 13: Requirements as to Minimum Paid-up Capital and
Reserves and Regulation of Capital
09. Section 11 of the Act lays down the requirements as to minimum paid-up
capital and reserves. Different limits have been laid down for banking companies
incorporated outside India and other banking companies. Under section 12, the
capital of a banking company can consist of ordinary (i.e., equity) shares only,
except where preference shares have been issued prior to July 1, 1944 or where
the banking company has been incorporated before January 15, 193712. Section 13
restricts the pay out; either directly, or indirectly, of commission, brokerage,
discount or remuneration in any form in respect of any shares issued by a banking
company to two and one-half percent of the paid-up value of the said shares.
12The attention of the members is also invited to RBI's circular no. DBOD.BP.BC.42/21.01.002/
2007-08 of October 29, 2007 on "Guidelines for issuing preference shares as part of regulatory
capital".
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Guidance Note on Audit of Banks (Revised 2019)
Sec 14 and 14A: Prohibition on Creation of Charge on Unpaid Capital
10. A banking company is prohibited from creating any charge on their un-
paid shares. A banking company is also prohibited from creating floating charge
on the undertaking or any property of the company or any part thereof unless the
creation of such floating charge is certified in writing by the RBI as not being
detrimental to the interest of the depositors of such company.
Sec 15: Restriction on Payment of Dividend
11. No banking company shall pay any dividend on its shares until all its
capitalised expenses (including preliminary expenses, organisation expenses,
share-selling commission, brokerage, amount of losses incurred and any other
item of expenditure not represented by tangible assets) have been completely
written off. A banking company may, however, pay dividends on its shares
without writing off:
a. Depreciation, if any, in the value of Investments in approved securities
where such depreciation has not been capitalised or otherwise accounted
for as loss,
b. Depreciation, if any, in the value of its investments in shares, debentures or
bonds where adequate provision for such depreciation has been made to
the satisfaction of the auditors,
c. Bad debts, if any, where adequate provision for such bad debts has been
made to the satisfaction of the auditors.
Sec 17: Reserve Fund
12. Every banking company incorporated in India is required to transfer out
of the balance of profit of each year as disclosed in the Profit and Loss account
to reserve fund, a sum equivalent to not less than 20% of its profit before
declaration of dividend. Central Government may on recommendation of the RBI
having regard to adequacy of its paid up capital and reserves declare in writing
that the provisions of Section 17(1) shall not apply to the banking company.
Where a banking company appropriates any sum or sums from the reserve fund
or the share premium account, it shall report the fact to the RBI.
Sec 18: Cash Reserve
13. Every banking company, other than a schedule bank , is required to
maintain in India a cash reserve with itself or by way of balance in a current
account with the RBI, 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 per cent of the
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Legal Framework
total of its demand and time liabilities in India as on the last Friday of the second
preceding fortnight.
14. Such companies are also required to submit to the RBI 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.
Sec 19: Restriction on Nature of Subsidiary Companies
15. A banking company is prohibited from forming a subsidiary company
except for the following purposes:
a. For undertaking any of the businesses which, under clauses (a) to (o) of
Section 6(3), is permissible for a banking company,
b. With the previous approval of RBI in writing for carrying on of the business
of banking exclusively outside India,
c. For undertaking of such other business, which RBI may, with the prior
approval of the Central Government, consider conducive to the spreading of
banking in India or to be otherwise useful or necessary in public interest.
16. A banking company shall not hold shares in any other company other
than the subsidiary, whether as pledgee, mortgagee or absolute owner of an
amount exceeding 30% of the paid up share capital of that company or 30% of its
own paid up share capital and free reserves, whichever is less. No shares shall
be held as pledgee, mortgagee or absolute owner in any company, other than a
subsidiary company, in the management of which any managing director or
manager of the banking company is in any manner concerned or interested.
Sec 20 and 21: Restriction on Loans and Advances
17. Section 20 of the Banking Regulation Act, 1949, (hereinafter referred to
as `the Act') lays down restrictions on loans and advances by banks. Apart from
banking companies, nationalised banks, State Bank of India, its subsidiaries, and
regional rural banks are also covered by this section. Accordingly, none of these
banks can grant loans and advances in the following circumstances:
(a) on the security of its own shares;
(b) to or on behalf of any of its directors;
(c) to any firm in which any of its directors is interested as a partner, manager,
employee or guarantor;
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Guidance Note on Audit of Banks (Revised 2019)
(d) any company of which, or of a subsidiary of the holding company of which,
any of the directors of the bank is a director, manager, employee or
guarantor or in which he holds substantial interest. This restriction,
however, does not apply to the following companies:
(i) a subsidiary of the banking company;
(ii) a company registered under section 8 of the Companies Act, 2013;
and
(iii) a government company.
(e) any individual in respect of whom any of its directors is a partner or
guarantor.
18. Under section 20(5) of the Act, the RBI has been empowered to clarify
whether any transaction is a loan or advance for the purpose of this section and
the decision of RBI thereon shall be final. In doing so, the RBI would consider the
nature of the transaction, the period within which and the manner and the
circumstances in which, any amount due on account of the transaction is likely to
be realised, the interest of the depositors and other relevant considerations. In
exercise of this power, the RBI has, vide its circulars
DBOD.No.Dir.BC.4/13.03.00/2012-13 dated July 2, 2012 and
DBR.Dir.BC.No.38/13.03.00/2015-16 dated September 16, 2015 excluded
certain loans to directors from the purview of section 20.
19. Under section 20A of the Act, a banking company is prohibited from
remitting, wholly or partly, the debts due to it by certain persons without obtaining
the prior approval of the RBI. Any such remission made without the prior
approval of the RBI is void and ineffective. The persons specified in this behalf
are:
(a) any director of the banking company;
(b) any firm or company in which any director is interested as director, partner,
managing agent or guarantor; and
(c) any individual if any director of the bank is his partner or guarantor.
The above prohibition also applies to nationalised banks, State Bank of India, its
subsidiaries, and regional rural banks.
20. Under section 21 of the Act, the RBI has the power to determine the
policy in relation to advances to be followed by banking companies generally, or
by any banking company in particular. In particular, the RBI can give directions
to banking companies regarding:
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Legal Framework
(a) the purposes for which advances may or may not be made;
(b) the margins to be maintained in respect of secured advances;
(c) the maximum amount of advances or other financial accommodation which
may be made by a banking company to any one company, firm, association
of persons or individual;
(d) the maximum amount up to which guarantees may be given by a banking
company on behalf of any one company, firm, association of persons or
individual; and
(e) the rate of interest and other terms and conditions on which advances or
other financial accommodation may be made or guarantees may be given.
21. Every banking company (as also a nationalised bank, State Bank of
India, a subsidiary of State Bank of India, and a regional rural bank) is bound to
comply with the policy determined, and directions given, by the RBI.
Sec 22: Licensing of Banking Companies
22. Section 22 of the Act prohibits a company from carrying on banking
business in India unless it holds a license issued by the RBI. The licence may be
a conditional licence. The licence may be cancelled if the company ceases to
carry on banking business in India or fails to comply with the conditions imposed
upon it under sub-section (1) of this section or fails to fulfil any other condition
laid down in the section.
Sec 23: Restrictions on Opening and Transfer of Places of Business
23. Under section 23, prior permission of the RBI is required for opening of
new, or transfer of existing, places of business in India. Similarly, prior permission
from RBI is required by a banking company incorporated in India for opening a
new, or transferring an existing, place of business outside India. The above
restrictions, however, do not cover the change of location of an existing place of
business within the same city, town or village. Further, opening of a temporary
place of business for a period not exceeding one month is also exempted provided
the conditions laid down in this behalf are satisfied. The term `place of business'
includes any sub-office, pay office, sub-pay office and any place of business at
which deposits are received, cheques are encashed or monies are lent.
24. It may be noted that the RBI has permitted banks to open new places of
business or transfer existing ones without obtaining specific permission from it
provided certain conditions specified by the RBI in this behalf are satisfied.
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Sec 24: Maintenance of a Percentage of Assets (SLR)
25. Section 24 mandates that a scheduled bank, in addition to the average
daily balance required to be maintained under Section 42 of the Reserve Bank of
India Act, 1934 every other banking company, in addition to the cash reserve
required to be maintained under section18, shall maintain in India, assets of the
value which shall not be less than such percentage not exceeding forty percent
of the total of its demand and time liabilities in India as on the last Friday of the
second preceding fortnight, in such form and manner as the RBI may by
notification in the Official Gazette, specify from time to time.
26. Section 25 requires that the assets in India of every banking company at
the close of business on the last Friday of every quarter or if that day is a public
holiday, at the close of the preceding working day, shall not be less than 75% of
its demand and time liabilities in India.
Returns to be Submitted to the RBI
27. The Banking Regulation Act, 1949 requires banking companies,
nationalised banks, State Bank of India, its subsidiaries, and regional rural banks
to furnish the following returns to the RBI:
(a) Monthly return of assets maintained in India in accordance with section 24
and demand and time liabilities in India at the close of business on each
alternate Friday during the month. [Section 24]
(b) Quarterly return of assets and liabilities in India at the close of business on
the last Friday of every quarter. [Section 25]
(c) Annual return of unclaimed accounts which have not been operated for 10
years. [Section 26]
(d) Monthly return of assets and liabilities in India at the close of business on
the last Friday of every month. [Section 27]
28. The above types of banks also have to furnish such other statements or
information as may be required by the RBI under section 27 of the Act. In
exercise of its powers under the aforesaid section, the RBI requires a large
number of returns to be furnished to it. Some of the important returns required to
be furnished to the RBI are as enumerated below, with their periodicity indicated
in parentheses.
(a) Report on Non-performing Advances (annual).
(b) Statement showing the position of reconciliation of investment account
(annual).
(c) Statement on compromises and settlements involving write off (half-yearly).
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Legal Framework
(d) Statement on bad debts written off (annual).
(e) Details of Doubtful or Loss Assets and also Suit Filed accounts with
outstandings aggregating Rs. one crore and above (half-yearly).
(f) Details of remittance of profits/surplus retained in India (annual).
(g) Particulars of provisions held on problem credits of overseas branches (half-
yearly).
(h) Inter-branch reconciliation (quarterly).
(i) Reconciliation of outstanding inter-branch accounts (annual).
(j) Reconciliation of clearing differences (annual).
(k) Position of balancing of books (quarterly).
(l) Returns relating to frauds, robbery, etc., including fraud involving Rs. one
crore and above (quarterly).
(m) Return of Capital Adequacy (quarterly).
(n) Return on Asset Quality (quarterly).
(o) Asset-liability management (monthly).
(p) Return in respect of Statutory Liquidity Ratio (monthly).
Sec 29-33: Provisions Relating to Accounts and Audit
29. Section 29 of the Act lays down requirements as to profit and loss
account and balance sheet. Section 30 deals with audit of profit and loss account
and balance sheet prepared in accordance with section 29. Section 31 deals with
publication of profit and loss account and balance sheet and their submission to
RBI, whereas section 32 deals with submission of profit and loss account and
balance sheet along with the auditor's report to the Registrar of Companies.
Section 33 deals with display of audited balance sheet and profit and loss
account by companies incorporated outside India and carrying on banking
business in India. These provisions are discussed in detail in Chapter,
`Accounting and Auditing Framework' given in Pen Drive/CD of the Guidance
Note. It may be noted that some of the above provisions are not applicable to
nationalised banks, State Bank of India, subsidiaries of State Bank of India,
regional rural banks, and co-operative banks (this aspect is discussed later in this
Chapter).
Other Important Provisions of the Banking Regulation Act, 1949
30. Besides the above provisions, a number of other provisions of the Act are
relevant to the work of the auditor. Some of the important provisions are as follows:
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Guidance Note on Audit of Banks (Revised 2019)
Section 9 Disposal of non-banking assets
(Banks are prohibited to hold any immovable property
other than assets for its own use and should dispose off
the assets held in satisfaction of claim within 7 years or
such extended period as RBI allows.)
Section 36A Certain provisions of the Act do not apply to certain
banking companies
Section 49A Restriction on acceptance of deposits, withdrawable by
cheque
Section 45Y Power of Central Government to make rules for the
preservation of records
31. Further, the provisions of the Banking Regulation Act, 1949, except as
provided for in the said Act, will override anything to the contrary contained in the:
memorandum or articles of the banking company or
in any agreement executed by it or
in any resolution passed by the banking company in a general meeting or its
Board of Directors.
Pursuant to Banking Regulation (Amendment) Act, 2017 which has come into
effect from May 4, 2017 has inserted two new section 35AA & Section 35AB by
which the central government may authorise the Reserve Bank of India to direct
banks to initiate recovery proceedings against loan defaulters under the
Insolvency and Bankruptcy Code, 2016.
Reserve Bank of India Act, 1934
32. As per section 42, every bank included in the Second Schedule of the
Reserve Bank of India Act shall maintain with the RBI an average daily balance
of not less than 4% of its total demand and time liabilities. RBI has power to
increase the said rate by issuing notification in the Gazette of India but the
increased rate shall not exceed 20% of its total demand and time liabilities.
Inspection by the RBI
33. Wide powers have been given to the RBI under section 35 of the
(Banking Regulation Act, 1949) for inspection of any banking company and its
books and accounts. The Central Government can also direct the RBI to cause
such an inspection. RBI has embarked on a transformatory journey towards Risk
Based Supervision (RBS) approach from the earlier transaction-centric CAMELS
(capital adequacy, asset quality, management, earnings, liquidity, and systems)
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Legal Framework
and CALCS (capital adequacy, asset quality, liquidity, compliance and systems
and controls) approaches. Significant improvements is being made in terms of
the quality of data provided to RBI and understanding of the data requirements.
Power of the RBI to Give Directions
34. The RBI is empowered to issue such directions to banking companies
generally or to any banking company in particular as it deems fit in public interest,
or in the interest of banking policy, or to prevent the affairs of any banking company
from being conducted in a manner detrimental to the interests of the depositors or
in a manner prejudicial to the interests of the banking company, or to secure the
proper management of any banking company generally (section 35A of the
Banking Regulation Act, 1949). The RBI is also empowered to caution or prohibit
banking companies generally or any particular banking company against entering
into any particular transaction or class of transactions, and generally give advice to
any banking company [Clause (a) of sub-section (1) of section 36 of the Banking
Regulation Act, 1949].
Applicability of Various Enactments to Different Types of
Banks
35. As mentioned in paragraph 01 above, a number of enactments govern the
functioning of banks in India. While the Banking Regulation Act, 1949 is applicable
to all types of banks (though some of its provisions may not be applicable to certain
types of banks or may be applicable with certain modifications), the other
enactments are relevant only to particular type(s) of banks. The enactments
applicable to different types of banks are discussed below.
Nationalised Banks
36. Nationalised banks are governed by
(a) Banking Companies (Acquisition and Transfer of Undertakings) Act,
1970/1980; and
(b) specified provisions of the Banking Regulation Act, 1949.
37. Fourteen banks were nationalised under the Banking Companies
(Acquisition and Transfer of Undertakings) Act, 1970 while another six were
nationalised under the Banking Companies (Acquisition and Transfer of
Undertakings) Act, 1980. The provisions of these two enactments are identical
and deal, inter alia, with such matters as the following:
Authorised and paid-up capital.
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Guidance Note on Audit of Banks (Revised 2019)
Annual accounts.
Qualifications, appointment, powers and duties of auditor (including contents
of audit report).
Disposal of profits.
Special audit at the instance of the Central Government.
Time and place of annual general meeting and business to be transacted
thereat.
Restrictions on payment of bonus to officers and other employees.
Powers of the Board of Directors to make regulations in consultation with the
RBI and with the previous sanction of the Central Government.
38. Apart from all the provisions of the aforesaid Act of 1970/1980, the
following provisions of the Banking Regulation Act, 1949, also apply to
nationalised banks by virtue of section 51 of the latter Act:
Section 10 Prohibition of employment of managing agents and
restrictions on certain forms of employment
Section 13 Restriction on commission, brokerage, discount, etc., on
sale of shares
Section 14 Prohibition of charge on unpaid capital
Section 14A Prohibition of floating charge on assets
Section 15 Restrictions as to payment of dividend
Section 17 Reserve Fund
Section 19 Restriction on nature of subsidiary companies
Section 20 Restrictions on loans and advances
Section 20A Restriction on power to remit debts
Section 21 Power of Reserve Bank to control advances by banking
companies
Section 21A Rate of interest charged by banking companies not to be
subject to scrutiny by Courts
Section 23 Restrictions on opening of new, and transfer of existing,
places of business
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Section 24 Maintenance of a percentage of assets
Section 25 Assets in India
Section 26 Return of unclaimed deposits
Section 27 Monthly returns and power to call for other returns and
information
Section 28 Power to publish information
Section 29 Accounts and balance sheet
[excluding sub-
section (3)]
Section 30 Audit
[excluding sub-
sections (1B), (1C)
and (2)]
Section 31 Submission of returns
Section 34 Accounting provisions of the Act not retrospective
Section 35 Inspection
Section 35A Power of the Reserve Bank to give directions
Section 36 Further powers and functions of Reserve Bank
[excluding clause
(a) of sub-section
(1)]
Section 45Y Power of Central Government to make rules for the
preservation of records
Section 45Z Return of paid instruments to customers
Section 45ZA Nomination for payment of depositors' money
Section 45ZB Notice of claims of other persons regarding deposits not
receivable
Section 45ZC Nomination for return of articles kept in safe custody with
banking company
Section 45ZD Notice of claims of other persons regarding articles not
receivable
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Guidance Note on Audit of Banks (Revised 2019)
Section 45ZE Release of contents of safety lockers
Section 45ZF Notice of claims of other persons regarding safety lockers
not receivable
Section 46 Penalties
Section 46A Chairman, director, etc., to be public servants for the
purposes of Chapter IX of the Indian Penal Code
Section 47 Cognisance of offences
Section 47A Power of Reserve Bank to impose penalty
Section 48 Application of fines
Section 50 Certain claims for compensation barred
Section 52 Power of Central Government to make rules
Section 53 Power to exempt in certain cases
State Bank of India and its Subsidiaries
39. State Bank of India and its subsidiaries are governed by
(a) State Bank of India Act, 1955/State Bank of India (Subsidiary Banks) Act,
1959, as the case may be; and
(b) specified provisions of the Banking Regulation Act, 1949.
40. The provisions of the Banking Regulation Act, 1949, applicable to State
Bank of India and its subsidiaries are specified in section 51 of the said Act and
are the same as those applicable to nationalised banks (described in paragraph
38 above).
Regional Rural Banks
41. Regional rural banks are governed by
(a) Regional Rural Banks Act, 1976; and
(b) specified provisions of the Banking Regulation Act, 1949.
42. The provisions of the Banking Regulation Act, 1949, applicable to
regional rural banks are specified in section 51 of the said Act and are the same
as those applicable to nationalised banks (described in paragraph 38 above).
Co-operative Banks
43. Co-operative banks are governed by
(a) The Co-operative Societies Act, 1912, or the Co-operative Societies Act
582
Legal Framework
of the state concerned, as the case may be; and
(b) Part V of the Banking Regulation Act, 1949.
44. Part V of the Banking Regulation Act, 1949, modifies certain
provisions of the Act in their application to co-operative banks and omits
certain others. The sections which have been significantly modified in their
application to co-operative banks are sections 2, 5-A, 6, 7, 8, 9, 11, 18, 19,
20, 21, 22, 23, 24, 27, 29, 31, 35, 35A, 36, 36A, 49A, 52, 54 and 55. Besides,
the First Schedule to the Act is not applicable to co-operative banks while the
Third and the Fourth Schedules to the Act have been replaced by a schedule
applicable only to co-operative banks.
Scheduled Banks
45. These are the banks included in the Second Schedule to the
Reserve Bank of India Act, 1934. The RBI includes a bank in the said
Schedule if it fulfils certain conditions.
46. The RBI gives certain facilities to scheduled banks including the
following:
(a) Purchase, sale and rediscounting of certain bills of exchange (including
foreign bills of exchange) or promissory notes.
(b) Purchase and sale of foreign exchange.
(c) Making of loans and advances to scheduled banks.
(d) Maintenance of the accounts of scheduled banks in its banking
department and issue department.
(e) Remittance of money between different branches of scheduled banks
through the offices, branches or agencies of the RBI free of charge or at
nominal charges.
Companies Act, 2013
47. Section 2 of the Banking Regulation Act, 1949, provides that the
provisions of the Act shall be in addition to, and not, save as expressly provided
there under, in derogation of the Companies Act, 2013, and any other law for the
time being in force. Thus, banking companies attract the provisions of both the
Banking Regulation Act, 1949, as well as the Companies Act, 2013. In case the
provisions of these enactments are at variance, the provisions of the Banking
Regulation Act, 1949, shall prevail.
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Guidance Note on Audit of Banks (Revised 2019)
Regulatory Directives
48. Section 35A of the Banking Regulation Act 1949 empowers the RBI
to issue directions to banking companies generally or in particular, from time
to time and such directions shall be binding on all the banking companies.
Vested with such power, RBI has issued various circulars regarding banking
supervision, banking operations, etc. The circulars issued by RBI deal with
issues among other things, accounting, accounting standards, financial
statement disclosures, etc. It is mandatory for every banking company to
follow the RBI's directions and RBI closely monitors such compliances. The
circulars issued by RBI cover every facet of banking business.
49. RBI issues Master Circulars every year by consolidating the earlier
circulars on the subject and the latest circulars issued are updated. The
master circulars and other circulars are hosted on RBI website
(www.rbi.org.in) in respect of various matters concerning banking business,
valuation of investments, revenue recognition, para-banking activities, capital
adequacy, frauds classification and reporting, risk management, classification
of advances, etc. Recently, RBI has started issuing Master Directions on all
regulatory matters beginning January 2016. Some of these master
circulars/master Directions have been provided in the Pen Drive/CD enclosed
with this Guidance Note.
584
2
Appendices
APPENDIX I
Text of Section 6 of the Banking Regulation Act,
1949
(1) In addition to the business of banking, banking company may engage in
any one or more of the following forms of business, namely:
(a) the borrowing, raising, or taking up of money; the lending or advancing of
money either upon or without security; the drawing, making, accepting,
discounting, buying, selling, collecting and dealing in bills of exchange,
hundis, promissory notes, coupons, drafts, bills of lading, railway receipts,
warrants, debentures, certificates, scripts and other instruments, and
securities whether transferable or negotiable or not; the granting and
issuing of letters of credit, traveller's cheques and circular notes; the buying,
selling and dealing in bullion and specie; the buying and selling, of foreign
exchange including foreign bank notes; the acquiring, holding, issuing on
commission, underwriting and dealing in stock, funds, shares, debentures,
debenture stock, bonds, obligations, securities and investments of all kinds;
the purchasing and selling of bonds, scrips or other forms of securities on
behalf of constituents or others, the negotiating of loans and advances; the
receiving of all kinds of bonds, scrips or valuables on deposit or for safe
custody or otherwise; the providing of safe deposit vaults; the collecting and
transmitting of money and securities;
(b) acting as agents for any Government or local authority or any other person
or persons; the carrying on of agency business of any description including
the clearing and forwarding of goods, giving of receipts and discharges and
otherwise acting as an attorney on behalf of customers, but excluding the
business of a [managing agent or secretary and treasurer "managing agent"
(w.e.f. 1st October, 1959)] of a company;
(c) contracting for public and private loans and negotiating and issuing the
same;
(d) the effecting, insuring, guaranteeing, underwriting, participating in managing
and carrying out of any issue, public or private, of State, municipal or other
loans or of shares, stock, debentures, or debenture stock of any company,
corporation or association and the lending of money for the purpose of any
such issue;
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Guidance Note on Audit of Banks (Revised 2019)
(e) carrying on and transacting every kind of guarantee and indemnity
business;
(f) managing, selling and realizing any property which may come into the
possession of the company in satisfaction or part satisfaction of any of its
claims;
(g) acquiring and holding and generally dealing with any property or any right,
title or interest in any such property which may form the security or part of
the security for any loans or advances or which may be connected with any
such security;
(h) undertaking and executing trusts;
(i) undertaking the administration of estates as executor, trustee or otherwise;
(j) establishing and supporting or aiding in the establishment and support of
association, institutions, funds, trusts and conveniences calculated to
benefit employees or ex-employees of the company or the dependents or
connections of such persons; granting pensions and allowances and
making payments towards insurance; subscribing to or guaranteeing
moneys for charitable or benevolent objects or for any exhibition or for any
public, general or useful object;
(k) the acquisition, construction, maintenance and alteration of any building or
works necessary or convenient for the purposes of the company;
(l) selling, improving, managing, developing, exchanging, leasing, mortgaging,
disposing of or turning into account or otherwise dealing with all or any part
of the property and rights of the company;
(m) acquiring and undertaking the whole or any part of the business of any
person or company, when such business is of nature enumerated or
described in this sub-section;
(n) doing all such other things as are incidental or conducive to the promotion
or advancement of the business of the company;
(o) any other forms of business which the Central Government may by
notification in the Official Gazette, specify as a form of business in which it
is lawful for a banking company to engage.
(2) No banking company shall engage in any form of business other than
those referred to in sub-section (1).
586
APPENDIX II
The Third Schedule to the Banking Regulation
Act, 1949
(See Section 29)
FORM `A'
Form of Balance Sheet
Balance Sheet of _____________________ (here enter name of the Banking Company)
Balance Sheet as on 31st March (Year) (000's omitted)
Schedule As on 31.3__ As on 31.3__
(current year) (previous
year)
Capital & Liabilities
Capital 1
Reserves & Surplus 2
Deposits 3
Borrowings 4
Other liabilities and provisions 5
Total
Assets
Cash and Balances with Reserve 6
Bank of India
Balances with banks and money 7
at call and short notice
Investments 8
Advances 9
Fixed Assets 10
Other Assets 11
Total
Contingent Liabilities 12
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Guidance Note on Audit of Banks (Revised 2019)
Schedule As on 31.3__ As on 31.3__
(current year) (previous
year)
Bills for Collection
Schedule I
Capital
As on As on
31.3__ 31.3__
(current (previous
year) year)
I. For Nationalised Banks
Capital (Fully owned by Central Government)
II. For Banks Incorporated Outside India
Capital (The amount brought in by banks by
way of start-up capital as prescribed by RBI
should be shown under this head.)
Amount of deposit kept with RBI under section
11(2) of the Banking Regulation Act, 1949
Total
III. For Other Banks
Authorised Capital
(....... shares of Rs.... each)
Issued Capital
(...... shares of Rs..... each)
Subscribed Capital
(.....shares of Rs..... ..each)
Called-up Capital
(....... shares of Rs... each)
Less: Calls unpaid
Add: Forfeited shares
Total
Schedule 2
Reserves & Surplus
As on 31.3__ As on 31.3__
(current year) (previous year)
I. Statutory Reserves
Opening Balances
Additions during the year
Deductions during the year
588
Appendices
II. Capital Reserves
Opening Balances
Additions during the year
Deductions during the year
III. Share Premium
Opening Balances
Additions during the year
Deductions during the year
IV. Revenue and Other Reserves
Opening Balance
Additions during the year
Deductions during the year
V. Balance in Profit and Loss Account
Total (I, II, III, IV and V)
Schedule 3
Deposits
As on 31.3__ As on 31.3__
(current year) (previous year)
A. I. Demand Deposits
(i) From banks
(ii) From others
II. Savings Bank Deposits
III. Term Deposits
(i) From banks
(ii) From others
Total (I, II and III)
B. (i) Deposits of branches inIndia
(ii) Deposits of branches
outside India
Total
Schedule 4
Borrowings
As on 31.3__ As on 31.3__
(current year) (previous
year)
I. Borrowings in India
(i) Reserve Bank of India
(ii) Other banks
(iii) Other institutions and
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Guidance Note on Audit of Banks (Revised 2019)
agencies
II. Borrowings outside India
Total (I & II)
Secured borrowings included in I & II above Rs.
Schedule 5
Other Liabilities and Provisions
As on 31.3__ As on 31.3__
(current year) (previous
year)
I. Bills payable
II. Inter-office adjustments (net)
III. Interest accrued
IV. Others (including provisions)
Total
Schedule 6
Cash and Balances with Reserve Bank of India
As on 31.3__ As on 31.3__
(current year) (previous
year)
I. Cash in hand
(including foreign currency notes)
II. Balances with Reserve Bank of India
(i) in Current Account
(ii) in Other Accounts
Total (I & II)
Schedule 7
Balances with Banks and Money at Call & Short Notice
As on 31.3__ As on 31.3__
(current year) (previous
year)
I. In India
590
Appendices
(i) Balances with banks
(a) in current accounts
(b) in other deposit accounts
(ii) Money at call and short notice
(a) with banks
(b) with other institutions
Total (i & ii)
II. Outside India
(i) in current accounts
(ii) in other deposit accounts
(iii) Money at call and short notice
Total
Grand Total (I & II)
Schedule 8
Investments
As on 31.3__ As on 31.3__
(current year) (previous year)
I. Investments in India in
(i) Government securities
(ii) Other approved securities
(iii) Shares
(iv) Debentures and bonds
(v) Subsidiaries and/or joint ventures
(vi) Others (to be specified)
Total
II. Investments Outside India in
(i) Government securities
(including local authorities)
(ii) Subsidiaries and/or joint
ventures abroad
(iii) Other investments(to be specified)
Total
Grand Total (I & II)
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Guidance Note on Audit of Banks (Revised 2019)
Schedule 9
Advances
As on 31.3__ As on 31.3__
(current year) (previous year)
A. (i) Bills purchased and discounted
(ii) Cash credits, overdrafts and loans
repayable on demand
(iii) Term loans
Total
B. (i) Secured by tangible assets
(ii) Covered by bank/Government
guarantees
(iii) Unsecured
Total
C. I. Advances in India
(i) Priority sectors
(ii) Public sector
(iii) Banks
(iv) Others
Total
II. Advances outside India
(i) Due from banks
(ii) Due from others
(a) Bills purchased and
discounted
(b) Syndicated loans
(c) Others
Total
Grand Total (C.I. & C.II)
Schedule 10
Fixed Assets
As on 31.3__ As on 31.3__
(current year) (previous year)
I. Premises
At cost as on 31st March of the
preceding year
Additions during the year
592
Appendices
Deductions during the year
Depreciation to date
II. Other Fixed Assets
(including furniture and fixtures)
At cost as on 31st March of the
preceding year
Additions during the year
Deductions during the year
Depreciation to date
Total (I & II)
Schedule 11
Other Assets
As on 31.3__ As on 31.3__
(current year) (previous year)
I. Inter-office adjustments (net)
II. Interest accrued
III. Tax paid in advance/tax deducted at
source
IV. Stationery and stamps
V. Non-banking assets acquired in
satisfaction of claims
VI. Others*
Total
* In case there is any unadjusted balance of loss the same may be shown under this item
with appropriate footnote.
Schedule 12
Contingent Liabilities
As on 31.3__ As on 31.3__
(current year) (previous year)
I. Claims against the bank not
acknowledged as debts
II. Liability for partly paid investments
III. Liability on account of outstanding
forward exchange contracts
IV. Guarantees given on behalf of
constituents
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Guidance Note on Audit of Banks (Revised 2019)
(a) In India
(b) Outside India
V. Acceptances, endorsements and
other obligations
VI. Other items for which the bank is
contingently liable
Total
Form `B'
Form of Profit & Loss Account
for the year ended 31st March_________
(000's omitted)
Year ended Year ended
Schedule 31.3__ 31.3__
(current year) (previous year)
I. Income
Interest earned 13
Other income 14
Total
II. Expenditure
Interest expended 15
Operating expenses 16
Provisions and contingencies
Total
III. Profit / Loss
Net profit/loss () for the year
Profit/loss () brought forward
Total
IV. Appropriations
Transfer to statutory reserves
Transfer to other reserves
Transfer to -
Government/Proposed dividend
Balance carried over tobalance-
sheet
Total
594
Appendices
Schedule 13
Interest Earned
Year ended Year ended
31.3__ 31.3__
(current year) (previous year)
I. Interest/discount on advances/bills
II. Income on investments
III. Interest on balances with Reserve Bank
of India and other inter-bank funds
IV. Others
Total
Schedule 14
Other Income
Year ended Year ended
31.3__ 31.3__
(current year) (previous year)
I. Commission, exchange and brokerage
II. Profit on sale of investments
Less: Loss on sale of investments
III. Profit on revaluation of investments
Less: Loss on revaluation of investments
IV. Profit on sale of land, buildings and other
assets
Less: Loss on sale of land, buildings and
other assets
V. Profit on exchange transactions
Less: Loss on exchange transactions
VI. Income earned by way of dividends etc.
from subsidiaries, companies and/or joint
ventures abroad/in India
VII. Miscellaneous income
Total
Note: Under items II to V, loss figures may be shown in brackets.
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Guidance Note on Audit of Banks (Revised 2019)
Schedule 15
Interest Expended
Year ended Year ended
31.3__ 31.3__
(current year) (previous year)
I. Interest on deposits
II. Interest on Reserve Bank of India/inter-
bank borrowings
III. Others
Total
Schedule 16
Operating Expenses
Year ended Year ended
31.3__ 31.3__
(current year) (previous year)
I. Payments to and provisions for
employees
II. Rent, taxes and lighting
III. Printing and stationery
IV. Advertisement and publicity
V. Depreciation on bank's property
VI. Directors' fees, allowances and
expenses
VII. Auditors' fees and expenses (including
branch auditors' fees and expenses)
VIII. Law charges
IX. Postage, telegrams, telephones, etc.
X. Repairs and maintenance
XI. Insurance
XII. Other expenditure
Total
596
APPENDIX III
Illustrative Format of Report of the Branch
Auditor of a Nationalised Bank
Independent Branch Auditor's Report
To,
The Statutory Central Auditors
________ Bank
Report on the Audit of the Financial Statements
Opinion
1. We have audited the Financial Statements of _______________Branch of
____________ (name of the Bank) which comprise the Balance Sheet as at 31st
March 20XX, the Statement of Profit and Loss for the year then ended and other
explanatory information [in which are included the Returns for the year ended
on that date].
2. In our opinion, and to the best of our information and according to the
explanations given to us, read with the Memorandum of Changes (mentioned in
paragraph 7 below), the aforesaid financial statements give the information required
by the Banking Regulation Act, 1949, in the manner so required for bank and give
a true and fair view in conformity with the accounting principles generally accepted
in India of the state of affairs in case of the Balance Sheet of the branch as at March
31, 20XX and true balance of profit/loss for the year ended on that date.
Basis for Opinion
3. We conducted our audit in accordance with the Standards on Auditing
(SAs) issued by ICAI. Our responsibilities under those standards are further
described in the Auditor's Responsibilities for the Audit of the Financial Statements
section of our report. We are independent of the bank in accordance with the code
of ethics issued by the Institute of Chartered Accountants of India together with
ethical requirements that are relevant to our audit of the financial statements in
[jurisdiction], and we have fulfilled our other ethical responsibilities in accordance
with these requirements and the code of ethics. We believe that the audit evidence
we have obtained is sufficient and appropriate to provide a basis for our opinion.
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Guidance Note on Audit of Banks (Revised 2019)
Management's Responsibilities for the Financial Statements
4. The Bank's management is responsible with respect to the preparation
of these financial statements that give a true and fair view of the financial position
and financial performance of the Bank in accordance with the accounting
principles generally accepted in India, including the Accounting Standards issued
by ICAI, and provisions of Section 29 of the Banking Regulation Act, 1949 and
circulars and guidelines issued by the Reserve Bank of India (`RBI') from time to
time. This responsibility also includes maintenance of adequate accounting
records in accordance with the provisions of the Act for safeguarding of the
assets of the Bank and for preventing and detecting frauds and other
irregularities; selection and application of appropriate accounting policies; making
judgments and estimates that are reasonable and prudent; and design,
implementation and maintenance of adequate internal financial controls, that
were operating effectively for ensuring the accuracy and completeness of the
accounting records, relevant to the preparation and presentation of the financial
statements that give a true and fair view and are free from material misstatement,
whether due to fraud or error.
In preparing the financial statements, management is responsible for assessing
the Bank's ability to continue as a going concern, disclosing, as applicable,
matters related to going concern and using the going concern basis of
accounting unless management either intends to liquidate the Bank or to cease
operations, or has no realistic alternative but to do so.
Auditor's Responsibilities for the Audit of the Financial Statements
5. Our objectives are to obtain reasonable assurance about whether the
financial statements as a whole are free from material misstatement, whether
due to fraud or error, and to issue an auditor's report that includes our opinion.
Reasonable assurance is a high level of assurance, but is not a guarantee that
an audit conducted in accordance with SAs will always detect a material
misstatement when it exists. Misstatements can arise from fraud or error and are
considered material if, individually or in the aggregate, they could reasonably be
expected to influence the economic decisions of users taken on the basis of
these financial statements.
As part of an audit in accordance with SAs, we exercise professional judgment and
maintain professional skepticism throughout the audit. We also:
· Identify and assess the risks of material misstatement of the financial
statements, whether due to fraud or error, design and perform audit
procedures responsive to those risks, and obtain audit evidence that is
sufficient and appropriate to provide a basis for our opinion. The risk of not
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detecting a material misstatement resulting from fraud is higher than for one
resulting from error, as fraud may involve collusion, forgery, intentional
omissions, misrepresentations, or the override of internal control.
· Evaluate the appropriateness of accounting policies used and the
reasonableness of accounting estimates and related disclosures made by
management.
· Report that the audit at branch level is not be able to conclude on the
appropriateness of management's use of the going concern basis of
accounting and, based on the audit evidence obtained at branch, whether a
material uncertainty exists related to events or conditions that may cast
significant doubt on the Bank's ability to continue as a going concern.
· Evaluate the overall presentation, structure and content of the financial
statements, including the disclosures, and whether the financial statements
represent the underlying transactions and events in a manner that achieves
fair presentation.
We communicate with those charged with governance regarding, among other
matters, the planned scope and timing of the audit and significant audit findings,
including any significant deficiencies in internal control that we identify during our
audit.
We also provide those charged with governance with a statement that we have
complied with relevant ethical requirements regarding independence, and to
communicate with them all relationships and other matters that may reasonably be
thought to bear on our independence, and where applicable, related safeguards.
Other Matter
6. No adjustments/provisions have been made in the accounts of the
Branch in respect of matters usually dealt with at Central Office, including in
respect of:
(a) Bonus, ex-gratia, and other similar expenditure and allowances to branch
employees;
(b) Terminal permissible benefits to eligible employees on their retirement
(including additional retirement benefits), Gratuity, Pension, liability for
leave encashment benefits and other benefits covered in terms of `AS 15
(Revised)Employee Benefits' issued by the Institute of Chartered
Accountants of India;
(c) Arrears of salary/wages/allowances, if any, payable to staff;
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Guidance Note on Audit of Banks (Revised 2019)
(d) Staff welfare contractual obligations;
(e) Old unreconciled/unlinked entries at debit under various heads comprising
Inter branch/office Adjustments;
(f) Interest on overdue term deposits;
(g) Depreciation on fixed assets;
(h) Auditors' fees and expenses;
(i) Taxation (Current Tax and Deferred Tax);
(j) Any other provision made by Head Office.
7. The following is a summary of Memorandum of Changes submitted by us to
the branch management13.
Memorandum of Changes (summary)
No. Increase Decrease
a) In respect of Income
b) In respect of expenditure
c) In respect of Assets
d) In respect of Liabilities
e) In respect of Gross NPAs
f) In respect of Provision on NPAs14
g) In respect of Classification of
Advances
h) In respect of Risk Weighted Assets
i) Other items (if any)
Report on Other Legal and Regulatory Requirements
8. The Balance Sheet and the Profit and Loss Account have been drawn up
in accordance with Section 29 of the Banking Regulation Act, 1949;
13Where Applicable.
14Applicable in cases where banks determine provision at Branch level.
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Appendices
9. Subject to the limitations of the audit indicated in paragraphs 4 to 6
above and as required by the Banking Companies (Acquisition and Transfer of
Undertakings) Act, 1970/1980, and subject also to the limitations of disclosure
required therein, we report that:
a. We have obtained all the information and explanations which to the best of our
knowledge and belief were necessary for the purposes of the audit and have
found them to be satisfactory;
b. The transactions of the branch which have come to our notice have been
within the powers of the Bank.
c. the returns received from the branch have been found adequate for the
purposes of our audit
10. We further report that:
a. in our opinion, proper books of account as required by law have been kept
by the Bank so far as it appears from our examination of those books;
b. the Balance Sheet, and the Profit and Loss Account dealt with by this report
are in agreement with the books of account;
c. In our opinion, the Balance Sheet, and the Profit and Loss Account comply
with the applicable accounting standards, to the extent they are not
inconsistent with the accounting policies prescribed by RBI.
For ABC and Co.
Chartered Accountants
Firm Registration No.
Signature
(Name of the Member Signing the Audit Report)
(Designation)15
Membership Number
Place of Signature
Date
15Partner or proprietor as the case may be.
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APPENDIX IV
Illustrative Format of Report of the Branch
Auditor of a Banking Company
Independent Bank Branch Auditor's Report
To,
The Statutory Central Auditors
________ Bank Limited
Report on the Audit of the Financial Statements
Opinion
1. We have audited the Financial Statements of _______________Branch of
____________ (name of the Bank) which comprise the Balance Sheet as at 31st
March 20XX, the Statement of Profit and Loss, and other explanatory information [in
which are included the Returns for the year ended on that date].
2. In our opinion, and to the best of our information and according to the
explanations given to us, read with the Memorandum of Changes (mentioned in
paragraph 7 below), the aforesaid financial statements give the information required
by the Banking Regulation Act, 1949 as well as the Companies Act, 2013, in the
manner so required for banking companies and give a true and fair view in
conformity with the accounting principles generally accepted in India of the state of
affairs in case of the Balance Sheet of the branch as at March 31, 20XX and its
profit/loss for the year ended on that date.
Basis for Opinion
3. We conducted our audit in accordance with the Standards on Auditing
(SAs) specified under section 143(10) of the Companies Act, 2013. Our
responsibilities under those Standards are further described in the Auditor's
Responsibilities for the Audit of the Financial Statements section of our report. We
are independent of the Bank in accordance with the Code of Ethics issued by the
Institute of Chartered Accountants of India together with the ethical requirements
that are relevant to our audit of the financial statements under the provisions of the
Companies Act, 2013 and the Rules thereunder, and we have fulfilled our other
ethical responsibilities in accordance with these requirements and the Code of
Ethics. We believe that the audit evidence we have obtained is sufficient and
appropriate to provide a basis for our opinion.
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Appendices
Responsibilities of Management and Those Charged with
Governance for the Financial Statements
4. Management of the Branch is responsible for the matters stated in
section 134(5) of the Companies Act, 2013 (`the Act') with respect to the
preparation of these financial statements that give a true and fair view of the
financial position and financial performance of the Branch in accordance with the
accounting principles generally accepted in India, including the Accounting
Standards specified under section 133 of the Act and provisions of Section 29 of
the Banking Regulation Act, 1949 and circulars and guidelines issued by the
Reserve Bank of India (`RBI') from time to time. This responsibility also includes
maintenance of adequate accounting records in accordance with the provisions
of the Act for safeguarding of the assets of the Branch and for preventing and
detecting frauds and other irregularities; selection and application of appropriate
accounting policies; making judgments and estimates that are reasonable and
prudent; and design, implementation and maintenance of adequate internal
financial controls, that were operating effectively for ensuring the accuracy and
completeness of the accounting records, relevant to the preparation and
presentation of the financial statements that give a true and fair view and are free
from material misstatement, whether due to fraud or error.
In preparing the financial statements, management is responsible for assessing
the Bank's ability to continue as a going concern, disclosing, as applicable,
matters related to going concern and using the going concern basis of
accounting unless management either intends to liquidate the Bank or to cease
operations, or has no realistic alternative but to do so.
Auditor's Responsibilities for the audit of the Financial Statements
5. Our objectives are to obtain reasonable assurance about whether the
financial statements as a whole are free from material misstatement, whether
due to fraud or error, and to issue an auditor's report that includes our opinion.
Reasonable assurance is a high level of assurance, but is not a guarantee that
an audit conducted in accordance with SAs will always detect a material
misstatement when it exists. Misstatements can arise from fraud or error and are
considered material if, individually or in the aggregate, they could reasonably be
expected to influence the economic decisions of users taken on the basis of
these financial statements.
As part of an audit in accordance with SAs, we exercise professional judgment and
maintain professional skepticism throughout the audit. We also:
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Guidance Note on Audit of Banks (Revised 2019)
· Identify and assess the risks of material misstatement of the financial
statements, whether due to fraud or error, design and perform audit
procedures responsive to those risks, and obtain audit evidence that is
sufficient and appropriate to provide a basis for our opinion. The risk of not
detecting a material misstatement resulting from fraud is higher than for one
resulting from error, as fraud may involve collusion, forgery, intentional
omissions, misrepresentations, or the override of internal control.
· Obtain an understanding of internal control relevant to the audit in order to
design audit procedures that are appropriate in the circumstances. Under
section 143(3)(i) of the Companies Act, 2013, we are also responsible for
expressing our opinion on whether the bank has adequate internal financial
controls system in place and the operating effectiveness of such controls.
· Evaluate the appropriateness of accounting policies used and the
reasonableness of accounting estimates and related disclosures made by
management.
· Report that the audit at branch level is not be able to conclude on the
appropriateness of management's use of the going concern basis of
accounting and, based on the audit evidence obtained at branch, whether a
material uncertainty exists related to events or conditions that may cast
significant doubt on the Bank's ability to continue as a going concern.
· Evaluate the overall presentation, structure and content of the financial
statements, including the disclosures, and whether the financial statements
represent the underlying transactions and events in a manner that achieves
fair presentation.
We communicate with those charged with governance regarding, among other
matters, the planned scope and timing of the audit and significant audit findings,
including any significant deficiencies in internal control that we identify during our
audit.
We also provide those charged with governance with a statement that we have
complied with relevant ethical requirements regarding independence, and to
communicate with them all relationships and other matters that may reasonably be
thought to bear on our independence, and where applicable, related safeguards.
Other Matter
6. No adjustments/provisions have been made in the accounts of the
Branch in respect of matters usually dealt with at Central Office, including in
respect of:
(a) Bonus, ex-gratia, and other similar expenditure and allowances to branch
employees;
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Appendices
(b) Terminal permissible benefits to eligible employees on their retirement
(including additional retirement benefits), Gratuity, Pension, liability for
leave encashment benefits and other benefits covered in terms of `AS 15
(Revised)Employee Benefits' issued by the Institute of Chartered
Accountants of India;
(c) Arrears of salary/wages/allowances, if any, payable to staff;
(d) Staff welfare contractual obligations;
(e) Old unreconciled/unlinked entries at debit under various heads comprising
Inter branch/office Adjustments;
(f) Interest on overdue term deposits;
(g) Depreciation on fixed assets;
(h) Auditors' fees and expenses;
(i) Taxation (Current Tax and Deferred Tax);
(j) Any other provision made by Head Office.
7. The following is a summary of Memorandum of Changes submitted by us
to the branch management16.
Memorandum of Changes (summary)
No. Increase Decrease
a) In respect of Income
b) In respect of expenditure
c) In respect of Assets
d) In respect of Liabilities
e) In respect of Gross NPAs
f) In respect of Provision on NPAs17
g) In respect of Classification of
Advances
h) In respect of Risk Weighted Assets
i) Other items (if any)
Report on Other Legal and Regulatory Requirements
8. The Balance Sheet and the Profit and Loss Account have been drawn up
in accordance with the provision of Section 29 of the Banking Regulation Act, 1949
16Where Applicable.
17Applicable in cases where banks determine provision at Branch level.
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Guidance Note on Audit of Banks (Revised 2019)
read with Section 133 of the Act read with Rule 7 of the Companies (Accounts)
Rules, 2014.
9. As required by sub-section (3) of section 30 of the Banking Regulation
Act, 1949, we report that:
a. We have obtained all the information and explanations which to the best of our
knowledge and belief were necessary for the purpose of the audit and have
found them to be satisfactory.
b. The transactions of the branch which have come to my/our notice have been
within the powers of the Bank.
c. the returns received from the branch have been found adequate for the
purposes of our audit.
10. Further, as required by section 143(3) of the Act, we report that:
a. we have sought and obtained all the information and explanations which to
the best of our knowledge and belief were necessary for the purpose of our
audit;
b. in our opinion, proper books of account as required by law have been kept by
the branch so far as appears from our examination of those books;
c. The Balance Sheet, and the Statement of Profit and Loss, dealt with by this
report are in agreement with the books of account;
d. in our opinion, the aforesaid financial statements comply with the
Accounting Standards specified under Section 133 of the Act, read with
Rule 7 of the Companies (Accounts) Rules, 2014, to the extent they are not
inconsistent with the accounting policies prescribed by RBI;
e. with respect to the adequacy of the internal financial controls over financial
reporting of the Branch and the operating effectiveness of such controls,
refer to our separate Report in "Annexure A";
f. with respect to the other matters to be included in the Auditor's Report in
accordance with Rule 11 of the Companies (Audit and Auditors) Rules,
2014, in our opinion and to the best of our information and according to the
explanations given to us:
a) the Branch has disclosed the impact of pending litigations on its
financial position in its financial statements - Refer Schedule XX / Note
XX to the financial statements; (or the Branch does not have any
pending litigations which would impact its financial position18)
18As may be applicable.
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Appendices
(b) the Branch has made provision, as required under the applicable law
or accounting standards, for material foreseeable losses, if any, on
long-term contracts including derivative contracts -Refer Schedule XX
/ Note XX to the financial statements; (or the Branch did not have any
long-term contracts including derivative contracts for which there were
any material foreseeable losses19) and
(c) there has been no delay in transferring amounts, required to be
transferred, to the Investor Education and Protection Fund by the
Branch (or, following are the instances of delay in transferring
amounts, required to be transferred, to the Investor Education and
Protection Fund by the Branch or there were no amounts which were
required to be transferred to the Investor Education and Protection
Fund by the Branch19).
For ABC and Co.
Chartered Accountants
Firm Registration No._______
Signature
(Name of the Member Signing the Audit Report)
(Designation)20
Membership Number
Place of Signature
Date
19
As may be applicable.
20 Partner or proprietor as the case may be.
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Guidance Note on Audit of Banks (Revised 2019)
Annexure A to the independent auditor's report of even date on the
financial statements of _____ Branch of ______Bank Limited
[Referred to in Paragraph 10(e)]
Report on the Internal Financial Controls over Financial Reporting under
Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013
1. We have audited the internal financial controls over financial reporting of
____Branch of ______ Bank Limited (`the Branch') as at 31 March 20XX in
conjunction with our audit of the financial statements of the Branch for the
year ended on that date.
Management's Responsibility for Internal Financial Controls over
Financial Reporting
2. The Management of the Branch is responsible for establishing and
maintaining internal financial controls based on _____ [for example, "the
internal control over financial reporting criteria established by the Branch
considering the essential components of internal control stated in the
Guidance Note on Audit of Internal Financial Controls Over Financial
Reporting (`the Guidance Note') issued by the Institute of Chartered
Accountants of India (`the ICAI')".] These responsibilities include the design,
implementation and maintenance of adequate internal financial controls that
were operating effectively for ensuring the orderly and efficient conduct of its
business, including adherence to Branch's policies, the safeguarding of its
assets, the prevention and detection of frauds and errors, the accuracy and
completeness of the accounting records, and the timely preparation of
reliable financial information, as required under the Companies Act, 2013
(`the Act').
Auditor's Responsibility
3. Our responsibility is to express an opinion on the Branch's internal financial
controls over financial reporting based on our audit. We conducted our audit
in accordance with the Guidance Note on Audit of Internal Financial Controls
Over Financial Reporting (`the Guidance Note') and the Standards on
Auditing (`the Standards'), issued by the ICAI and deemed to be prescribed
under section 143(10) of the Act, to the extent applicable to an audit of
internal financial controls over financial reporting, both issued by the ICAI.
Those Standards and the Guidance Note require that we comply with ethical
608
Appendices
requirements and plan and perform the audit to obtain reasonable assurance
about whether adequate internal financial controls over financial reporting
was established and maintained and if such controls operated effectively in
all material respects.
4. Our audit involves performing procedures to obtain audit evidence about the
adequacy of the internal financial controls system over financial reporting
and their operating effectiveness. Our audit of internal financial controls over
financial reporting included obtaining an understanding of internal financial
controls over financial reporting, assessing the risk that a material weakness
exists, and testing and evaluating the design and operating effectiveness of
internal control based on the assessed risk. The procedures selected
depend on the auditor's judgement, including the assessment of the risks of
material misstatement of the financial statements, whether due to fraud or
error.
5. We believe that the audit evidence we have obtained is sufficient and
appropriate to provide a basis for our audit opinion on the Branch's internal
financial controls system over financial reporting.
Meaning of Internal Financial Controls Over Financial Reporting
6. A branch's internal financial control over financial reporting is a process
designed to provide reasonable assurance regarding the reliability of
financial reporting and the preparation of financial statements for external
purposes in accordance with generally accepted accounting principles. A
branch's internal financial control over financial reporting includes those
policies and procedures that (1) pertain to the maintenance of records that,
in reasonable detail, accurately and fairly reflect the transactions and
dispositions of the assets of the branch; (2) provide reasonable assurance
that transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted accounting
principles, and that receipts and expenditures of the branch are being made
only in accordance with authorizations of management and directors of the
bank; and (3) provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use, or disposition of the branch's
assets that could have a material effect on the financial statements.
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Guidance Note on Audit of Banks (Revised 2019)
Inherent Limitations of Internal Financial Controls Over Financial
Reporting
7. Because of the inherent limitations of internal financial controls over financial
reporting, including the possibility of collusion or improper management
override of controls, material misstatements due to error or fraud may occur
and not be detected. Also, projections of any evaluation of the internal
financial controls over financial reporting to future periods are subject to the
risk that the internal financial control over financial reporting may become
inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.
Opinion
8. In our opinion, the Branch has, in all material respects, an adequate internal
financial controls system over financial reporting and such internal financial
controls over financial reporting were operating effectively as at 31 March
201X, based on ______ [for example, "the internal control over financial
reporting criteria established by the Branch considering the essential
components of internal control stated in the Guidance Note issued by the
ICAI"].
For ABC and Co.
Chartered Accountants
(Firm's Registration No.)
Signature
(Name of the Member Signing the Audit Report)
(Designation)21
Membership Number
Place of Signature
Date of Report
21Partner or proprietor, as the case may be.
610
APPENDIX V
Illustrative Format of Engagement Letter to be
sent to the Appointing Authority of the
Nationalised Bank by Branch Auditor
{The following letter is for use as a guide and will need to be varied according to
individual requirements and circumstances relevant to the engagement.}
The Board of Directors
(or the appropriate representative of senior management).
[Date]
Subject: Engagement Letter
Dear Sirs,
I/We refer to the letter No. ................ dated .......received from
........................................(Name of the relevant authority) informing me/us
about my/our appointment to carry out the statutory audit of the (name of the
branch) branches of your Bank for the financial year beginning April 1, 20XX
and ending 31st March 20YY, including Tax Audit, issuance of the Long Form
Audit Report and, as a part of the audit, verification and/ or certification of certain
specific aspects pertaining to these branches, as listed in your aforementioned
letter.
1. Scope and Objective
We are pleased to confirm our acceptance for the aforementioned assignment
through the Letter of Acceptance attached herewith and the following sets out the
area of responsibility of the Branch Management and myself/ourselves subject to
the following:
i) Our audit of the financial statements of these branches will be conducted
with the objective of our expressing an opinion on the financial statements
of these branches. These financial statements include the Balance Sheet
(Form A), wherein we express our opinion on the true and fair view of the
state of affairs and the Profit and Loss Account (Form B), wherein we
express our opinion on the true balance of the profit/ loss for the year ended
on 31st March 20XX.
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Guidance Note on Audit of Banks (Revised 2019)
ii) We will conduct our audit in accordance with the Standards on Auditing
(SAs) and any other applicable pronouncements issued by Institute of
Chartered Accountants of India (ICAI), as well as the requirements of the
Banking Regulation Act, 1949, and the guidelines/ directions issued by the
Reserve Bank of India under the said statutes, from time to time. Those
Standards require that we comply with the ethical requirements and plan
and perform the audit to obtain reasonable assurance about whether the
financial statements are free of material misstatements.
iii) An audit involves performing procedures to obtain audit evidence about the
amounts and disclosures in the financial statements. The procedures
selected depend upon the auditor's judgement, including the assessment of
the risks of material misstatement of the financial statements, whether due
to fraud or error. An audit also includes evaluating the appropriateness of
accounting principles used and the reasonableness of the accounting
estimates made by management, as well as evaluating the overall
presentation of the financial statements.
iv) Because of the inherent limitations of an audit, together with the inherent
limitations of internal control, there is an unavoidable risk that some
material misstatements may not be detected, even though the audit is
properly planned and performed in accordance with SAs.
v) In making our risk assessments, we consider internal control relevant to the
entity's preparation of the financial statements in order to design audit
procedures that are appropriate in the circumstances, but not for the
purpose of expressing an opinion on the effectiveness of the entity's
internal control. However, we will communicate to you in writing concerning
any significant deficiencies in internal control relevant to the audit of the
financial statements that we have identified during the audit.
vi) We invite your attention to the fact that, in terms of RBI Circular No.
DBS.FGV.(F).No. BC/ 23.08.001/2001-02 dated May 3, 2002 relating to
implementation of recommendations of the Committee on Legal Aspects of
Bank Frauds (Mitra Committee) and the recommendations of the High Level
Group set-up by the Central Vigilance Commission applicable to all
scheduled commercial banks (excluding RRBs) we are required to report to
the RBI anything susceptible to fraud or fraudulent activity or any act of
excess power or any foul play in any transaction.
2. Management's Responsibility
Our assignment will be conducted on the basis that the branch management and,
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Appendices
where appropriate, those charged with governance of the bank acknowledge and
understand that they have responsibility:
(a) For the preparation of financial statements that give a true and fair view in
accordance with the applicable Financial Reporting Framework. This
includes:
the responsibility for the preparation of financial statements on a going
concern basis;
the responsibility for selection and consistent application of
appropriate accounting policies, including implementation of
applicable Accounting Standards, along with proper explanation
relating to any material departures from those Accounting Standards;
the responsibility for making judgements and estimates that are
reasonable and prudent, so as to give a true and fair view of the state
of affairs of the branch at the end of the financial year and true
balance of the profit or loss of the branch for that period.
(b) for such internal controls, as the branch management determines, are
necessary to enable the preparation of financial statements, that are free
from material misstatement, whether due to fraud or error. The
responsibility for internal controls also implicitly enshrines the responsibility
for compliance with the relevant directions/ circulars of the Reserve Bank of
India, including for those aspects which have been specifically listed for
verification/ certification by us in your aforementioned letter; and
(c) to provide us with:
(i) access to all information, including the books, account, vouchers,
internal policies and circulars, and other records and documentation,
of the branch, whether kept at the branch office or elsewhere, of which
the branch management is aware, that is relevant to the preparation of
the financial statements such as records, documentation and other
matters;
(ii) additional information that we may request from the branch
management for the purpose of the audit, including any internal audit,
concurrent audit, revenue audit, stock audit, Reserve Bank of India's
Inspection report; and their latest updated compliance position.
(iii) unrestricted access to persons within the entity, from whom we
determine it necessary to obtain audit evidence. This includes our
entitlement to require from the officers of the branch such information
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Guidance Note on Audit of Banks (Revised 2019)
and explanations, as we may think necessary for the performance of
our duties as auditor.
3. Other Matters
As part of our assignment, we will request from the branch management, written
confirmation concerning representations made to us in connection with the audit,
in accordance with Standard on Auditing 580 "Written Representations", issued
by the ICAI including confirmations in respect of the balances held by the Branch
with other banks, and such other items on the financial statements of the Branch,
as may be considered necessary by us for the purpose of our assignment.
It may also be noted that non-submission of the written confirmation to the
representations asked for or non-provision of any information/ confirmation,
requested by us from the branch management, may result in limitation on the
scope of our assignment and possibly invite necessary qualification in our
auditors report
In terms of Standard on Auditing 720(Revised) "The Auditor's Responsibilities
Relating to Other Information" issued by the ICAI, we request you to provide to
us a Draft of the Annual Report containing the audited financial statements so as
to enable us to read the same and communicate material inconsistencies, if any,
with the audited financial statements, before issuing the auditor's report on the
financial statements.
We also wish to invite your attention to the fact that, our audit process is subject
to 'peer review'/ `quality review' under the Chartered Accountants Act, 1949, to
be conducted by an independent reviewer. The reviewer may inspect, examine
or take abstracts of our working papers, in the course of the peer review / quality
review.
We look forward to full cooperation from your staff during our audit.
Our fees for the said audits (excluding fees for Tax Audit and the travelling
expenses will be as specified by the Reserve Bank of India/ State Bank of
India22.
Our fees for audit of Non Business Offices/ CMS Branches, as well as the tax
audit fees of the branches, would be as specified in your aforementioned letter.
Please sign and return the attached copy of this letter to indicate your
acknowledgement of, and agreement with, the arrangements for our
aforementioned assignment/s including our respective responsibilities. (Kindly
also mark a copy of such acknowledgement to the concerned official/s of the
respective branch managements.)
22As may be appropriate.
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Appendices
XYZ & Co.
Chartered Accountants
..............................
(Signature)
(Name of the Member)
Designation23
Date:
Place:
Acknowledged on behalf of ................... Branch of .....................Bank
..........................
(Signature)
Name and Designation
Date
Attached: Letter of Acceptance duly signed by us.
23Partner or proprietor, as the case may be.
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APPENDIX VI
Illustrative Format of Written Representation
Letter24 to be obtained from the Branch
Management
M/s XYZ & Co.,
Chartered Accountants,
Place
Dear Sir(s),
Sub.: Audit for the year ended March 31, 20XX
This representation letter is provided in connection with your audit of the financial
statements of _____________ branch of _______________ bank, for the year
ended March 31, 20XX, for the purpose of expressing an opinion as to whether
the financial statements give a true and fair view of the state of affairs of
___________ branch of _______________ bank as of March 31, 20XX, and of
the results of operations for the year then ended. We acknowledge our
responsibility for preparation of financial statements, in accordance with the
financial reporting framework applicable to the Bank, including the regulatory
requirements of the Reserve Bank of India.
We confirm, to the best of our knowledge and belief, the following
representations:
1. Accounting Policies
The accounting policies, as approved by the board of directors of the Bank, have
been duly followed. There are no changes in the accounting policies followed by
the branch during the current year.
2. Assets
2.1 All the assets owned by the bank and transferred to the branch and such
other asset/s, as has/ have been acquired by the branch, has/have been
duly accounted for, and none of the assets is encumbered.
2.2 Fixed assets held by branches have been properly accounted from the
date the asset is purchased and put to use and have been physically
verified at the year end. No discrepancies have been noticed on such
24 Kindly also refer Standard on Auditing (SA) 580, "Written Representations".
616
Appendices
verification. Depreciation on these assets has been adequately provided as
per the policy of the bank.
2.3 In respect of assets other than fixed assets, the same have not been
impaired and do not have a value lower than realizable value.
2.4 The branch is operating from a leased premise and there is no dispute with
respect to the tenancy and lease charges.
2.5 The Branch has not got any notice from the landlord for evacuation or
redevelopment of the premises which may possibly necessitate shifting the
branch premises in the near future.
3. Capital Commitments
At the balance sheet date, outstanding commitments for capital expenditure have
been duly depicted in the financial statements.
4. Cash and Bank Balances
The cash balance as on March 31, 20XX is Rs._____________, and has been
verified by us. Internal guidelines on periodic cash verification have been duly
followed.
Fake notes received by the Bank have been duly impounded and relevant
guidelines of RBI thereon have been complied.
Effective Dual custody of Cash has been maintained at all times during the
financial year.
5. Liabilities
The branch has recorded all known and anticipated liabilities in the financial
statements. Liabilities on account of GST have been correctly recorded.
6. Contingent Liabilities
6.1 The branch has fully disclosed in the notes to the financial statements;
(a) guarantees that we have given to third parties;
(b) Letters of Credits (Local/ Import);
(c) Letters of Comfort (Local/ Import);
(d) Deferred Payment Credits/ Guarantees (Local/ Import); and
(e) Other contingent liabilities.
6.2 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 claims, branch rentals, municipal
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Guidance Note on Audit of Banks (Revised 2019)
taxes, local levies, etc., except for those which have been appropriately
included under contingent liabilities.
6.3 None of the contingent liabilities disclosed and other than provided for are
likely to result in a further loss, requiring adjustment of assets or liabilities or
provisions in the books of accounts.
6.4 Frivolous claims from Customers / third parties have not been included in
Contingent liabilities.
Provisions for Claims and Losses
7. Provision has been made in the accounts for all known losses and
claims of material amounts.
8. There have been no events subsequent to the balance sheet date, that
require adjustment of, or disclosure in, the financial statements or notes thereto.
9. We have made available to you all the following latest reports on the
accounts of our branch, and updated compliance by the branch on the
observations contained therein:
a) Previous year's branch audit report and LFAR;
b) Internal inspection reports;
c) Report on any other Inspection Audit that has been conducted in the course
of the year, relevant to the financial year 2017-18.
Apart from the above, the branch has not received any show cause notice,
inspection advice, etc., from the 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.
10. Balancing of Books
The books of the accounts are computerised and hence the subsidiary records
are automatically balanced with the relevant control records. In the case of
manual sub-ledgers maintained, we confirm that they duly match with the general
ledger balances.
11. Overdue/Matured Term Deposits
All overdue/ matured term deposits are held as matured term deposits.
12. Advances
In respect of the Advances and income thereon, the income recognition and
asset classification norms prescribed by the Reserve Bank of India have been
complied with.
618
Appendices
13. Outstanding in Suspense/ Sundry Account
The yearwise/ entrywise break up of amounts outstanding in Sundry deposits/
Sundry assets, as on March 31, 2017 has already been submitted to you along
with explanation of the nature of the amounts in brief, and supporting evidences
relating to the existence of such amounts in the aforesaid accounts.
14. Interest Provisions
Interest provision has been made on deposits, etc., in accordance with the extant
instructions of the Head Office.
The interest provision for Head Office Interest shall be made at the Head Office.
15. Long Form Audit ReportBranch Response to the
Questionnaire
In connection with the Long Form Audit Report, complete information (including
all updated Internal Circulars issued till date, Receipt & disposal of Complaints &
grievances) as regards each item in the questionnaire, has been made available
to you in order to enable you to verify the same for the purpose of your audit.
16. Other Certification
Duly authenticated, information along with necessary source documents as
regards other matters which, as per the bank's letter of appointment, require
certification, has been made available to you.
17. On Demonetization is deleted as not applicable this year.
18. Information Provided
We have provided you with:
o Access to all information of which we are aware that is relevant to the
preparation of the financial statements such as records,
documentation, updated internal policies and circulars and other
matters;
o Additional information that you have requested from us for the
purpose of the audit; and
o Unrestricted access to persons within the entity from whom you
determined it necessary to obtain audit evidence.
All transactions have been recorded in the accounting records and are
reflected in the financial statements.
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Guidance Note on Audit of Banks (Revised 2019)
We have disclosed to you the results of our assessment of the risk that the
financial statements may be materially misstated as a result of fraud.
We have disclosed to you all information in relation to fraud or suspected
fraud that we are aware of and that affects the entity and involves:
o Management;
o Employees who have significant roles in internal control; or
o Others where the fraud could have a material effect on the financial
statements.
We have disclosed to you all information in relation to allegations of fraud,
or suspected fraud, affecting the entity's financial statements
communicated by employees, former employees, analysts, regulators or
others.
We have disclosed to you all known instances of non-compliance or
suspected non-compliance with laws and regulations whose effects should
be considered when preparing financial statements.
We have disclosed to you the identity of the entity's related parties and all
the related party relationships and transactions of which we are aware.
Any other matters that the auditor may consider necessary.
19. General
There is no enquiry going on or concluded during the year by the Central Bureau
of Investigation (CBI), or any other vigilance or investigating agency, on the
branch or on its employees and no cases of frauds or of misappropriation of
assets of the branch have come to the notice of the Management during the
year, other than for amounts for which provisions have already been made in the
books of accounts.
20. The provision for nonperforming assets, depreciation, provision for
income tax, provision for bonus, gratuity, etc., is made at the Head Office.
Therefore, the same has not been provided in the branch accounts. The branch
has correctly deducted Tax at source and paid the same on time to the relevant
authorities.
21. FIMMDA guidelines have been followed, wherever applicable.
22. The branch has complied with all aspects of contractual agreements,
that could have a material effect on the financial statements in the event of non
compliance. There has been no noncompliance with requirements of regulating
620
Appendices
authorities, that could have a material effect on the financial statements in the
event of noncompliance.
23. The other particulars required, have already been given to you, and
particulars and other representations made to you from time to time are true and
correct in all respects.
Thanking you,
Yours faithfully
For & on behalf of __________ branch of ______________ bank
Authorised Signatory
621
APPENDIX VII
Illustrative Checklist on Audit Considerations in
CIS Environment
While carrying out the audit in fully computerised environment, it is important to
note that the primary audit objective does not undergo change, it is only the
approach and methodology that undergoes a change. For achieving the primary
objective in each of the aspects of the financial statements - balance sheet,
statement of profit and loss, financial disclosures, notes to accounts, and special
purpose certificates, the auditors must consider the following broad suggestions:
Clearly identify and document the underlying audit objective and also the
significant inherent risks (accounting, compliance, etc.) involved in each
of the area.
Gain an understanding of the IT system in use, flow of
activities/processes, data interface, flow of accounting entries, regular
and exception reports generated on daily basis, critical manual
processes and controls.
Understand and document the processes involved and IT systems used
for month end and year-end financial closures and data extractions.
Identify sample size and carry out test of controls and substantive
checking.
Document process and results.
Form an opinion.
The following indicative checklist can be used (centralised and decentralised)
while undertaking the audit in fully computerised environment:
Sr. Particulars Yes/No/NA Comments
No.
A Basic Approach and Methodology
i. Have you obtained flow charts of activities in
relation to data entry, recording, processing,
storage and interface in each of the systems?
Obtain a list of unprocessed transactions as at
the year end.
ii. Have you gathered information about the
critical IT and manual controls in relation to
data processing and data interface, in general,
622
Appendices
Sr. Particulars Yes/No/NA Comments
No.
and accounting and preparation and
presentation of financial statements in
particular?
iii. Have you reviewed the work done by other
agencies, such as, internal auditors, concurrent
auditors, internal inspectors and system
auditors in relation to IT processes and
systems? Have you documented significant
observations, if any, made by any of the above
agencies?
iv. Have you enquired about the major
breakdowns/corruption in system/data, cyber
frauds, frauds using computer etc. and root
causes during the year having bearing on the
preparation and presentation of financial
statements and how the same were resolved?
Obtain details of unresolved issues, if any, as at
the year end.
v. Have you identified the samples for test of
controls and substantive checking? Have you
documented the process of sampling and the
details of sample selected? Have you taken
screen shots of the relevant accounts/data
used in sampling?
vi. Have you compared the outcome of testing with
the financial records? Are you satisfied with the
results of test of controls and substantive
checking? If not, have you taken some more
samples for further testing?
vii. If you are not satisfied with the results, has this
been escalated to concerned officials and those
issues have been resolved.
viii. Are there any unresolved issues and have you
noted the same for final reporting?
ix. Have you documented the entire audit process
and significant observation at all stages?
x. Have you obtained written representations from
the management on all the required matters?
B System of accounting and record keeping
623
Guidance Note on Audit of Banks (Revised 2019)
Sr. Particulars Yes/No/NA Comments
No.
i. Have you understood the nature and title of all
the account heads used in preparation and
presentation of financial statements? Obtain
written note on basic purpose and usage of all
head of accounts and their mapping/linkage
with main heads of financial statements.
ii. Have you understood process of recording
transactions in all the heads of accounts
including routing/intermediary accounts? Obtain
a list of all the routing accounts and purpose
and usage thereof? Review the balances held
and the ageing of these accounts as at the year
end.
iii. Have you understood the concept of out of the
book entries passed at the year end for the
purpose of financial closure and subsequent
accounting/reversal thereof? Obtain a list of
common OBE passed the year end. Have you
reviewed the OBE passed at year end and also
subsequent accounting and reversal thereof till
the date of signing?
iv. Have you ensured that the balances as the
general ledger are tallied with the balances as
per the sub-systems used for recording primary
transactions? In case of significant differences,
ensure that the same are reported in the audit
report as qualification?
v. In respect of financial information required for
disclosures in the notes to accounts and also
for special purpose certificate, have you
understood the process of compiling
information and the underlying systems used?
Obtain all the backup papers used for
generating such financial information.
C Certain specific aspects
i. In case of deposits have you understood the
process for compliance with KYC? Please carry
out test check of certain cases and document
the test results.
624
Appendices
Sr. Particulars Yes/No/NA Comments
No.
ii. In case of deposits have you understood
various types of deposits and carried out test
check to ensure interest accrual, application,
year end provisions, TDS calculations, etc., are
correct? (In view of voluminous
records/accounts, many a times, it is not
possible to compare the results of test of
controls and substantive checking for year end
interest accrual with the books of account as
individual customer level data is not generated.)
Please document the process and test results.
iii. In case of advances have you understood
various types of facilities being offered, the
process of monitoring the limits and interest
accrual and application (including year end
provisions) in accounts under various types of
facilities? Special care needs to be taken while
monitoring the excesses/over-limits in case of
fungible/interchangeable limits. Special care
also needs to be taken for new age products
being offered by various banks, such as,
Channel Financing, Business Banking, Small
and Medium Enterprises Financing, Gold
Loans, etc. (In view of voluminous
records/accounts, many a times, it is not
possible to compare the results of test of
controls and substantive checking for year end
interest accrual with the books of account as
individual customer level data is not generated.)
Please document the process and test results.
iv. In case of advances have you understood the
process of identifying non-performing assets
(NPA) under various types of facilities (cash
credit, overdraft, term loan, packing credit, bill
purchase and discounting) and segments
(wholesale and retail)? Special care need to be
taken while reviewing the overdue or DPD
(days past due) reports provided by the banks,
as many banks have filtration process before
final reports are generated. (In case private
sector and foreign banks, the retail assets are
625
Guidance Note on Audit of Banks (Revised 2019)
Sr. Particulars Yes/No/NA Comments
No.
categorised under various products and
monitored accordingly for asset classification
and security-wise classification. Even the NPA
norms (which are generally more stringent than
RBI norms) and security-wise classification is
decided on product level basis and applied
accordingly.
v. Have you understood the process of identifying
NPA borrower-wise and not facility-wise? (In
case of private sector banks and foreign banks,
due to voluminous data, such identification is
either not done or is done at a time lag and in
some case, the customer data in retail portfolio
is not matched with wholesale portfolio for this
purpose. Further, special care need to be taken
in case of new age products as, in some banks,
these facilities may not fall within wholesale and
retail portfolio for the purpose of monitoring.)
Please document the process and test results.
vi. In case of foreign currency assets and
liabilities, have you understood the process of
revaluation (as per Accounting Standard (AS)
11 /FEDAI guidelines) periodically and at the
year end, as the case may be? Please
document the process and results.
vii. In case of sundry assets and liabilities, have
you understood the usage, process of
clearance of outstanding items, periodic ageing
and reporting and provisioning of old items? (In
case of fully computerised banks, some of
these heads of account are used as routing
accounts and have specified frequency for
periodic clearance.) Please document the
process and test results.
viii. In case of day to day operating expenses, have
you understood the process of accounting,
payments, TDS calculation and year end
provisioning? (In case of private sector banks,
the accounting and payment of expenses is
centralised and generally there is substantial
626
Appendices
Sr. Particulars Yes/No/NA Comments
No.
time gap between receipt of goods/services,
receipt of bill and accounting thereof. Special
care need to be taken for provision for
expenses as at the year end. Further in case of
payments to staff, many banks do not provide
access to staff records due to confidentiality. In
such cases, please ensure that alternate audit
approach is used to verify aggregate payments
instead of merely relying on representation by
the management or outsourced service
provider.) Please document the process and
test results.
ix. In case of fixed assets have you understood the
process of the entire process of purchasing
fixed assets and the capitalisation and
amortisation thereof? (Due to voluminous
transactions and internal processes involved in
purchase of fixed assets, many banks follow
the practice of capitalising the assets (largely in
case of IT assets) on the date of payment
rather than date on which asset is ready for use
or date on which asset is put to use. Such
practices must be corrected.) Please document
the process and test results.
x. Have you understood the process of maturity-
wise classification of assets and liabilities of the
bank? (In many banks it is not possible to
compare the results of test check carried out in
this regard with the actual classification, as it is
in-built in the basic system and moreover, the
account level information is not readily
available.) Please document the process and
test results.
xi. In case of data migration from one platform to
another platform have you verified that the
same was error free and there are no pending
issues having bearing on the preparation and
presentation of financial statements with
migration report?
xii. In case of errors spotted during the audit, have
you enquired about the primary reason/s and
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Guidance Note on Audit of Banks (Revised 2019)
Sr. Particulars Yes/No/NA Comments
No.
specific pattern/s, if any for the errors? (In
computerised accounting, due to automated
data processing, it is quite likely that there are
some primary reasons and some patterns
behind the errors which, if not detected, could
lead to serial misstatement in the financial
statements.) Please document the process and
test results.
628
APPENDIX VIII
Overview of Various CBS and Basic Concepts
Introduction to FINACLE
A Financial Package, for Banking Solution developed by Infosys on a platform of
Oracle, is thus named as FINACLE. Presently, many Indian Public Sector Banks,
Private Sector Banks and Foreign Banks operating in India are using this
software as banking solution due to high flexibility and scalability. Finacle is an
integrated, on-line, enterprise banking system designed to provide the "e-
platform".
Prior to 1995 it was known as BANC 2000, a Total Branch Automation package
with a distributed network. After 1995 Infosys developed the same as FINACLE,
a Core Banking Solution.
Functionalities
Finacle facilitates anywhere banking
It is menu driven software with easy navigation.
It is functionality rich and addresses the retail and corporate banking
requirements.
Customization and parameterization are two special features of Finacle.
Finacle provides multi-lingual support
Finacle provides multi-level security i.e. operation, database and application
level security
It supports workflow based Transaction Processing.
It has High level of security control and audit capabilities
It has a common transaction interface for all type of transactions.
It provides a browser based GUI interface to Finacle
SQL & PL SQL is used for generation of MIS, Reports, Queries at
Centralized Level.
Designed for optimum Usage Of Network Bandwidth
There are two Functional Modules -
a. Retail and Corporate Module - Encompassing Saving Accounts,
Current Accounts, Term Deposits, Cash Credit Accounts, Overdraft
Accounts, Term Loans, Demand Loans.
629
Guidance Note on Audit of Banks (Revised 2019)
b. Trade Finance Module - Encompassing Inland & Foreign Bills,
Forward Contracts, Inland & Foreign Documentary Credits, Inland &
Foreign Bank Guarantees, Inland & Foreign Remittances and
Preshipment Credits.
Security in Finacle
FINACLE is having multiple levels of Security. Various security levels embedded
in it are as follows.
OS Level
o No access to OS
o OS and application level profile
o Direct login to application menu
Database level
o Protection from external updating
Application level
o Menu level
o User level
o Product level
o Account level
o Transaction level
Dual control for all transactions
o Maker-Checker Concept
Controlled error handling through exceptions
o (1) Warning (2) Exception (3) Error
Finacle Overview
Finacle User Menu
Menu Block Favorites !
Main Menu
-> Sub Menu
-> Menu Description [Menu
Code] User Defined Favorites
MESSAGE AREA (A)
Menu Btn.1 Btn.2 Btn.3 Btn.4 Btn.5 Btn.6 Btn.7
(B)
Option Action Bar
630
Appendices
A = Progress Indicator
B = Field to Specify Menu Option
· Menu Block: The block houses all the menu and sub-menu options
available in Finacle.
· Menu Option Block: Menu Code to be entered to gain access to the
respective menu.
· Action Bar: User can execute the process of Finacle Operations by clicking
on various options on this bar. The Hot-Keys are also assigned for all
options, which appear on the bar.
· Action Buttons: Every action button has a specific purpose. E.g. On clicking
WhoAmI button, system will display user_id of the user who is currently
logged in & other information viz. date, name of SOL in a message box.
· Message Bar: The message bar displays warnings, exceptions, errors or
Lists under a specific field code.
· Favorites: Menu items which are required and used on Regular basis can
be put in favorites by copying from Menu Block. As a one time process
Specific Menu Item which is required to be copied to Favorites should be
located in Menu Block and with the use of Drag and Drop the function can
be stored under Favorites menu.
· Progress Indicator: It shows the progress of the action initiated through the
use of Colours (i.e. Green indicates that the System is "Ready" for
processing, Red indicates that the "System is busy in Processing Activity
and Yellow indicates that browser is performing internal processing like
assembling / painting screen as per requirement. User should not operate
the system)
General Key Map
Default Physical Keys in Finacle are as follows. However, default key map differs
in individual bank.
Physical Key What does it do?
F1 Field level help. Like in several word processors and
spreadsheet packages, F1 displays context sensitive help
messages and field level help messages.
List. This key lists the codes that may be used in a particular
F2
field.
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Guidance Note on Audit of Banks (Revised 2019)
Physical Key What does it do?
F3 / ESC Quit/ Back. Quits and takes the user back to where he started
when in action. It can be used when the input is incorrect and
the user wants to abandon what he has been doing. It can
also be used to go back to the previous menu.
F4 Accept. After the user has completed the input, this key can
be used to accept the data.
F5 Background Menu
F6 Next Block
F8 Copy Record
F9 Display Signature
F10 Commit/ Save. This is very important key and this concludes
the transactions. This is the commit and transactions get into
the General Ledger (database) when this key is used.
F11 Next field
F12 Previous Block
TAB Go to next valid field
ENTER Go to the next field
DOWN Arrow Next Record (In a list or result of a query)
(NextRec
button)
UP Arrow Previous Record (In a list or result of a query)
(PrecRec
button)
CTRL+F1 Help maintenance
CTRL+F3 Show key map
CTRL+F4 Display error
CTRL+F8 Terminal lock
CTRL+F9 Memo pad look up
CTRL+F11 Context level help
632
Appendices
Physical Key What does it do?
CTRL+D Page down on a list
CTRL+E Explode. This key is particularly useful for the further inquiry.
CTRL+F Clear field. This key combination can be used when the user
wants to clear the field.
CTRL+T Display LGI. The user ID, Terminal ID, SOL, BOD Date and
language details are displayed.
CTRL+U Page up on a list
CTRL+X Put BOD date. This key combination populates the default
BOD date in the field.
SHIFT+F4 Select the current item from the list. This key combination can
be used to select a value from the list of valid values listed for
a particular field.
SHIFT+F11 Transmit
SHIFT+TAB Go to the previous field
Introduction to TCS BaNCS
A Financial Package, for Banking Solution offered by Tata Consulting Services.
The Core Banking solution TCS BaNCS is an integrated solution that automates
all aspects of core banking operations across entities, languages and currencies.
BaNCS is built on open architecture, component-based product suite to leverage
service-oriented and event-driven architectures.
Functionalities
Entire range of banking products including savings, checking, overdraft and
deposit accounts
Entire range of lending products
Complement of transactional services including remittance, foreign
exchange, cards and trade finance
Accessibility through multiple channels, including mobile banking and web
Full integration of front-, middle-, and back-office processes
Accurate, timely and actionable information about customer relations
Single view between bank and customer
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Guidance Note on Audit of Banks (Revised 2019)
"Anytime anywhere" banking
Introduction to Oracle FlexCube
FlexCubeProvides a comprehensive, integrated, interoperable, and modular
solution that enables banks to manage evolving customer expectations.
Functionalities
24/7 processing of large transaction volumes, with high availability
Multiple delivery channel support
Security management covering application and role-based access
Service-oriented architecture supports agile business process management
Componentized architecture helps build scalable and reusable solutions
Quick access screens through Hot Keys in Flexcube
Hot Screen Name Description
Keys
Alt + B Balance This screen displays the account details of the
Inquiry savings and checking account balances such as
the available balance, nucleated balance, current
book balance, passbook balance, net balance, etc.
Alt + C Customer This screen displays the details such as the name,
Name And address, city, country, SSN/TIN number, etc of the
Address selected customer
Inquiry
Alt + A Account This screen displays the account details of the
Details customer such as account number, account
branch, account currency, customer name, etc.
Alt + S Amount based This screen displays the images on the basis of the
Account details maintained in the Amount Based Operating
Image Display Instruction Maintenance ( Fast Path: 7116) option
Alt + P This will enable the user to print the receipt of the
transaction.
F8 This will enable the user to return to the same
screen.
634
Appendices
General Concepts of CBS and of Finacle:
SOL ID & Set ID (Init. Br. ID)
SOL ID: Under Core Banking System, each Branch, Back Office,
Administrative / Controlling Office are assigned a code i.e. Service Outlet ID
[SOL ID]. It helps in identifying the Branch / Office under which the Account
is maintained. Hence, if a branch at Delhi is assigned a SOL ID of "0089",
the accounts opened under Delhi Branch will display "0089" as SOL ID in
CBS.
As discussed above under CBS any branch can initiate transaction for any of
the account maintained with the bank. Hence, a distinction is required
between the branch which maintains the account and the branch who initiate
the transaction.
Set ID (Init. Br. ID): Set ID or Initiating Branch ID is a SOL ID of the Branch
who initiated the transaction.
E.g.:
Transaction of a Cash withdrawal by a customer of Mumbai Branch (SOL ID
"0044") from Delhi Branch (SOL ID "0089"). In the instant case "0089" is Init.
Br. ID and "0044" is Account SOL ID.
In order to search transactions based on the branch who initiated
transactions in Finacle, SET ID (Init. Br. ID) parameter is required to be used
under Menu Code "FTI".
Tran ID, Journal No. & Date
Each transaction in Finacle will be assigned a unique Transaction ID. The
Transaction ID remains unique only for the day, since, on the next day the
Transaction IDs are reset.
Combination of Transaction ID and transaction date make it unique across
the system. In Finacle, once the transaction is "Entered", a Tran ID is
generated. To locate any transaction from the database the user need to use
Tran ID and Date at TI/TM Menu command.
Under BaNCS the transaction number is known as Journal Number.
Transaction Type & Subtype
Transactions in Finacle are entered with the Transaction Type and
Transaction Subtype. It easier to trace set of transactions with Transaction
Type & Sub Type.
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Guidance Note on Audit of Banks (Revised 2019)
Codes for Transaction Type and Sub Types are prescribed differently by
each bank.
E.g.:
Transaction Type codes for Cash and Transfer may be of following types.
Tran Type: Cash: "C", Transfer: "T"
Sub Tran Type: CR Cash Receipt, CP: Cash Payment
The auditor must acquaint himself with the Transaction Types used by each
bank. It helps auditors to design query (search parameters) for inquiry of
financial transactions.
Customer Master Level Configurations
Under CBS, the customer is identified by a number generally called CUST
ID / CIF No. Following are the advantages of separate configuration for
Customer and Accounts of Customer.
Identification of unique customers.
Data redundancy can be reduced by eliminating the process of updating
repetitive details about customer at each time of opening of Account.
It is easier to comply with Customer centric Regulations. E.g. TDS
provisions under Income Tax Act (where payment to customer is important
than payment for an account), IRAC Guidelines (where classification of
account is Borrower-wise and not Account-wise)
Multiple accounts of the customer can be mapped to a customer for better
identification.
Under the Customer Master Level configuration basic details about the customer
are updated. Details include Name, Date of Birth, PA Number etc.
Once the CUST ID / CIF is opened, various accounts can be opened under the
said CUST ID / CIF. Relationship between CUST ID/CIF No. and Account is that
of Parent and Child wherein the Account Master inherits the information and
parameter values from Customer Master.
In Finacle menu command CUMM / CUMI is used for inquiry on CUST ID / CIF
No. Under BaNCS the customer master details can be reviewed through
"Customer Master Details" module.
Important Points for Auditors:
636
Appendices
1. Issues with multiple CUST-ID:
In terms of guidelines issued by RBI on UCIC, each customer in bank is
required to be assigned a unique ID. However, it has been observed in
many banks that multiple CUST IDs have been opened for a customer. It
has also been observed that at the time of migration had migrated old
customer information to one CUST ID and have opened new CUST IDs for
opening of new accounts post migration.
Due to multiple CUST ID the vary purpose of having configuration of CUST
ID is defeated. The auditors should verify such discrepancies at the time of
account opening verification. Moreover, the auditors should also seek help
of bank's IT Dept. for generation of report based on combination of
information viz. Name, PAN, date of birth, employee code etc. to identify
existing cases of multiple CUST ID in the system.
2. Difference in customer's name at CUST ID and at Account Level:
At the time of opening of Account, Finacle automatically displays the name
of Account Holder based on CUST ID details. However, Finacle also allows
user to amend the name. Generally the said change is configured as an
exception which requires sufficient powers / work class in the system to
override.
The Auditor at the time of Account Opening verification should verify the
details as per CUST ID and in Account. Difference in names at both the
places increases unwarranted confusion. Moreover, auditor should seek
help of bank's IT Dept. for generation of report based on difference in name
as per CUST ID and as per Accounts opened (if any).
Account Level Configurations
Configurations / parameters for are setup at the time of Account Opening.
Modification afterwards is also permitted.
Account Level master contains the parameters and details specifically with
respect to account. For instance, Interest Rate, Interest payment periodicity,
Freeze, Lien etc.
It is important to note here that under CBS majority of functions and
transactions are master driven and hence, any minor error at Master Level
(whether Customer Master or Account Master) can have magnanimous
effect on transaction processing. E.g. if Interest Collection Flag is selected
as "N" at Account Master Level, the system will not collect any interest.
Hence, accuracy of master is a vital audit area.
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Guidance Note on Audit of Banks (Revised 2019)
Pointing Type Accounts / Self Reconciling Accounts
Apart from maintaining Customer Accounts, the bank's general ledger also
contains various Suspense / Sundry Accounts. Such accounts can be with
Debit or Credit balance.
The said accounts are used for limited purpose and for parking of entries for
limited time frame. Transactions wherein either Debit / Credit leg is not
confirmed / identifiable at the time of Transactions are parked in such
accounts. E.g. An amount of Rs. 1,000 is given to an employee in advance
for purchase of Stationery item for branch. The said transaction will be kept
under such Suspense / Sundry account till the date the employee submits
the bill / returns the advance.
The transactions processed in such accounts are not routine hence it calls
for continuous monitoring and earliest reversal. Moreover, numerous
transactions in an office account make it difficult for reconciliation. In earlier
times, the activity of reconciling the office account was manual.
However, under CBS such accounts are opened under Pointing Type Office
Account / Self Reconciling Accounts Scheme Code which facilitates
automatic reconciliation and real-time information on outstanding / non-
reversed transactions.
Transactions in such type of accounts are in two parts. i) Originating
Transaction ii) Reversal Transaction. For each reversal entry, the system will
prompt the user to point it to an originating transaction. There can be
multiple reversals against single originating transaction. Such type of
Account will also ensure that in case of a Debit Type Office Account, Credit
entry as Originating entry will not be permitted.
On the users side, at the time of reversal of Transaction the system will ask
the user to "Point" the Originating Transaction against which the transaction
is being reversed. On selection, the system will reduce the balance under
the said Originating Transaction. Under this type of Pointing Type Account,
at any given point of time aggregate of outstanding transaction-wise balance
will be equal to the Office Account Ledger Balance.
Under Finacle, verification of outstanding / non-reversed entries can be
verified from menu command IOT (Inquire on Transaction). Moreover, a
report on outstanding office account transaction can be generated through
Menu MSGOIRP. Various customized reports for the said purpose are also
available under each banks "Report" menu in Finacle.
Under BaNCS, the outstanding entries are available through offline reports
viz. "Audit BGL accounts age wise break up" and "GL-Outstanding-Accnts"
report.
638
Appendices
Interest Table Maintenance
Interest collection as well as payment in CBS can be through Interest Tables
or can be by way of absolute rate. In case a loan account wherein Interest
Rate is based on a reference rate (say Base Rate), the Interest Rate field is
updated with the Reference Rate Table to ensure automatic updation of
Interest on subsequent change.
In case of Interest Table master, the primary rate is sourced from a Master
Table. For instance, in case of Loan sanctioned as Base Rate + 3 %
whereas Base Rate at the time of Sanction was 10%, the Interest Rate field
will be updated either with BR+3 Table code or with BR Table with 3%
updated in Account Preferential Debit Interest with +3%. Method of updation
of interest may differ from bank to bank.
In case of few specialized products (e.g. subsidy linked accounts) limit level
interest rate is required to be applied. In such case the parameters are setup
at Interest Table Master Level and the said table code is updated under
Interest Table field at Account Master Level.
In case of a fixed rate loan, the interest rate is updated as absolute figure in
Interest Rate field instead of Table. However, few banks follow the practice
of updating "ZERO Interest Rate Table" with necessary interest rate at
Account Preferential Debit Interest.
Interest Flags
Values at Interest Flags determine the payment & collection of Interest.
Applicable flags (i.e. Interest payment, Interest collection) are required to be
updated at Account Master Level. Hence, if the Interest Collection Flag is
updated as "N", there will not be charging of interest by system, although
proper Interest Table Master is selected.
Withholding Tax Flags
Interest payment to the customer is aggregated at Customer Master Level
(i.e. for all the accounts opened under a CUST ID / CIF No.). The threshold
limit for TDS is computed based on the amount aggregated at CUST ID
Level. Once the payment of Interest exceeds minimum threshold level
prescribed under Income Tax provisions, the system initiates deduction of
taxes from Interest. However, for cases wherein customer has submitted
Form 15H/ 15G / tax exemption certificate, necessary flags are required to
be updated to prevent deduction of taxes upto the enhanced limit (as
applicable).
Withholding Tax flags are available at both CUST ID and Account Master
Level. With the recent change in the Income Tax guidelines w.r.t. online
submission of details of Form 15G/15H, the exemption is required to be
639
Guidance Note on Audit of Banks (Revised 2019)
flagged at CUST ID level for the amount of Interest Income declared by the
customer.
In Finacle, withholding (TDS) flags are driven by Tax Slab. For each type of
customer different tax slabs have been defined at Master Level e.g. TDS for
individuals, TDS for corporate, TDS for exempt entities. It is important for
auditor to verify correctness of Tax Slab vis a vis constitution of customer.
Freeze Flags (Debit, Credit and Total)
In case of court order, dispute between the joint account holders, recovery
notice from revenue authority the transactions in accounts are required to be
suspended. Depending upon the requirement the transactions are
suspended (viz. Debit, Credit or all) through Freeze Flags.
The freeze can be applied at CUST ID Level (i.e. all the accounts of the
customer) or specific account of the customer. The source documents are
required to be verified for marking of freeze and unfreeze event. The inquiry
of accounts with Freeze Flag can be made in Finacle through ACS Menu
Command with Freeze Flag as "T"=Total Freeze, "D"=Debit Freeze,
"C"=Credit Freeze.
Schemes & Scheme Codes
Different types of account products are offered to customer with different
characteristics. For instance, various types of Savings Accounts are offered.
The aggregation of account balance for such cases will take place at Sub GL
& GL Level. However, for account operations and account master setup
different schemes are setup in CBS. Scheme Code acts as a placeholder.
Inquiry for different types of accounts can be made in Finacle through ACS
Menu Command with "Scheme Code".
Exception Types
The transaction errors are handled in CBS through following modes.
Warning Warns user for possible errors based on prefixed criteria
Exception Allows user (with sufficient power) to override. However,
the transaction will be recorded in Exception Report for the day
Error Does not allow user to proceed further, unless the correct values
are filled in.
Maker & Checker Matrix for valid transaction
Under CBS the transactions are processed by atleast two officials of the
bank under Maker and Checker mode. The same is tracked through the
640
Appendices
transaction events (viz. entry, posting and verification). Posting is the event
which updates the GL Balance. Posting activity depends on the rights
assigned to each user ID.
Inventory Locations
The inventory concept under CBS refers to handling of security stationeries
viz. Non-personalized cheque books, Demand Drafts, Term Deposit
Receipts. Each bank, as per the requirement, creates different inventory
location and inventory sub location codes in CBS.
Predominantly, locations are created for Joint Custody (Dual Custody),
Employee Custody, External Locations. Barring, external location, balancing
of security stationery is available for all the locations.
In Finacle the report on outstanding inventory items can be generated
through Menu command ISRA. Whereas under BaNCS the same set of
reports can be generated through VPIS (Valuable Paper Inventory System)
module.
Zones in Clearing Modules
For easy identification of Type of cheque and proper reconciliation various
zones are opened on daily basis (as per clearing cycle) in CBS.
Various zones are opened for Non CTS Cheques, Interbank Cheque, KYC
Cheques, MICR Cheques, Non-MICR Cheques, Warrants, CMSCheques
etc.
Opening of Zone is the primary event before lodging any Inward Clearing
instrument or Outward Clearing Instrument.
Limit and Limit Node
Under Finacle the Limit Management is done through Limit Node
Maintenance. Wherein, the limits are specified at each node level with
capping.
Credit Limits can be set at Account Level as well as at Node Level for
deriving the Drawing Power for a customer. Setting up of Limit at
Node level has following advantages.
i. Managing two or more accounts with drawing power deriving
from the same security.
ii. Interchangeability of limits among different accounts.
iii. Monitoring the overall exposure to a single client / group of
clients.
641
Guidance Note on Audit of Banks (Revised 2019)
iv. Exposure to a select commodity / security. Limit Node
Maintenance helps to build these requirements in the limit
management
Limit Node:
i. Limit nodes are used to group accounts under one node to
enable easy monitoring and organization.
ii. A limit node can be linked to a security for deriving drawing
power.
iii. Distribution of overall group (group may be a group of clients or a
group of accounts) limits to individual members (members may
be accounts or clients) is possible through creation of Parent
Node and Child Nodes.
iv. Every child node can further be distributed to group of accounts
or clients.
v. This is diagrammatically explained through below example.
Facility Particulars Limit Remarks
Type (Rs.
Lacs)
Funded Term Loan 225 Funded Limit Cap is 500 Lacs
WCDL 75 Upper Limits fixed in each
type of Facility
CC 200
BP / FBP / BD 50
Total Funded Facilities 500
Non- LC 300 Non Funded capping is at Rs.
Funded BG 300 500 Lacs
Total Non-Funded Facilities 500
Total Company Exposure 1000 Total Exposure to Company
should not exceed 1,000
Lacs
Temporary Overdraft (TOD) Setup:
Granting of TOD to a customer is a credit decision from Bank's perspective.
Auditor has to review the source documents and delegated powers to
ascertain whether the sanction was inline with the guidelines prescribed by
the bank.
642
Appendices
Setup of TOD is done in Finacle as follows. TOD is granted to an account
under various circumstances. For instance,
Type Event Mode
TODIC Interest Calculation Single
TODDL Drop in Limit Single
TODMN / TODUG Manual / User Generated Single / Running / Adhoc
Explanation of various TOD modes is as follows.
Mode Narrative
Single (S) It refers to TOD for specific Purpose / transaction. It can be
used only for the specific transaction during which the same
was granted.
Running (R) It refers to setting up of a parallel limit at account level for a
defined period over and above credit limits (if any).
Adhoc (A) Adhoc allows customer with OD / CC Accounts to operate
within TOD Limits for defined period.
From above narrative it appears that running and adhoc TODs serve the
same purpose. However, from CBS perspective, both the events are
different. In case of single and running TOD, CBS computes the number of
TOD sanctioned in the account. In case the cumulative number exceeds the
prescribed limit for an account, an exception gets triggered for all
subsequent transactions. Whereas in case of Adhoc TOD the said TOD is
not counted under number of TODs thereby circumventing the exception
controls embedded in the system.
It is important for auditors to verify cases wherein Adhoc Limits have not
been delinked on expiry in system.
Register Type& Subtype (Trade Transactions)
The concept of Register Type and Sub Type is same as Transaction Type
and sub types as discussed above. The types are used to aggregate
transactions of same nature in system. It helps in identifying and tracking of
transaction in a better manner. In Finacle, Register Type and Sub Types
have been used in Inland Trade Transaction and Foreign Trade
Transactions modules.
643
Guidance Note on Audit of Banks (Revised 2019)
List of few Register Types and Subtypes for an Import Transactions is as
follows.
Reg. Type Sub Type
Import Bill on Collection Sight
Import Bill on Collection Usance
Import Bill under LC Sight
Import Bill under LC Usance
Direct Import Bill TT (Telegraphic Transfer) / DD (Foreign
Demand Draft)
Advance Remittance against TT (Telegraphic Transfer) / DD (Foreign
Import Demand Draft)
644
APPENDIX IX
List of Important Menu Commands of CBS
Following is the list of various important menu commands for Auditors
based on area of operations in the bank.
i. Accounts, Customer Master and Inquiry
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 7 CUMM / CUMI Customer Master Inquiry
Maintenance / Inquiry
Finacle 7 ACM / ACI Account Master Inquiry
Maintenance / Inquiry
Finacle 7 ACLI Account Ledger Inquiry Inquiry
Finacle 7 ACCBAL Component of Account Inquiry
Balance Inquiry
Finacle 7 ACS Account Criterion Search Inquiry
(Search /
Criterion
based)
Finacle 7 CUS Customer Selection / Inquiry
Inquiry (Search /
Criterion
based)
Finacle 7 ACINT Interest Run for Accounts Inquiry /
Report
Finacle 7 INTTM Interest Table Master Inquiry
Maintenance
Finacle 7 AFI Audit File Inquiry Inquiry
Finacle 10 CRM Module Customer Master Inquiry &
maintenance Modifications
Finacle 10 HACLI, HACLINQ Account Ledger Inquiry Inquiry
645
Guidance Note on Audit of Banks (Revised 2019)
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 10 HACM, HACMTD Account Master, Account Inquiry
Master Term Deposits
Finacle 10 HINTTM Interest Table Master Inquiry
Maintenance
Finacle 10 HAFI Audit File Inquiry Inquiry
BaNCS Customer To verify all accounts of Inquiry
Management -> one Customer
Enquiries ->
Search by CIF
Number
BaNCS Customer Search using available Inquiry
Management -> information (ID Number)
Enquiries ->
Search by ID
Number
BaNCS Customer Search using available Inquiry
Management -> information (Name)
Enquiries ->
Search by Name
BaNCS Customer Inquiry on Linked Accounts, Inquiry
Management -> Owned Accounts etc.
Relationship /
Ownership ->
Associated
Accounts
FlexCube CH021 Account Master Inquiry
Maintenance
FlexCube CH701 Customer account Inquiry
balances-Other than loans-
For standard accounts but
including CC limit accounts
FlexCube CH703 RD account balances- Inquiry
Customer wise
646
Appendices
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
FlexCube 2000 CTI Customer Search Inquiry
FlexCube 7004 Customer Name and Inquiry
Address Inquiry
FlexCube 7100 All Balance Inquiry Inquiry
FlexCube 7105 Display Customer Image Inquiry
FlexCube BA095 Account Level Attributes Inquiry
Inquiry
FlexCube 7002 Balance Inquiry Inquiry
FlexCube CH031 Statement Inquiry Inquiry
FlexCube BAM24 Account Status Audit Trail Inquiry
Inquiry
FlexCube 1337 Term Deposit Interest Inquiry
Payout Inquiry
FlexCube 7020 TERM DEPOSIT Balance Inquiry
Inquiry
FlexCube TD023 TERM DEPOSIT Rates Inquiry
History Inquiry
FlexCube TD031 TERM DEPOSIT Audit Trail Inquiry
Inquiry
FlexCube TD037 TERM DEPOSIT Account Inquiry
Ledger Inquiry
FlexCube TD050 TERM DEPOSIT Interest Inquiry
Inquiry
FlexCube TD11 TDS Inquiry Inquiry
ii. Transactions
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 7 TM / TI Transaction Maintenance / Inquiry
647
Guidance Note on Audit of Banks (Revised 2019)
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Inquiry
Finacle 7 FTI Financial Transaction Inquiry
Inquiry (Search /
Criterion
based)
Finacle 7 FTR Financial Transaction Report
Inquiry Report
Finacle 10 HTI Transaction Maintenance / Inquiry
Inquiry
Finacle 10 HFTI Financial Transaction Inquiry
Inquiry (Search /
Criterion
based)
BaNCS Deposit / CC / OD Transaction Enquiry Inquiry
Accounts &
(Additional options
Services ->
available: Transaction
Enquiries ->
Types: 99 All Financial,
Transaction
98 Cash Transaction, 25
Repayment Details, 33
Message Details
BaNCS -> Branch BGL Transaction Enquiry Inquiry
Accounting (BGL)
-> Enquire ->
Transaction
FlexCube TD044 TD Transactions Inquiry Inquiry
FlexCube LN058 Loan Interest Adjustment Inquiry
Transaction
FlexCube PM025 Payment Transaction Inquiry
Inquiry
FlexCube GLM04 GL Transactions and Inquiry
Movements Inquiry
648
Appendices
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
FlexCube AT002 Audit Trail Financial Inquiry
Transactions Inquiry
FlexCube BA777 Audit Trail Inquiry for Non- Inquiry
Financial Txns
iii. Clearing Transactions
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 7 MCLZOH Maintain Clearing Zone Inquiry
Finacle 7 OCTM Outward Clearing Inquiry
Transaction Maintenance
Finacle 7 ICTM Inward Clearing Inquiry
Transaction Maintenance
Finacle 10 HOCTM Maintain Clearing Zone Inquiry
Finacle 10 HICTM Outward Clearing Inquiry
Transaction Maintenance
Finacle 10 HMCLZOH Inward Clearing Inquiry
Transaction Maintenance
BaNCS Collection and Inquiry for Cheque Inquiry
Cheque Purchase / on Collection
Purchase ->
Enquiries ->
Enquiries
FlexCube ST023 Outward Clearing Inquiry
FlexCube ST033 Inward Clearing Inquiry
FlexCube BA990 Clearing Inquiry Inquiry
FlexCube ST002 Value Date Clearing Inquiry Inquiry
649
Guidance Note on Audit of Banks (Revised 2019)
iv. Office Accounts Maintenance
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 7 ACLPOA Account Ledger Print Office Report
Account
Finacle 7 IOT Inquire on Transaction Inquiry &
Report
Finacle 7 MSGOIRP Outstanding Items Report Report
Finacle 10 HIOT Inquire on Transaction Inquiry &
Report
Finacle 10 HACLPOA Account Ledger Print Office Report
Account
BaNCS -> Branch Enquiry on BGL Account Inquiry
Accounting (BGL)
-> Enquire ->
Account
BaNCS -> Branch Search an Account Number Inquiry
Accounting (BGL) by BGL Name
-> Enquire ->
Account Number
Search
BaNCS -> Branch BGL Transaction Enquiry Inquiry
Accounting (BGL)
-> Enquire ->
Transaction
Flexcube GLM01 GL Voucher Entry Inquiry
Flexcube GLM02 Chart of Accounts Inquiry
Flexcube GLM04 GL Transactions and Inquiry
Movement Inquiry
Flexcube 1005 Miscellaneous GL Transfer Inquiry
(Dr/Cr)
650
Appendices
v. Loans & Advances
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 7 SRM Security Register Inquiry
Maintenance
Finacle 7 HCLM / CLL Collateral Maintenance Inquiry
Finacle 7 ACHLM Account History Limit Inquiry
Maintenance
Finacle 7 ALM Account Lien Maintenance Inquiry
Finacle 7 ACTODM Account TOD Maintenance Inquiry
Finacle 7 TODRP TOD Register Printing Inquiry
Finacle 7 PSP Pass Sheet Print Report
Finacle 7 ACLPCA Account Ledger Printing Report
Finacle 7 LAGI Loan General Inquiry Inquiry
(Criterion
based
search)
Finacle 7 LAOPI Loan Overdue Position Inquiry
Inquiry (Criterion
based
search)
Finacle 7 LTL Limit Tree Lookup Inquiry
Finacle 7 LNDI Limit Node Inquiry Inquiry
Finacle 7 AINTRPT Interest Report for Accounts Report
Finacle 10 HSCLM Security Register Inquiry
Maintenance
Finacle 10 HALM Account Lien Maintenance Inquiry
Finacle 10 HACTODM Account TOD Maintenance Inquiry
Finacle 10 HPSP Pass Sheet Print Report
Finacle 10 HACLHM Account Limit History Inquiry
Maintenance
Finacle 10 HAINTRPT Interest Report for Accounts Report
Finacle 10 HINTPRF Interest Proof Report Report
651
Guidance Note on Audit of Banks (Revised 2019)
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
BaNCS Deposit / CC / OD To verify the Account Inquiry
Accounts & Master Details
Services ->
Enquiries ->
Deposit / CC / OD
Account
BaNCS Deposit / CC / OD Printing Statement of Report
Accounts & Account for a Deposit or CC
Services -> / OD
Enquiries ->
Statement Print
BaNCS Deposit / CC / OD Basic details on Enquiry on Inquiry
Accounts & Screen on Deposit
Services -> Accounts
Enquiries -> Short
BaNCS Deposit / CC / OD Additional Details on Inquiry
Accounts & Enquiry Screen for Deposit
Services -> Accounts
Enquiries -> Long
BaNCS Deposit / CC / OD Details of changes in Inquiry
Accounts & Interest Rate for an account
Services -
>Interest Rate
History
BaNCS -> DL/TL Loan account operations Inquiry
Accounts &
Services -> Loan
Tracking ->
Operations
BaNCS -> DL/TL To print Repayment Report
Accounts & schedule for a DL / TL
Services -> Loan Account
Processing ->
Generate
Repayment
Schedules -
652
Appendices
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
>Action "E"
BaNCS -> DL/TL To view amount of Arrears Inquiry
Accounts & & Breakup of Principal,
Services -> Interest Realized, Charges
Enquiries -> Short & Arrear of Interest
-> Option
"Balance Breakup
Enquiry"
BaNCS -> DL/TL Enquire on linked collateral Inquiry
Accounts &
Services ->
Security (Primary /
Collateral) ->
Customer ->
Enquiry ->
Enquire Security
Summary
FlexCube CH066 Limit Collateral Inquiry Inquiry
FlexCube CHM06 OD Collateral Maintenance Inquiry
FlexCube CHM07 OD Limit Master Inquiry
Maintenance
FlexCube ST070 Cheque Purchase Inquiry
FlexCube CH033 Average Quarterly / Monthly Inquiry
Balance Inquiry
FlexCube TDM24 Lien Master Inquiry
FlexCube 1413 Loan Disbursement Inquiry Inquiry
FlexCube LN522 Account Schedule Inquiry Inquiry
FlexCube LNM10 Account Transactions Inquiry
Inquiry
FlexCube BA433 Collateral To Accounts Inquiry
Inquiry
FlexCube BA434 Account To Collateral Inquiry
Inquiry
653
Guidance Note on Audit of Banks (Revised 2019)
vi. DD / PO, Cheque Book maintenance, Stop Payments and Security
Stationery maintenance
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 7 DDSM DD Status Maintenance Inquiry
Finacle 7 DDIP Inquiry on Specific DD Paid Inquiry
Finacle 7 ISRA Inventory Status Report Report
Finacle 7 IMI Inventory Movement Inquiry Inquiry
Finacle 7 ICHB Issue Cheque Book Inquiry
Finacle 7 CHBM Cheque Book Maintenance Inquiry
Finacle 7 SPP Stop Payment of Cheque Inquiry
Finacle 7 SPRG Stop Payment Register Report
Finacle 10 HDDSM DD Status Maintenance Inquiry
Finacle 10 HDDIP Inquiry on Specific DD Paid Inquiry
Finacle 10 HISRA Inventory Status Report Report
Finacle 10 HIMI Inventory Movement Inquiry Inquiry
Finacle 10 HICHB Issue Cheque Book Inquiry
Finacle 10 HCHBM Cheque Book Maintenance Inquiry
Finacle 10 HSPP Stop Payment of Cheque Inquiry
Finacle 10 HSPRG Stop Payment Register Inquiry
BaNCS -> Valuable Paper To check inventory status Inquiry
Inventory System
[VPIS] -> Enquiry
of VPIS ->
General Enquiry
BaNCS -> VPIS -> Lost / Location for Lost / Inquiry
Damaged / Damaged / Cancelled
Cancelled Inventories
Inventories
BaNCS -> VPIS -> Details of Inventory Inquiry
Enquiry of VPIS - available at Teller level
>Teller Level
654
Appendices
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Inquiry
FlexCube CH078 Cheque Status Inquiry
Maintenance
FlexCube CHM35 Stop Cheque Instructions Inquiry
FlexCube CHM37 Cheque Book Issue Inquiry
Maintenance
FlexCube IV011 Stock Inquiry Inquiry
FlexCube IV004 Inventory Lost report Inquiry
Register maintenance
FlexCube MCA80 Inquiry of sold/issued Inquiry
inventory
vii. Compliances
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 7 TDSIP TDS Inquiry / Print Inquiry and
Report
Finacle 7 AFSM Account Freeze Inquiry
Maintenance
Finacle 10 HTDSIP TDS Inquiry / Print Inquiry and
Report
Finacle 10 HAFSM Account Freeze Inquiry
Maintenance
FlexCube TDS06 Tax Parameters Inquiry
Maintenance
FlexCube TDS04 Tax waiver criteria Inquiry
Maintenance
FlexCube TDS05 Customer special Tax code Inquiry
maintenance
FlexCube TDS11 Tax Inquiry Inquiry
655
Guidance Note on Audit of Banks (Revised 2019)
viii. Trade Finance and Foreign Exchange Transactions
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 7 INBOEM Bill of Entry Maintenance Inquiry
Finacle 7 BI Bills Inquiry (Inland) Inquiry
(Criterion
based
search)
Finacle 7 BP Bills Inquiry (Inland) Report
Printing
Finacle 7 BM Bill Maintenance (Inland) Inquiry
Finacle 7 FBI Foreign Bill Inquiry Inquiry
(Criterion
based
search)
Finacle 7 FBM Foreign Bill Maintenance Inquiry
Finacle 7 FBP Foreign Bill Inquiry Report
Printing
Finacle 7 BRBPR Balancing Report for Bills Report
Purchased (Inland)
Finacle 7 BRCR Balancing Report for Bills Report
on Collection (Inland)
Finacle 7 FBBR Balancing Report for Report
Foreign Bills
Finacle 7 DCQRY Documentary Credit Query Inquiry
(Criterion
based
search)
Finacle 7 GI Guarantee Inquiry Inquiry
Finacle 7 IRM Inward Remittance Inquiry
Maintenance
Finacle 7 ORM Outward Remittance Inquiry
Maintenance
656
Appendices
CBS Menu Code / Menu Name Menu Type
Package Access path (Inquiry /
Report)
Finacle 10 HINBOEM Bill of Entry Maintenance Inquiry
Finacle 10 MIIB Maintain Import & Inward Inquiry
Bills
Finacle 10 MEOB Maintain Export & Outward Inquiry
Bills
Finacle 10 IBL Bill Inquiry Inquiry
(Criterion
based
search)
Finacle 10 HBRBPR Balancing Report for Bills Inquiry
Purchased (Inland)
Finacle 10 HBRCR Balancing Report for Bills Inquiry
on Collection (Inland)
Finacle 10 HFBBR Balancing Report for Inquiry
Foreign Bills
Finacle 10 HGI Guarantee Inquiry Inquiry
Finacle 10 HIRM Inward Remittance Inquiry
Maintenance
Finacle 10 HORM Outward Remittance Inquiry
Maintenance
FlexCube SY001 Guarantee Inquiry Inquiry
FlexCube BIM04 Bill Parameters Inquiry
Maintenance
FlexCube BIM05 Bills Processing Inquiry
Maintenance
FlexCube BI001 Bills Data Entry Inquiry
657
Guidance Note on Audit of Banks (Revised 2019)
Note:
The discussion of Menu codes / commands in this chapter is only for guidance of
members. The purpose of inclusion of the same here is to understand functioning
of banking software. Moreover, with the continuous changes and customization
requests by banks, all the menu codes may not be available / accessible in all
the banks.
The Finacle menu codes discussed in this chapter is for version 7 (except
expressly mentioned). Finacle has introduced new version namely Finacle 10.X.
Few banks have already migrated to newer version and few more are in process
of migration. Under Finacle 10.X there are changes in Menu Codes apart from
other navigational changes.
Disclaimer:
Images, Logo, Screen Shots, Menu Codes, Software Name etc are the property
of respective Software developer / Trademark owners.
658
APPENDIX X
Illustrative Checklist on Audit activity through
CBS
1. Parameters affecting automatic identification of NPAs and re-designing
of audit processes
In terms of directives issued by Ministry of Finance and Reserve Bank of
India, it is mandatory for banks to identify the bad loans through CBS /
Systems instead of conventional methods. CBS like other software work on
GIGO principle. Master Data play an important role in correct identification of
Bad Loans.
Following are few scenarios wherein incorrect updation in Master Data,
manipulation through transactions etc. may impact correct identification of
bad loans through CBS.
Parameters Auditors' Primary Suggested System Support
Checks
Discrepancies Whether EMI / Finacle:
in setting up installment is ACI -> Option "E"
the EMI / correctly setup. Repayment details
Installments Whether EMI / BaNCS:
installment amount is
DL/TL Accounts &
matching with the
Services -> Enquiries ->
Sanctioned Terms.
Account
Whether periodicity of
Deposit / CC / OD
Installment is
Accounts & Services ->
correctly classified as
Enquiries -> Deposit / CC /
per Sanctioned
OD Account
Terms?
(Short & Long Inquiry
options are available under
both menu.)
Multiple sets of For case of Multiple Finacle:
EMI / sets of EMI e.g. For ACI -> Option "E"
Installments 1-5 years EMI of Rs. Repayment details
7,000 and after 5
BaNCS:
659
Guidance Note on Audit of Banks (Revised 2019)
Parameters Auditors' Primary Suggested System Support
Checks
years Rs. 7,500 DL/TL Accounts &
Whether sets of EMI Services -> Enquiries ->
are properly entered? Account
Is there any Deposit / CC / OD
substantial difference Accounts & Services ->
between 1st set of Enquiries -> Deposit / CC /
EMI and 2nd or other OD Account
sets (e.g. 1st set Rs. (Short & Long Inquiry
5,000 and 2ndRs. options are available under
1,00,000) which cast both menu.)
doubt on debt
serviceability?
System CBS contain two sets Finacle:
determined of parameters. At first ACM / ACI Option `Y'
Asset instance CBS identify Asset Classification
Classification the account based on Inquiry
vis a vis User set parameters under
A report containing
defined Asset Asset Classification
accounts wherein there is
Classification types.
difference between Asset
In few CBS it has Classification by System
been observed that and by user should be
user is generally requested for. Accounts
given the option to listed in the said report
differ and select / should be thoroughly
amend the verified.
classification. In such
cases detailed
scrutiny of NPA
system is required to
be carried out.
Due to errors in
certain Master Data,
there can be
erroneous
identification of
account as NPA.
However, such
accounts require
660
Appendices
Parameters Auditors' Primary Suggested System Support
Checks
detailed scrutiny.
Manipulation Changes in SL / DP Finacle:
in SL / DP should be cross ACLHM Account Limit
checked with History Maintenance
Sanctioned Letter.
BaNCS:
Whether any change
Tailormade report on
in Limit is supported
Changes in Account Limits
by necessary
documentation?
Incorrect Based on moratorium Finacle:
moratorium period CBS will ACI Option "E"
period identify the Loan Repayment Details
Installment and will
BaNCS:
track repayment.
Account Master details
In case the
(Long Inquiry)
moratorium period /
installment start date
is erroneously
updated system will
not show correct
result.
Re-phasement Loan Account Finacle:
without Installments are ACI Option "E"
reporting it as rephased / Repayment Details
reschedule recalibrated without
BaNCS:
reporting the same as
Re-schedule. Account Master details
(Long Inquiry)
Verify whether any
change in Repayment Report containing details
instruction is made of all the cases wherein
through System. EMI / Installment is
Compare the said changed should be sought
accounts with list of
Restructured
Accounts.
Installment Check whether Finacle:
Start Date is Installment Start Date ACI Option "E"
entered as per
661
Guidance Note on Audit of Banks (Revised 2019)
Parameters Auditors' Primary Suggested System Support
Checks
Future Date sanctioned term? Repayment Details
In case of future date BaNCS:
system will not Account Master details
identify installment (Long Inquiry)
and any repayment
received will be
shown as "Overflow".
Interest Check whether Finacle:
Demand date Interest Start Date ACI Option "E"
(Future Date) entered is as per Repayment Details
Sanctioned Term?
BaNCS:
In case of future date
Account Master details
as Interest Demand
(Long Inquiry)
Date system will not
accrue interest and
any repayment
received will be
shown as "Overflow".
Fictitious Are there any quarter Finacle:
credit through / year end credits ACLI (Use CTRL + E to
Office Account cited in the account? Explore the Tran)
/ Inter-branch Check the source of Review of Office Account
Account Credit Entries. Ledgers
Review transactions BaNCS:
in Office Accounts /
Deposit / CC / OD
Inter Branch
Accounts & Services ->
Accounts.
Enquiries -> Transaction
DL/TL Accounts &
Services -> Enquiries ->
Transaction
Round tripping Close scrutiny of Finacle:
from internal transaction and ACLI (Use CTRL + E to
accounts review of chain / Explore the Tran)
series of transaction
Using only Account
for accounts with
Turnover Information
deficiency is required.
generated through "ATOR"
Such transactions will / "CUTI" / "ACTI" menu
662
Appendices
Parameters Auditors' Primary Suggested System Support
Checks
inflate the Credit may lead to incorrect
Turnover in the inference, since the credits
account. are not solitary credits in
account.
BaNCS:
Deposit / CC / OD
Accounts & Services ->
Enquiries -> Transaction
DL/TL Accounts &
Services -> Enquiries ->
Transaction
Temporary Check whether the Finacle:
Overdrafts TOD is sanctioned in ACLI Option "O"
order to bring the
TODRP TOD Register
overdrawn limit to
Printing
base level additional
facility through TOD BaNCS:
is sanctioned. TOD Report
Devolved bills Devolved Bills under Finacle:
parked in LCs are required to BI & FBI with Bill Status
Office be debited to the as "K" using status date
Accounts and Limit Accounts only. filter
not in limit Assessment of Asset
BaNCS:
account Classification will be
based on composite Report on Devolved bills under
overdrawn portion Import LC
Limit + LC Devolved
amount (if any on
devolvement)
Check whether the
amount of
devolvement of LC
backed bills are
parked in Office
Accounts or any
separate account?
Multiple CUST Check whether Finacle:
ID to prevent multiple CUST IDs ACS Account Selection
663
Guidance Note on Audit of Banks (Revised 2019)
Parameters Auditors' Primary Suggested System Support
Checks
the other have been opened for (Search based on Name)
account from the borrower with LAGI Loan Account
becoming NPA different accounts? General Inquiry (Inquiry
NPA Report and based on other
search all the case by parameters)
few characters of BaNCS:
Name.
Customer Management ->
Enquiries -> Search by
Name
2. Parameters affecting collection of Interest / Revenue
Primary revenue for banks is Interest on Loans and Advances. Charging of
Interest is completely automated barring few products. However, the
processing is based on certain important parameters. System parameters /
fields which affect the Interest Computation should be thoroughly verified.
Important Interest Parameters
Interest Table
Debit Interest Rate & Credit Interest Rate
Interest Version
Currency
Limit Level Interest
Penal Interest
Interest Rate (Static / Absolute & Based on Ref. Rate)
Interest Preferential Customer Level: Interest Rate preference will be
applied to all the accounts of the customer based on type of Interest.
Debit Interest Preferential
Positive preference value
Negative preference value
Credit Interest Preferential
Positive preference value
Negative preference value
Interest Preferential Account Level: Interest Rate preference will be
applied to the specific account wherein the preference is updated.
664
Appendices
Debit Interest Preferential
Positive preference value
Negative preference value
Credit Interest Preferential
Positive preference value
Negative preference value
System Support / Important Menu Codes:
Finacle: INTCI, AINTRPT, INTPRF, INTTM
TCS Bancs: i) OD/CC Accounts -> Interest Rate History ii) DL / TL -
> Interest Rate History
Following are few events / scenarios wherein there is a possibility of non
application / incorrect application of Interest.
Sr. Event / Scenario
No.
1 Interest pegging in Advance Accounts set as "Y". (If "Y" is selected,
system will charge interest at the rate prevailing at the time of
Account Opening. For the cases of Fixed Rate Loans Pegging Flag
will be "Y")
2 Future Date is updated in Interest Demand Date
3 Interest on Principal / Payment of Interest Flag is set as "N"
4 Effective Rate of Interest is updated as "0"
5 Account Open and Installment Start Dates are identical.
6 Account Open and Interest Demand Dates are identical.
7 Interest Table Code "Zero" is selected
8 Interest Demand Date is Past Date
9 Interest Demand Frequency is Blank.
3. Audit of Foreign Exchange Transactions with the use of CBS
The liberalization of economy is paving way for opening of new areas for
Inbound and outbound investment. Moreover, with the increase in the global
trade the foreign exchange and cross border transactions are increasing at a
rapid speed. However, it also poses challenge of preventing misuse of
regulations and money laundering activities.
665
Guidance Note on Audit of Banks (Revised 2019)
Following are few activities that the auditor must carry out for audit of
Foreign Exchange Transactions.
Audit Activity Important Menu Codes of Finacle
Review of Letter of Credits For Inquiry DCQRY
issued, Expired, Search on
For Report DCREG, DCRPTS,
Outstanding LCs
DCSTMT
Review of Bank Guarantee For Inquiry GI
issued, invoked, closed,
For Report GILR, GPI
outstanding, Search on expired
BGs
Audit of Inland Bills (under For search: BI
collection, under LC, discounted)
Search result printing: BP
For specific bill: BM
Audit of outstanding Inland Bills Report BRCR (Collection Bills),
BRBPR (Purchased Bills)
Audit of Foreign Bills (under For search: FBI
collection, under LC, discounted)
Search result printing: FBP
For specific bill: FBM
Audit of outstanding Foreign Bills Report FBBR
Audit of Inward and Outward For Inward Remittance: IRM
Remittances (Other than Import
For Outward Remittance: ORM
and Export Transactions)
Tracking of Packing Credit Account wise Packing Credit: ACLI
granted and tracking of order in
Running Packing Credit: RPCTM
case of Running Packing Credit
4. Audit of Office Account Transactions through CBS
Office accounts are opened for the purpose of parking entries till the time the
final effect is not determined. However, at various occasions it has been
observed that the entries remain in the said parking accounts for a long
period. Moreover, in case of weak monitoring of the said accounts, the Office
Accounts are susceptible to fraud and misappropriation.
666
Appendices
There are various types of office accounts.
1. Based on Functionality
a. Pointing Type / Self Reconciling Accounts
b. Non Pointing Type Accounts
2. Based on Type of Entry
a. Sundry Accounts, Suspense Accounts
b. EOD/BOD Check Accounts
c. Inter branch Account
d. Mirror Accounts
e. Pool Accounts
Following are few audit actionables for auditor carrying out audit of Office
Account Transactions.
Events Audit actionable Suggested system
support
Cash Payment from Authorization of Finacle:
Office Accounts Transaction as per
ACLI For
Delegated Authority
Transaction
FTI For Search
BaNCS:
BGL -> Enquire ->
Transaction
TOD through Office Through ineligible credit Finacle:
Accounts originating from a office
ACLI For
account, customer can
Transaction in
be accommodated.
Office Account
It also circumvent the
BaNCS:
number of TODs granted
to Customer. BGL -> Enquire ->
Transaction
Moreover, interest will
not be applied in the said
case.
667
Guidance Note on Audit of Banks (Revised 2019)
Events Audit actionable Suggested system
support
Parking of Cash Difference in Finacle:
Difference in Office Reconciliation, Cash
ACLI For
Accounts, Clearing / Shortage debited to
Transaction in
Remittance Office Account and not
Office Account
differences through reversed.
Office Accounts IOT For inquiry
Review ledger account in
on outstanding
detailed.
transaction
MSGOIRP For
Printing of
outstanding office
account transaction
report
BaNCS:
BGL -> Enquire ->
Transaction
"Outstanding BGL
Transaction"
Report
Rotation of entries in To prevent entry being Finacle:
Office Accounts reported as long
ACLI For
outstanding entry, a new
Transaction in
transaction with debit
Office Account
and credit leg in the
same account is posted. BaNCS:
Thus, the system
BGL -> Enquire ->
considers the new
Transaction
transaction date for
reporting as outstanding
entries.
Review transactions with
same Debit and Credit
amount through Ledger
Scrutiny.
668
Appendices
Events Audit actionable Suggested system
support
Correctness in If the transactions have Finacle:
mapping of reversal not been reversed
ACLI For
transaction to against the related
Reversal
originating originating entries the
Transaction in
transaction report generated by CBS
Office Account
will show incorrect
outstanding items. BaNCS:
BGL -> Enquire ->
Transaction
Value Dated (Back Transaction credited in Finacle:
Dated) Transactions the Advance type
ACLI For
accounts, Operative
Transaction in
accounts with a value
Office Account
date (Back date) wherein
the clear funds were not FTI For Value
available in the office Dated Transaction
accounts.
BaNCS:
Review the transactions
BGL -> Enquire ->
from Revenue Leakage
Transaction
perspective.
Round Tripping Rotation of entry from Finacle:
office account to
ACLI For
operative account(s)
Transaction in
without any justification /
Office Account
source document.
BaNCS:
Review the transactions
from the perspective of BGL -> Enquire ->
inflating credit turnover of Transaction
account.
Advance paid for Entries for payment of Finacle:
Fixed Assets not advance against
ACLI For
capitalized procurement of Fixed
Transaction in
Assets not reversed.
Office Account
IOT For inquiry
669
Guidance Note on Audit of Banks (Revised 2019)
Events Audit actionable Suggested system
support
on outstanding
transaction
MSGOIRP For
Printing of
outstanding office
account transaction
report
BaNCS:
BGL -> Enquire ->
Transaction
"Outstanding BGL
Transaction"
Report
Income realized not Loan Installment Finacle:
credited to Revenue received from Customer,
ACLI For
Account not adjusted.
Transaction in
Processing Fees Office Account
received, not credited to
IOT For inquiry
Income Account
on outstanding
Charges collected, not transaction
credit to Income Account
MSGOIRP For
Printing of
outstanding office
account transaction
report
BaNCS:
BGL -> Enquire ->
Transaction
"Outstanding BGL
Transaction"
Report
670
Appendices
5. Manual updation in CBS and its verification aspects
Under any CBS the transactions are processed as per predefined process.
Majority of the processes in CBS are automated and based on masters. A
manual intervention in automated process leads to error in transaction
processing.
Following are few manual changes / modification in system which affects the
transaction processing. The auditor must review the manual updation in
CBS.
Manual Entry Probable impact
Advances
Interest Rate change Revenue Leakage, Excess collection
of Interest
Change in EMI Revenue Leakage, NPA
Identification
Processing of transactions against Recovery of amount from customer
uncleared outward clearing effect in case of cheque return
Backdated Renewal Date updation NPA Identification
(Updating Date of Renewal on
running date with past date)
Change in Limit From Non Fund NPA Identification
Base to Fund Base
Account & Customer Master
Tax exemption updation Non compliance with TDS provisions
Dormant to Active Susceptible to fraud
Interest Table Code as "0" Revenue Leakage
Interest Collection Flag "N" Revenue Leakage
Reclassification of Agriculture Sectorial Classification
Advance as per revised RBI
norms dt. April 23, 2015
Foreign Exchange Transactions
Erroneous Foreign Exchange Revenue Leakage, Accommodation to
Rate customer
671
Guidance Note on Audit of Banks (Revised 2019)
Manual Entry Probable impact
Full BOE received flag marked as Reporting to RBI under BEF Return
"Y" wherein BOE for entire
transaction is not received
FIRC Issuance (without updating Duplicate issuance of FIRC without
flag printed "Y") "Duplicate FIRC" inscription.
Merchant Trade Transaction Reporting to RBI
(Manual mapping)
Transaction Processing & Housekeeping
Changes / Modification in Auto Revenue Leakage
Calculated charge amount at the
time of posting of transaction
Ineligible Credits to NRE and Non compliance of FEMA Guidelines
FCRA Accounts
ATM Replenishment entries Susceptible to Fraud
Payment for FD Closure proceeds Non compliance with Income Tax
in Cash through Office Accounts Guidelines
in excess of Rs. 20,000
Revalidation of Old DDs Susceptible to Fraud
Value Dating (Credit Transactions Revenue Leakage
in CC / OD Account with Value
Date without Value Dating at
Debit Leg)
Debit to Income Account (though Revenue Leakage
Transaction Maintenance Menu)
Manual Credit to Income Account Revenue Leakage (Computation of
(though Transaction Maintenance Income credited to be verified)
Menu)
RTGS / NEFT in cash through Non compliance with AML guidelines
office accounts > 49,999
Delay in posting of clearing Accommodation to customer
cheque return
Manual Transfer of Security Susceptible to Fraud (Avoid reporting
Stationery from Inventory location of missing inventory)
to External Location
672
Appendices
6. Generation & verification of specific reports based on various criteria:
CBS allows generation of various reports through Frontend as well as
through Backend. Few important reports for review by auditors are as
follows.
(a) Exception Report
Reports for the month end and two days prior and after month end
should be verified. Exceptions of following natures should be closely
verified.
(i) Balance exceeded Account Limit
(ii) Manual debits to Income Account
(iii) Value Dated Transactions
(iv) Manual entry for SI Failure cases
(v) Instrument passed against Clearing
(vi) Backdated entries (normally restricted)
(b) Irregularity Report
Reports for the month end and two days prior and after month end
should be verified. Report contains details of Accounts where Balance in
Accounts are greater than the Limits Sanctioned. Check whether the
same is due to,
(i) Application of Interest
(ii) Granting of Intra Day TOD
(iii) Passing of Instruments against Clearing Effects
(c) Accounts where Interest Code is `0'
Interest will not be charged from Accounts where Interest Code is
selected as `0'. Hence, a detailed checking is required. Possible reasons
can be if it is a NPA account or an account with a moratorium.
(d) Interest Collection Flag as "No"
If Interest Collection Flag is selected as "No", Software will not consider
the account for calculation and entry for Debit Interest.
(e) Debit Interest SI Failed Report
Failure of Standing Instruction for Debit Interest should be closely
verified. If the SI is failed the Account will not be debited for Interest. SI
Failure can be for any reason like
673
Guidance Note on Audit of Banks (Revised 2019)
(i) Non availability of Balance in Account (In case of TOD in Operative
Account)
(ii) Non availability of Limit in Account
(iii) Technical Snag in execution
Whether Branch has manually passed the entry for all such cases should
be verified.
(f) Loan Installment SI Failed Report
Same as above
(g) Report containing all Advance Accounts with Limits
Generally, CBS Softwares generate a Report wherein details of all
Advance Accounts are listed. Excel can be used to verify cases of DP >
SL, Margin Requirement, etc.
(h) TOD Report
Documents and sanction orders should be verified for all the cases of
Manually granted TODs. In Finacle the report can be generated through
Menu Code "TODRP".
(i) Account Turnover Report
To review the quantum of transactions in the borrower accounts turnover
reports should be used. In Finacle, inquiry for Account Turnover can be
carried out through "ACTI, CUTI" Menu codes and report can be generated
through "ATOR" Menu.
(j) Loan Inquiry
In Finacle, criterion based search for Loan Accounts is available through
Menu option "LAGI". The said menu can be used to verify,
New sanction, Accounts closed
Loans under various schemes
Loans based on Account Classifications
Accounts search based on Limit (Credit & Stock Audit)
(k) Loan Overdue Inquiry
In Finacle, criterion based search for Overdue & Overflow Loan Accounts is
available through Menu option "LAOPI". In case of BaNCS the said details
are available through offline daily report. The said menu can be used to
verify,
674
Appendices
Principle & Interest Overdue & Overflow
Overdue in "%" as well as Overdue in "No. of Days"
(l) Financial Transaction Inquiry
In Finacle, report based on different criteria for financial transactions can be
generated through Menu Option "FTR". The said menu can be used to
verify,
Loan disbursement in Cash (SubGL code & Tran Type)
Value Dated Transactions verification (Only value dated flag)
Transactions in Loan / OD-CC Accounts (SubGL, Tran Type, Part Tran
Type)
Credits to NRE Accounts in a period (SubGL, Part Tran Type)
Credits to FCRA Accounts in a period (SubGL, Part Tran Type)
Cash Deposit Transactions above Rs. 50,000 to verify compliance with
Income Tax Guidelines on PAN (Tran Type, Tran Sub Type)
Cash Transactions above Rs. 10 Lacs to verify compliance with AML
Guidelines (Tran Type)
Debits to ESCROW Accounts to verify compliance with ESCROW
Agreement (SubGL, Part Tran Type)
7. Guide on Audit Activity through CBS for LFAR and Tax Audit
Requirements
Following are few checkpoints for auditors for reporting under Long Form
Audit Report alongwith suggested system support.
Audit Activity / Auditors' Primary Suggested System Support
Process / Audit Checks
Area
Cash Physical verification Finacle:
of Cash Balance "ACLI" - Account Ledger
Cash Balance as on Inquiry (Vault A/c and Teller
the date of Audit Accounts)
Period BaNCS:
Cash Balances -> Reports -> Cash Related
reported in Friday -> View Cash Summary
Statement (Click on Fetch)
675
Guidance Note on Audit of Banks (Revised 2019)
Audit Activity / Auditors' Primary Suggested System Support
Process / Audit Checks
Area
-> Branch Reports -> Cash
Officer's Jotting Book
Report
-> Reports -> Printing
Reports -> Cashier / Teller
Cash Report
Balances with Balance as on Date Finacle:
RBI / SBI / Transactions in "ACLI" - Account Ledger
Other Banks Mirror Accounts Inquiry
Reconciliation BaNCS:
Statement -> Branch Accounting
(Generally outside of (BGL) -> Enquire ->
CBS) Transaction
Advances Sanction Limit / Finacle:
Drawing Power "ACLHM" Account Limit
setup History Maintenance
"ACM / ACI" Account
Master (Go to Limit details)
"LTL" Limit Tree Lookup
(Tree view of all Limits)
BaNCS:
DL/TL Accounts & Services
-> Enquiries -> Account
Deposit / CC / OD Accounts
& Services -> Enquiries ->
Deposit / CC / OD Account
Advances Account & Customer Finacle:
Master parameters "ACLHM" Account Limit
setup viz. History Maintenance for DP
Interest & SL Account Specific
Parameters "ACM / ACI" Account
(Regular & Master
Penal Interest)
"CUMM / CUMI "
676
Appendices
Audit Activity / Auditors' Primary Suggested System Support
Process / Audit Checks
Area
Repayment Customer Master
Instructions BaNCS:
Standing DL/TL Accounts & Services
Instructions (SI) -> Enquiries -> Account
Parameters Deposit / CC / OD Accounts
& Services -> Enquiries ->
Deposit / CC / OD Account
(Short & Long Inquiry options
are available under both
menu.)
Advances Transactions in Finacle:
Borrower's Account "ACLI" - Account Ledger
Inquiry
BaNCS:
Deposit / CC / OD Accounts
& Services -> Enquiries ->
Transaction
DL/TL Accounts & Services
-> Enquiries -> Transaction
Advances Interest Rate History Finacle:
"INTTM" Interest Table
Master Maintenance (Under
Inquire Mode Account
Specific)
BaNCS:
Deposit / CC / OD Accounts
& Services -> Interest Rate
History
DL/TL Accounts & Services
-> Interest Rate History
Advances Conduct of Account Finacle:
and Credit Turnover "ATOR" Account
Turnover of CC Turnover Report
677
Guidance Note on Audit of Banks (Revised 2019)
Audit Activity / Auditors' Primary Suggested System Support
Process / Audit Checks
Area
Account based on "ACTI" Account Turnover
Borrower's Business Inquiry
profile "CUTI" Customer Level
In case of Loan Turnover Inquiry
accounts ACTUAL BaNCS:
recovery of
DL / TL Accounts &
Installments and
Services ->Enquiries -
Interest
>Long
Deposit/CC/OD Accounts &
Services ->Enquiries -
>Long
Advances Non Performing Finacle:
Asset "ACS" Account Selection
Search an (2nd Screen IRAC Code
Account based Main Asset Classification)
on Criteria BaNCS:
DL / TL Accounts &
Services ->Enquiries -
>Short -> Select Option "1"
TL / DL [Long Inquiry
for NPA Date]
Deposit/CC/OD Accounts &
Services ->Enquiries -
>Short -> Select Option "2"
CC / OD [Long Inquiry
for NPA Date]
Common Processing -
>Overdue / NPA ->NPA
Enquiry (Risk Grade Inquiry
/ NPA Status Inquiry)
Advances Interest Report Finacle:
"AINTRPT" Interest
Report for Account
BaNCS:
678
Appendices
Audit Activity / Auditors' Primary Suggested System Support
Process / Audit Checks
Area
Product Sheets To be
requested from Data Center
(if not available through
user login)
Advances Primary & Collateral Finacle:
Security "SRM" Security Register
Maintenance Maintenance
BaNCS:
DL/ TL Accounts &
Services -> Security
(Primary/ Collateral) -
>Customer -> Amend /
Enquiry ->Amend / Enquire
Security
Advances Lien Marking Finacle:
"ALM" Account Lien
Maintenance
BaNCS:
DL/ TL Accounts &
Services -> Security
(Primary/ Collateral) -
>Customer -> Amend /
Enquiry ->Amend / Enquire
Security
(Under BaNCS
Collateral ID is required to
be created before setting
up limits)
Advances Account Ledger Finacle:
Printing "PSP" Pass Sheet Print
"ACLPCA" Customer
Ledger Account Print
BaNCS:
679
Guidance Note on Audit of Banks (Revised 2019)
Audit Activity / Auditors' Primary Suggested System Support
Process / Audit Checks
Area
Print Menu available under
DL / TL Accounts &
Services and Deposit / CC
/ OD Accounts & Services
Advances Non Fund based Finacle:
Facility (LC, BG) "GI" Guarantee Inquiry
"DCQRY" Documentary
Credit Query
BaNCS:
Report generated from
Trade module
Stationery Physical Verification Finacle:
of Stationery and "ISRA" Inventory Status
confirmation of Report (Locationwise viz.,
Balance as per CBS Dual Lock, Individual,
Cancelled etc.)
BaNCS:
Through Valuable Paper
Inventory System [VPIS]
module
Office Accounts Outstanding entries Finacle:
(Suspense, for reporting "IOT" Inquire on
Sundry etc.) Entries outstanding Transaction (As on date
Whether any Inquiry)
provisioning is "MSGOIRP" Outstanding
required? Items Report
BaNCS:
Through offline reports viz.
"Audit BGL accounts age
wise break up" and "GL-
Outstanding-Accnts" report.
Office Accounts Printing of Office Finacle:
(Suspense, Accounts "ACLPOA" Account
680
Appendices
Audit Activity / Auditors' Primary Suggested System Support
Process / Audit Checks
Area
Sundry etc.) Ledger printing Office
Account
BaNCS:
BGL Accounting Menu
Inter Branch Un-reconciled Finacle:
Account transactions Through Outstanding IBR
Report.
BaNCS:
Through offline
"Outstanding IBR Report"/
"IBR Summary report"
TDS Related TDS Information and Finacle:
Reports "TDSIP" TDS Inquiry &
Reports
Month-end report on
accountwise /
transactionwise Tax
deduction.
Bank specific customized
Menu / report
BaNCS:
Through offline monthly
report on accountwise /
transactionwise Tax
deduction.
681
APPENDIX XI
Features of the Gold Monetization Scheme
The Broad features of the Gold Monetization Scheme are summarised below:
Acceptance of 1. Deposits under the scheme are to be made at
Deposits and the
Interest
a. Collection and Purity Testing Centre (CPTC) -the
accretion
collection and assaying centres certified by the
Bureau of Indian Standards (BIS) and notified by the
Central Government for the purpose of handling gold
deposited and redeemed under the Scheme, or
b. designated bank branches, where, at their discretion,
banks may accept the deposit of gold.
2. Minimum Deposits -With no maximum limit for deposit,
the minimum deposit at any one time shall be raw gold
(bars, coins, jewellery, excluding stones and other metals)
equivalent to 30 grams of gold (of 995 fineness only).
3. Assaying of Gold - All gold deposited under the
scheme, whether tendered at the CPTC or designated
bank branches, shall, (except standard good delivery gold
accepted at the designated branches), be assayed at
CPTC for fire assaying.
4. Interest on such deposits accrues from the date of
conversion of gold deposited into tradable gold bars after
refinement or 30 days after the receipt of gold at the
CPTC or the bank's designated branch, as the case may
be, whichever is earlier.
5. Gold deposited to be treated as an item in safe custody
- Between the date of acceptance of the gold and till
commencement of the date of accretion of interest, the
gold deposited shall be treated as an item in safe custody
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Appendices
held by the designated bank.
Valuation On the day the gold deposited starts accruing interest, the
designated banks shall translate the gold liabilities and
assets in Indian Rupees*. The prevalent custom duty for
import of gold will be added to the above value to arrive at
the final value of gold. This methodology will also be
followed for valuation of gold at any subsequent valuation
date(s) and for the conversion of gold into Indian Rupees
under the Scheme.
(*by crossing the London AM fixing for Gold / USD rate
with the Rupee-US Dollar reference rate announced by
RBI on that day)
Reporting to RBI The designated banks will be required to submit a
monthly report on GMS to the RBI in the prescribed
format.
However, as per RBI Circular No. DGBA GAD No
2294/15.04.001/2016-17 dated March 6, 2017, in order to
have uniformity in reporting, reconciliation and
accounting, agency banks may report the Gold
Monetisation Scheme transactions i.e., receipt, payment,
penalty, interest, commission for mobilisation, handing
charges, etc., directly through the government account
maintained for the purpose at Central Accounts Section,
Reserve Bank of India, Nagpur, on a daily basis.
Opening of Gold Customer identification criteria as applicable to any other
Deposit Account deposit accounts (KYC norms),shall apply and non-
customers can open a gold deposit account with zero
(opened with a
balance at any time prior to tendering gold at the CPTC.
designated bank
under the Scheme The designated banks will credit/record the STBD or
and denominated MLTGD, as the case may be (with the amount of 995
in grams of gold) fineness gold as indicated in the advice received from
CPTC), after 30 days of receipt of gold at the CPTC,
regardless of whether the depositor submits the receipt
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Guidance Note on Audit of Banks (Revised 2019)
for issuance of the deposit certificate or not.
Tendering of gold to CPTC
Before tendering the raw gold to a CPTC, the depositor
shall indicate the name of the designated bank with whom
he would like to place the deposit.
After assaying the gold, the CPTC will issue a receipt
signed by authorised signatories of the centre showing
the standard gold of 995 fineness on behalf of the
designated bank indicated by the depositor.
Simultaneously, the CPTC will also send an advice to the
designated bank regarding the acceptance of deposit.
Fee to CPTC
If in agreement with result of the fire assay test, the
customer will exercise his option to deposit the gold with
the bank and the fee charged by the CPTC will be borne
by the bank. In case of any disagreement with the fire
assay result, the customer will have the option to take
back the melted gold after paying a nominal fee to the
centre.
Documentation
Standard documentation (designed by IBA including
application form for tendering raw gold to the assaying
centers, the description of the physical appearance/
characteristics of gold, recording of the results of XRF by
the assaying centre, customer's consent for melting the
gold for fire-assaying and for making the final deposit, the
final receipt to be issued to the depositor ), are to be
made known and available to the CPTCs and to the
depositor upfront and should include all the terms and
conditions of the Scheme including the schedule of
charges.
-----------------------------------------------------------------------------
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Appendices
(The 995 fineness equivalent amount of gold as
determined by the CPTC will be final and any difference
in quantity or quality found after issuance of the receipt by
the CPTC including at the level of the refinery due to
refinement or any other reason shall be settled among the
three parties viz., the CPTC, the refiner and the
designated bank in accordance with the terms of the
tripartite agreement to be entered into.)
Types of 1.Short Term Bank Deposit. (STBD)
deposits
2.Medium and Long Term Government Deposit. (MLTGD)
Short Term Bank Duration - for a short term period of 1-3 years (with a roll
Deposit (STBD) over in multiples of one year), to be treated by banks as
their on-balance sheet liability; the duration being subject
to such minimum lock-in period and penalties, if any, as
may be determined by the banks as per their laid down
policy.
Interest-banks are free to fix the interest rates; and the
interest shall be credited in the deposit accounts on the
respective due dates and will be withdrawable periodically
or at maturity as per the terms of the deposit.
Redemption of principal and interest at maturity will, at the
option of the depositor be either in Indian Rupee
equivalent of the deposited gold and accrued interest
based on the price of gold prevailing at the time of
redemption, or in gold. The option in this regard shall be
made in writing by the depositor at the time of making the
deposit and shall be irrevocable:
Premature redemption, if any, shall be in Indian Rupee
equivalent or gold at the discretion of the designated
bank.
Imports permitted by designated banks for
redemption
The designated banks other than the nominated banks
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Guidance Note on Audit of Banks (Revised 2019)
shall be eligible to import gold only for redemption of the
gold deposits mobilised under the STBD.
(Nominated bank A Scheduled Commercial Bank
authorized by RBI to import gold in terms of RBI circular
A.P.(DIR Series) Circular No.79 dated February 18, 2015)
CRR and SLR
CRR and SLR requirements apply (as per instructions of
RBI ) from the date of credit of the amount to the deposit
account. However, the stock of gold held by banks in their
books will be an eligible asset for meeting the SLR
requirement in terms of RBI Master Circular - Cash
Reserve Ratio (CRR) and Statutory Liquidity Ratio (SLR)
dated 1 July 2015.
End use
In respect of gold mobilised under the STBD, the
designated banks may:
o sell the gold to MMTC for minting India Gold Coins
(IGC), to jewellers and to other designated banks
participating in GMS; or
o lend the gold under the GML scheme to MMTC for
minting India Gold Coins (IGC) and to jewellers.
Medium and Deposits shall be accepted by the designated banks on
Long Term behalf of the Central Government and shall constitute the
Government liability of Central Government; and the receipts issued by
Deposit (MLTGD) the Collection and Purity Testing Centre (CPTC) -the
collection and assaying centres certified by the Bureau of
Indian Standards (BIS) and notified by the Central
Government for the purpose of handling gold deposited
and redeemed under the Scheme, and the deposit
certificate issued by the designated banks shall clearly
state this.
Accordingly, such deposits shall not be reflected in the
balance sheet of the designated banks. Reserve Bank of
686
Appendices
India will maintain the Gold Deposit Accounts
denominated in gold in the name of the designated banks
that will in turn hold sub-accounts of individual depositors.
Control over the gold deposited - The designated banks
will hold the gold deposited on behalf of Central
Government until it is transferred to such person as may
be determined by the Central Government.
The gold received under MLTGD will be auctioned by the
agencies notified by Government and the sale proceeds
will be credited to Government's account held with RBI.
The details of auctioning and the accounting procedure
will be notified by Government of India.
Duration - the deposit can be made for a medium term
period of 5-7 years or a long term period of 12-15 years or
for such period as may be decided from time to time by
the Central Government. (The designated banks may
allow whole or part premature withdrawal of the deposit
subject to such minimum lock-in period and penalties, if
any, as determined by the Central Government.)
Redemption of the deposit including interest accrued -
Redemption will be only in Indian Rupee equivalent of the
value of the gold and accumulated interest as per the
price of gold prevailing at the time of redemption.
However, as per RBI Circular No.
DGBA.GBD.No.1007/15.04.001/2017-18 dated October
17, 2017.
- Reimbursement of payments made by banks, relating
to Medium and Long Term Government Deposit
(MLTGD), will be made by Central Account Section
(CAS), Nagpur, RBI.
- Accordingly, banks are advised to pay immediately
the interest amount already due to the depositors and
to take note that, in future, payment of interest to the
depositors is to be made on the due dates. After
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Guidance Note on Audit of Banks (Revised 2019)
making payments, the banks may raise claim to
Government through RBI (CAS, Nagpur).
End Use:
Gold accepted under MLTGD will be auctioned by MMTC
or any other agency authorized by the Central
Government and the sale proceeds credited to the
Central Government's account with RBI.
The entities participating in the auction may include RBI,
MMTC, banks and any other entities notified by the
Central Government in this regard.
Gold purchased by designated bank under the auction
may be utilized by them and they may :
o sell the gold to MMTC for minting India Gold Coins
(IGC), to jewellers and to other designated banks
participating in GMS; or
o lend the gold under the Gold Metal Loan (GML)
Scheme to MMTC for minting India Gold Coins (IGC)
and to jewellers.
Tripartite The designated bank shall enter into a legally binding
agreement tripartite agreement with the refiners and CPTCs with
between the whom they tie up under the Scheme; the refiners being
designated refineries accredited by the National Accreditation Board
banks, refiners for Testing and Calibration Laboratories(NABL) and
and CPTCs notified by the Central Government for the purpose of
handling gold deposited and redeemed under GMS.
The agreement shall cover nature of services to be
provided, standards of service, arrangements regarding
movement of gold, payment of fees and rights and
obligations of the parties.
Transfer of gold The CPTCs will transfer the gold to the refiners as per the
to the Refiners terms and conditions set out in the tripartite agreement.
The refined gold may, at the option of the designated
bank, be kept in the vaults maintained by the refiners or at
the branch itself.
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Appendices
For the services provided by the refiners, the designated
banks will pay a fee as decided mutually.
The refiners shall not collect any charge from the
depositor.
Oversight over 1. The Central Government:
the CPTCs and in consultation with BIS, NABL, RBI and IBA, may put
Refineries in place appropriate supervisory mechanism over the
CPTCs and the refiners so as to ensure observance
of the standards set out for these centres by
Government (BIS and NABL).
may take appropriate action including levy of penalties
against the non-compliant CPTCs and refiners.
may put in place appropriate grievance redress
mechanism regarding any depositor's complaints
against the CPTCs.
2. Complaints against the designated banks regarding
any discrepancy in issuance of receipts and deposit
certificates, redemption of deposits, payment of
interest will be handled first by the bank's grievance
redress process and then by the Banking
Ombudsman of RBI.
Risk The designated banks should put in place suitable risk
management management mechanisms including appropriate limits to
manage the risk arising from gold price movements in
respect of their net exposure to gold.
The designated banks are allowed to access the
International Exchanges, London Bullion Market
Association or make use of Over-the-counter contracts to
hedge exposures to bullion prices subject to the
guidelines issued by RBI.
689
APPENDIX XII
Illustrative Audit Checklist for Capital Adequacy
The checklist is only illustrative in nature. Members are expected to exercise their
professional judgment while using the checklist depending upon facts and
circumstances of each case.
Audit Procedures
CET 1, AT 1 and Tier II
1. Tally the balances in the various elements of
Capital from the trial balance/ groupings/ draft
financial statements.
2. Check whether various instruments comply
with the guidelines as laid down in the Master
Circular by referring to the Terms of Offer and
whether the same are approved by the Board
or other appropriate committee.
3. Check whether appropriate discounting has
been applied in the case of instruments
issued.
4. In case of foreign banks, examine whether
the undertaking has been obtained that the
bank would not remit abroad the funds
received and shown as Capital Reserve or
Remittable Surplus.
5. Examine whether various limits upto which
individual elements are to be included in
CET1, AT1 and Tier II capital as laid down in
the Master Circular are adhered to.
6. Verify various deductions with the balances in
the audited accounts and check the same for
limits and eligibility (e.g. securitisation
exposure) as laid down in the Master Circular.
690
Appendices
7. Verify the correctness of progressive discount
based on the remaining maturity of
instruments eligible for AT1 and Tier II.
Capital Charge on Credit Risk
The capital charge for credit risk is the sum total of
the capital charge to be maintained in respect of
the following:
On balance sheet items.
Off balance sheet items.
Failed transactions.
NPAs.
Securitisation transactions.
duly adjusted for haircuts based on the nature of
the collateral.
Risk Weights On Balance Sheet Items
The risk weights for all on balance sheet items
need to be determined based on the credit ratings
assigned by the rating agencies chosen by the
RBI.
1. Reconcile the balances of various advances
and other operating receivables where there is
a credit risk and which are considered for
calculation with the following schedules in the
financial statements to ensure completeness:
Schedule 6 Cash and balances with
Reserve Bank of India.
Schedule 7- Balances with Banks and
Money at Call and Short Notice.
Schedule 9- Advances.
Schedule 11(vi) Other Assets Others.
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Guidance Note on Audit of Banks (Revised 2019)
2. Review and document the process of
compilation and mapping of the various items
on balance sheet based on the categories and
their risk weights together with the appropriate
ratings and / or other conditions, as applicable.
3. For a sample of transactions verify the ratings
with the letters issued by the rating agencies
and accordingly check the correctness of the
risk weights assigned.
4. In cases where the risk weights are dependent
on the fulfilment of certain conditions (other
than ratings) verify the compliance therewith
based on the appropriate documentary
evidence. (e.g. claims on banks, regulatory
retail portfolio, claims against residential
property etc.)
5. Verify the validity of guarantees issued by
Central or State Government. Verify whether
the bank has properly classified claims on
State Government and claims guaranteed by
State Government due to difference risk
weight.
6. Verify the correctness of claims on CGTSI
and ECGC.
7. Verify the classification of loans restructured
loans/ NPAs/ NBFC/ CRE/ CRE-RH etc.
8. Verify LTV ratio on a test check basis in
respect of housing loans.
Risk Weights Off Balance Sheet Items
The risk weight for all off balance sheet credit
exposures is generally calculated as a two step
process as under, separately for market and non-
market related exposures:
The notional amount is converted into a credit
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Appendices
equivalent amount by multiplying the amount
by the specified credit conversion factor (for
non market transactions) or by applying the
current exposure method (for market related
transactions).
The resulting credit equivalent amount is
multiplied by the risk weight applicable to the
counterparty or the purpose for which finance
is extended or the type of asset, whichever is
higher.
Where the exposure is secured by eligible
collateral or guarantee, the credit risk mitigation
guidelines may be applied.
1. Reconcile the balances of the various off
balance sheet exposures which are considered
for calculation with the financial statements,
especially the schedule of contingent liabilities.
2. Review and document the process of
compilation and mapping of the various off
balance sheet item based on the nature of
the instruments.
3. For a sample of non-market transactions,
check the calculations of the credit equivalent
amount with specified credit conversion factor
based on the nature of the instrument. Check
the necessary documentation to confirm the
nature of the instrument.
4. For a sample of market related transactions,
check the necessary documentation to confirm
the nature of the contract and accordingly
check the calculations for the current credit
exposure and the potential future exposure.
5. Verify the classification of Financial and
Performance Guarantee by perusing the
sample guarantee issued by the branches.
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Guidance Note on Audit of Banks (Revised 2019)
6. Verify whether bills accepted under Letter of
Credit is assigned 100% risk weight as CCF.
7. Verify whether the bank has proper control for
accounting Buyer's credit/ Letter of Comfort.
8. Verify the correctness of undrawn exposures.
Capital Charge Failed Transactions
1. Review and document the procedures for
tracking and monitoring the credit risk
exposure arising from unsettled transactions,
both on Delivery Versus Payment (DVP) and
non DVP basis.
2. For a sample of DVP transactions, examine
whether the settlement has taken place on a
timely basis. In case of delays, check the
calculation of the capital charge by multiplying
the positive current exposure by the
prescribed factor depending upon the number
of days delayed.
3. For a sample of non-DVP transactions,
examine whether the settlement has taken
place as per the contracted maturity. In case
of delays, ascertain whether any payment
made is considered as a loan and the
appropriate risk weight is considered. In case
of settlement beyond five days ascertain
whether the full amount is deducted from the
capital.
Risk weights NPAs
1. Review and document the procedures for
identifying the unsecured portion of NPAs
separately for qualifying residential
mortgages and others.
2. For a sample of residential mortgages which
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Appendices
are NPAs, examine whether they meet with
the qualifying criteria with regard to the LTV
ratio and other factors and accordingly check
the assignment of the risk weight for the
unsecured portion depending upon the level
of provisioning.
3. For a sample of NPAs other than residential
mortgages check the assignment of the risk
weight based on the level of provisioning.
4. In respect of 3 above for identifying the
secured portion examine whether only eligible
collateral are considered and the same are
properly documented and the bank has a
clear and marketable title to realise the same.
5. Verify whether bucketing in difference risk
weight in respect of NPAs based on NPA
provision is carried out by the system and
verify the correctness of classification on a
test check basis
Capital Charge Securitisation transactions
Banks are required to hold regulatory capital after
adjusting the prescribed deductions eligible
against all securitisation exposures including
those arising from provision of credit mitigants,
investment in asset backed securities, retention
of subordinated tranche and extension of liquidity
facility or credit enhancement.
Examine whether the securitisation transactions
fulfil the requirements as prescribed in Master
Circular on "Prudential Guidelines on Capital
Adequacy and Market Discipline - New Capital
Adequacy Framework" (extract of the `Revision to
the Guidelines on Securitisation Transactions',
issued vide circular DBOD.No.BP.BC.103/
21.04.177/ 2011-12 dated May 07, 2012on
'Revision to the Guidelines on Securitisation
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Guidance Note on Audit of Banks (Revised 2019)
Transactions') to be eligible for deduction from
capital.
1. Based on the above, for a sample of
transactions / deals examine whether the
prescribed deduction from both CET 1, AT I
and Tier II capital has been correctly done
based on the rating and the level of
provisions. Review the necessary
documentation in support of the same.
2. Based on the above ascertain whether the
appropriate risk weights have been assigned.
Collateral Risk Management and Credit Risk
Mitigation
The objective of collateral risk management is to
ensure that only the eligible collateral are
considered for netting off which are adjusted for
volatility depending upon the nature of the capital
and further subjected to various types of haircuts
for different categories of mismatches like
currency and tenor mismatches.
1. Review and document the process for
collateral risk management as appropriate
and relevant including but not limited to:
Ageing reports.
Confirmation procedures.
Control of documents.
Compliance with covenants.
Audit of collateral by independent
agencies.
2. Examine whether the bank has complete
legal rights to enforce the security including
specific lien and is subject to haircuts for
residual tenor mismatch and currency
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Appendices
mismatch. Check the necessary
documentation in respect thereof.
Capital Charge for Market Risk
Capital charge for market risk involves
computation of the capital charge on interest rate
related instruments and equities in the trading
book and foreign exchange risk, including gold
and other precious metals. Accordingly, the
following would be covered:
Securities under the HFT and AFS category.
Open gold and FX position limits.
Trading position in derivatives.
Derivatives entered into for hedging trading
book exposures.
Interest Rate General Market Risk
The capital requirement for general market risk is
the sum of the following four components:
(i) Net short (only derivatives) or long position in
the trading book.
(ii) Small proportion of matched position for each
time band. (vertical disallowance)
(iii) A larger proportion of the matched positions
across different time bands. (horizontal
disallowance)
(iv) Net change for positions in options where
applicable.
1. Reconcile the balances considered for
calculation of the general interest rate risks
trading book positions with the figures reported
in the financial statements.
2. Review and document the process for
computation of the price sensitivity (modified
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Guidance Note on Audit of Banks (Revised 2019)
duration) for each instrument and test check
the calculations for a sample of instruments.
3. Review the process of capturing the above
data into different time bands based on the
maturity and accordingly apply the prescribed
change in yield and check the calculations for
the resulting capital charge and the
consequential vertical and horizontal
disallowances.
Interest Rate Specific Risk
The specific interest rate capital charge for
different types of debt securities / issuers is
prescribed separately for the following
categories:
Central, State and Foreign government bonds
under HFT and AFS category.
Banks bonds under HFT and AFS category.
Corporate bonds and securitised debt under
HFT and AFS category.
1. Reconcile the balances of government
securities under AFS and HFT considered for
computation of specific interest rate capital
charge with the financial statements.
2. Review and document the process of
compilation of data in respect of various types
of government securities under AFS and HFT
based on the type of investment and the
residual maturity.
3. For a sample of transactions in respect of the
above, verify the allocation percentage of the
specific risk capital based on the type of
investment and residual maturity based on the
verification of the relevant documentation.
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Appendices
4. Reconcile the balances of bonds issued by
banks under AFS and HFT considered for
computation of specific interest rate capital
charge with the financial statements.
5. Review and document the process of
compilation of data in respect of various types
of bonds issued by banks held as investments
under AFS and HFT based on the following
parameters:
Level of capital adequacy.
Nature of the bank (scheduled or non-
scheduled).
Residual maturity.
6. For a sample of transactions in respect of the
above, verify the allocation percentage of the
specific risk capital based on the various
parameters based on the verification of the
relevant documentation.
7. Reconcile the balances of corporate bonds
and securitised debt under AFS and HFT
considered for computation of specific interest
rate capital charge with the financial
statements.
8. Review and document the process of
compilation of data in respect of corporate
bonds and securitised debt instruments held
as investments under AFS and HFT based on
the following parameters:
Rating assigned.
Nature of the investment.
Residual maturity.
9. For a sample of transactions in respect of the
above, verify the allocation percentage of the
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Guidance Note on Audit of Banks (Revised 2019)
specific risk capital based on the various
parameters based on the verification of the
relevant documentation.
Equity General and Specific Market Risk
A uniform percentage of 9% is currently attracted
for the gross equity position for both specific and
general risks.
Foreign Exchange and Gold
These currently attract a risk weight of 100%
which is in addition to the capital charge for credit
risk for on and off balance sheet items.
1. Check the computation of the net open
position in each currency as a summation of
the following:
Net spot position.
Net forward position.
Guarantees and similar instruments.
Net future expenses / incomes not yet
accrued but fully hedged.
2. Based on the calculations of the market risk
for each of the above check the computation
of the aggregate capital charge of market
risks.
Interest rate risk
a) General market risk
Net position
Horizontal disallowance
Vertical disallowance
b) Specific market risk
Specific and general market equity risk
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Appendices
Foreign Exchange and gold.
Capital Charge for Exposure to Entities with
Unhedged Foreign Exchange Exposures
(UFCE)25
1. Ascertain the amount of the UFCE:
UFCE may exclude items which are effective
hedge against each other viz. financial hedge
and natural hedge. (On Sample basis, the
UFCE considered by the Bank can be verified
with the certificates issued by the statutory
auditor of the borrower entities, which is
usually taken by the Bank from them on a
quarterly/ half yearly basis.)
2. Estimate the extent of likely loss.
3. Estimate the riskiness of the unhedged
position and provide appropriately:
Likely Incremental Incremental
Loss/EBID (%) Provisioning Capital
Requirement on Requirement
the total credit
exposures over
and above extant
standard asset
provisioning
Upto15 per
0 0
cent
More than 15
per cent and
20bps 0
upto 30 per
cent
More than 30
per cent and 40bps 0
upto 50 per
25RBI/2013-14/448 DBOD.No.BP.BC. 85 /21.06.200/2013-14 dated January 15, 2014.
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Guidance Note on Audit of Banks (Revised 2019)
cent
More than 50
percent and
60bps 0
upto 75 per
cent
More than 75
80 bps
per cent
Banks should calculate the incremental
provisioning and capital requirements at least on a
quarterly basis . However, during the periods of
high USD-INR volatility, the calculations may be
done on a monthly basis.
Capital Charge for Operational Risk
Currently banks are required to maintain capital
charge for operational risk at 15% of the average
gross income for the last three financial years
1. Obtain the computation of the gross total
income and verify the same from the
respective years audited financial statements.
2. Examine whether the various deductions from
the net profit are appropriately considered.
For computing the gross income for determining the capital to be held
against operational risk, there is a clarification that the same should be
considered based on the average of the last three financial years. However,
there is no clarity as to whether this includes the current financial year
though the better practice would be to consider the average of the
preceding three years.
702
3
Suggested Abbreviations
used in the Banking Industry
Abbreviations have often been found to be used by the banking industry and
in the Circulars/ guidelines/directions of the Reserve Bank of India. It is
appropriate to understand what these abbreviations are:
Abbreviation Expanded form
AACS As Applicable to Co-operative Societies
ACF Auto-Correlation Function
AD Authorised Dealer
ADB Asian Development Bank
ADR American Depository Receipt
AE Aggregate exposure
AFS Annual Financial Statement
AFS Available For Sale
AGM Annual General Meeting
AICCCA Association of Independent Consumer Credit Counseling
Agencies
AIFI All-India Financial Institution
AIRCSC All India Rural Credit Survey Committee
ALM Asset-Liability Management
AMC Asset Management Company
AML Anti-Money Laundering
AO Additive Outliers
AR Auto Regression
ARC Asset Reconstruction Company
ARCIL Asset Reconstruction Company (India) Ltd.
ARIMA Auto-Regressive Integrated Moving Average
ASSOCHAM Associated Chambers of Commerce and Industry of India
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Guidance Note on Audit of Banks (Revised 2019)
ATM Asynchronous Transfer Mode
ATM Automated Teller Machine
BCBS Basel Committee on Banking Supervision
BCP Business Continuity Planning Process
BCSBI Banking Codes and Standards Board of India
BFS Board for Financial Supervision
BG Bank Guarantees
BIFR Board for Industrial and Financial Reconstruction
BIS Bank for International Settlements
BIS Bureau of Indian Standards
B/L Bill of Lading
BoE Bill of Exchange
BoP Balance of Payments
BOS Banking Ombudsman Scheme
BOT Build-Operate-Transfer
BPLR Benchmark Prime Lending Rate
BPM5 Balance of Payments Manual, 5th edition
BPSD Balance of Payments Division, DESACS, RBI
BPSS Board for Payment and Settlement Systems
BR Act Banking Regulation Act
BSC Balanced Scorecard
BSCS Basel Committee on Banking Supervision
BSE Bombay Stock Exchange Ltd.
BSR Basic Statistical Return
CAD Capital Account Deficit
CAG Controller and Auditor General of India
CALCS Capital Adequacy, Asset Quality, Liquidity, Compliance
and System
CAMELS Capital Adequacy, Asset Quality, Management, Earnings,
Liquidity, Systems and control
CAP Corrective Action Plan
CBLO Collateralised Borrowing and Lending Obligation
704
Suggested Abbreviations used in the banking industry
CBS Core Banking Solutions
CBS Consolidated Banking Statistics
CC Cash Credit
CCCS Consumer Credit Counseling Service
CCDM Credit Counseling and Debt Management
CCIL Clearing Corporation of India Ltd.
CCP Central Counter Party
CD Ratio Credit Deposit Ratio
CD Certificate of Deposit
CDBMS Central Data-base Management System
CDBS Committee of Direction on Banking Statistics
CDF Co-operative Development Fund
CDR Corporate Debt Restructuring
CDRM Corporate Debt Restructuring Mechanism
CEO Chief Executive Officer
CF Company Finance
CFMS Centralised Funds Management System
CFRA Combined Finance and Revenue Accounts
CFS Consolidated Financial Statements
CFT Combating Financing of Terrorism
CGFT Credit Guarantee Fund Trust
CGRA Currency and Gold Revaluation Account
CGTSI Credit Guarantee Trust for Small Industries
CRGFTLIH Credit Risk Guarantee Fund Trust for Low Income
Housing
CGTMSE Credit Guarantee Fund Trust For Micro And Small
Enterprises
CIBIL Credit Information Bureau of India Limited
CII Confederation of Indian Industries
CIN Corporate Identity Number
CLCC Central Labour Co-ordination Committee
CLF Collateralised Lending Facility
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Guidance Note on Audit of Banks (Revised 2019)
CME Capital Market Exposure
CMP Conflict Management Policy
CO Capital Outlay
COBIT Control Objectives for Information and related
Technology
CP Commercial Paper
CPC Cheque Processing Centre
CPI Consumer Price Index
CPI-IW Consumer Price Index for Industrial Workers
CPOS Central Point of Supervision
CPPAPS Committee on Procedures and Performance Audit on
Public Services
CPSS Committee on Payment and Settlement System
CPTC Collection and Purity Testing Centre
CR Capital Receipts
CRAR Capital to Risk-Weighted Asset Ratio
CRCS Central Registrar of Co-operative Societies
CRE Commercial Real Estate
CRE RH Commercial Real Estate Residential Housing Sector
CRILC Central Repository of Information on Large Credits
CRR Cash Reserve Ratio
CSA Co-operative Societies Act
CSD Customer Service Department
CSGL Constituent Subsidiary General Ledger
CSIR Council of Scientific and Industrial Research
CSO Central Statistical Organisation
CTR Cash Transaction Report
CTS Cheque Truncation System
CVC Central Vigilance Commission
D&B Dun & Bradstreet Information Services India (P) Ltd.
DAPs Development Action Plans
DBOD Department of Banking Operations and Development
706
Suggested Abbreviations used in the banking industry
DBS Department of Banking Supervision
DCA Debtor creditor agreement
DCB Demand Collection and Balance
DCCB District Central Co-operative Banks
DCCO Date of Commencement of Commercial Operations
DCM Department of Currency Management, RBI
DCRR Department for Co-operative Revival and Reforms
DD Demand Draft
DDS Data Dissemination Standards
DEIO Department of External Investments and Operations
DESACS Department of Statistical Analysis & Computer Services,
RBI
DFI Development Finance Institution
DGBA Department of Government and Bank Accounts, RBI
DGCI&S Directorate General of Commercial Intelligence and
Statistics
DI Direct Investment
DICGC Deposit Insurance and Credit Guarantee Corporation of
India
DID Discharge of Internal Debt
DLIC District Level Implementation and Monitoring Committee
DMA Direct Marketing Agent
DNSS Deferred Net Settlement System
DP Drawing Power
DPN Demand Promissory Note
DPSS Department of Payment and Settlement Systems
DRI Differential Rate of Interest
DRT Debt Recovery Tribunal
DSA Direct Sales Agent
DSBB Dissemination Standards Bulletin Board
DSCR Debt Service Coverage Ratio
DTL Demand and Time Liability
707
Guidance Note on Audit of Banks (Revised 2019)
DvP Delivery versus Payment
EBR Export Bills Rediscounted
ECB External Commercial Borrowing
ECB European Central Bank
ECGC Export Credit and Guarantee Corporation
ECS Electronic Clearing Service
EDI Electronic Data Interchange
EDMU External Debt Management Unit
EEA Exchange Equalization Account
EEC European Economic Community
EEFC Exchange Earners Foreign Currency
EFR Exchange Fluctuation Reserve
EFT Electronic Funds Transfer
EME Emerging Market Economy
EMI Equated Monthly Installment
EPF Employees Provident Fund
ESOP Employee Stock Option Plans
ETF Empowered Task Force
EUR Euro
EWS Early Warning System
EXIM Bank Export Import Bank of India
FAQs Frequently Asked Questions
FBIL Financial Benchmarks India Private Limited
FCA Foreign Currency Assets
FCAC Fuller Capital Account Convertibility
FCCB Foreign Currency Convertible Bond
FC GPR Foreign Collaboration- General Permission Route
FCNR (B) Foreign Currency Non-Resident (Banks)
FCNR Foreign Currency Non-Resident
FCNRA Foreign Currency Non-resident Account
FCNRD Foreign Currency Non-Repatriable Deposit
FC TRS Foreign Currency Transfer of Shares
708
Suggested Abbreviations used in the banking industry
FDI Foreign Direct Investment
FDIC Federal Deposit Insurance Corporation
FEDAI Foreign Exchange Dealers Association of India
FEMA Foreign Exchange Management Act
FFI Foreign Financial Institution
FFMC Full Fledge Money Changer
FI Financial Institution
FICCI Federation of Indian Chambers of Commerce and
Industry
FII Foreign Institutional Investor
FIMMDA Fixed Income Money Market and Derivatives Association
of India
FIPB Foreign Investment Promotion Board
FISIM Financial Intermediation Services Indirectly Measured
FITL Funded Interest Term Loan
FIU-IND Financial Intelligence Unit India
FLAS Foreign Liabilities and Assets Survey
FMC Forward Market Commission
FMD Financial Markets Department
FoB Free on Board
FOF Flow Of Funds
FPI Foreign Portfolio Investment
FRA Forward Rate Agreement
FRB Floating Rate Bond
FRBM Act Fiscal Responsibility and Budget Management Act
FRMS Fraud Reporting and Monitoring System
FRN Floating Rate Note
FSAP Financial Sector Assessment Programme
FSR Financial Stability Report
FSS Farmers' Service Societies
FST Financial Sector Technology
FWG First Working Group on Money supply
709
Guidance Note on Audit of Banks (Revised 2019)
GBP Great Britain Pound
GCC General Credit Card
GCS Gold Card Scheme
GDCF Gross Domestic Capital Formation
GDP Gross Domestic Product
GDR Global Depository Receipt
GFD Gross Fiscal Deficit
GFS Government Finance Statistics
GIC General Insurance Corporation
GLS Generalized Least Squares
GNIE Government Not Included Elsewhere
GoI Government of India
GPD Gross Primary Deficit
G-Sec Government Securities
HDFC Housing Development Finance Corporation
HFT Held For Trading
HICP Harmonised Index of Consumer Prices
HO Head Office
HTM Held to maturity
HUDCO Housing & Urban Development Corporation
IBA Indian Bank's Association
IBRD International Bank for Reconstruction and Development
IBS International Banking Statistics
ICA Inter creditor Agreement
ICAR Indian Council of Agricultural Research
ICMR Indian Council of Medical Research
IDB India Development Bonds
IDD Industrial Development Department
IDR Investment Depreciation Reserve
IEC Independent Evaluation Committee
IFAD International Fund for Agricultural Development
IFC International Finance Corporation
710
Suggested Abbreviations used in the banking industry
IFC(W) International Finance Corporation (Washington)
IFCI Industrial Finance Corporation of India
IFSC Indian Financial System Code
IFR Investment Fluctuation Reserve Account
IFS International Financial Statistics
IGC India Gold Coins
IGLS Iterative Generalized Least Squares
IIBI Industrial Investment Bank of India
IIP Index of Industrial Production
IIP/InIP International Investment Position
IMD India Millennium Deposits
IMF International Monetary Fund
IMPS Immediate Payment System
IN India
INR Indian Rupee
IOTT Input-Output Transaction Table
IP Interest Payment
IRAC (Norms) Income Recognition, Asset Classification and
Provisioning pertaining to Advances
IRBI Industrial Reconstruction Bank of India
ISDA International Swaps and Derivative Association
ISIC International Standard Industrial Classification
ISO International Standards Organization
IT Information Technology
ITGGSM Internal Technical Group on Government Securities
Market
ITGI IT Governance Institute
ITIL IT Infrastructure Library
ITRS International Transaction Reporting System
IWGEDS International Working Group on External Debt Statistics
JLF Joint Lenders' Forum
JLG Joint Liability Groups
711
Guidance Note on Audit of Banks (Revised 2019)
JPC Joint Parliamentary Committee
KCC Kisan Credit Card
KVIB Khadi and Village Industries Board
KVIC Khadi & Village Industries Corporation
KYC Know your Customer
LAB Local Area Bank
LAF Liquidity Adjustment Facility
LAMPS Large-sized Adivasi Multipurpose Societies
LAS Loan & Advances by States
LBD Land Development Bank
LBS Locational Banking Statistics
LC Letter of credit
LERMS Liberalised Exchange Rate Management System
LIBOR London Inter-Bank Offer Rate
LIC Life Insurance Corporation of India
LME London Metal Exchange
LoC Letters of comfort
LOLR Lender of Last Resort
LoU Letter of Undertaking
LS Level Shift
LT Long Term
LTCCS Long-Term Co-operative Credit Structure
LTO Long Term Operation
M1 Narrow Money
M3 Broad Money
MA Moving Average
MAP Monitorable Action Plan
MCA Ministry of Corporate Affairs
MCAs Model Concession Agreements
MEDP Micro Enterprise Development Programme
MFDEF Micro Finance Development and Equity Fund
MFI Micro Finance Institution
712
Suggested Abbreviations used in the banking industry
MIBOR Mumbai Inter-Bank Offer Rate
MICR Magnetic Ink Character Recognition
MIGA Multilateral Investment Guarantee Agency
MIS Management Information System
MLRO Money Laundering Reporting Office
MLTGD Medium and Long Term Government Deposit
MMBCS Magnetic Media Based Clearing System
MMSE Minimum Mean Squared Errors
MNBC Miscellaneous Non-Banking Companies
MNSB Multilateral Net Settlement Batch
MOF Master Office File
MoF Ministry of Finance
MoU Memorandum of Understanding
MPLS Multi-Protocol Layer Switching
MRM Monitoring and Review Mechanism
MRR Minimum Retention Requirement
MSF Marginal Standing Facility
MSS Market Stabilisation Scheme
MT Mail Transfer
MTM Mark-To-Market
NABARD National Bank for Agriculture and Rural Development
NAC(LTO) National Agricultural Credit (Long Term Operation)
NAFCUB National Federation of Co-operative Urban Banks
NAIO Non Administratively Independent Office
NAS National Account Statistics
NASSCOM National Association of Software and Services
Companies
NAV Net Asset Value
NBC Net Bank Credit
NBC Non-Banking Companies
NBFC Non-Banking Financial Company
NBFI Non-Banking Financial Institutions
713
Guidance Note on Audit of Banks (Revised 2019)
NBV Net Book Value
NDS Negotiated Dealing System
NDS-OM NDS Order Matching
NDTL Net Demand and Time Liability
NEC Not Elsewhere Classified
NEDFi North Eastern Development Finance Corporation Ltd.
NEER Nominal Effective Exchange Rate
NEFT National Electronic Fund Transfer
NFA Non-Foreign Exchange Assets
NFCC National Foundation for Credit Counselling
NFD Net Fiscal Deficit
NFGBC Non-food Gross Bank Credit
NFS National Financial Switch
NGO Non-Government Organisation
NHB National Housing Bank
NHC National Housing Credit
NIA New India Assurance Company Limited
NIC National Industrial Credit
NIC National Industrial Classification
NIF Note Issuance Facility
NIM Net Interest Margin
NIMC National Implementation Monitoring Committee
NNML Net Non-Monetary Liabilities
NOC No Objection Certificate
NOF Net Owned Fund
NPA Non-Performing Asset
NPD Net Primary Deficit
NPFA Non-Performing Financial Assets
NPL Non-Performing Loan
NPRB Net Primary Revenue Balance
NPV Net Present Value
NR(E)RA Non-Resident (External) Rupee Account
714
Suggested Abbreviations used in the banking industry
NR(NR)RA Non-Resident (Non-Repatriable) Rupee Account
NRE Non-Resident External
NRG Non-Resident Government
NRI Non-Resident Indian
NRNR Non Resident Non Repatriable (Account)
NRSR Non Resident Special Rupee (Account)
NSC National Statistical Commission
NSE National Stock Exchange
NSSF National Small Savings Fund
OBS Off-balance Sheet
OBU Off-Shore Banking Unit
OD Over Draft
ODA Official Development Assistance
OECD Organisation for Economic Co-operation and
Development
OECO Organisaton for Economic Co-operation
OFI Other Financial Institutions
OLRR On-line Reject Repair
OLTAS On-line Tax Accounting System
OMO Open Market Operations
ORFS On-line Returns Filing System
OSCB Other Indian Scheduled Commercial Bank
OSMOS Off-Site Monitoring and Surveillance System
OSS Off-site Surveillance System
OTC Over the Counter
OTS One Time Settlement
PACF Partial Auto-Correlation Function
PACS Primary Agricultural Credit Society
PAN Permanent Account Number
PAIS Personal Accident Insurance Scheme
PCARDB Primary Co-operative Agriculture and Rural
Development Bank
715
Guidance Note on Audit of Banks (Revised 2019)
PCR Provisioning Coverage Ratio
PD Primary Dealer
PD Primary Deficit
PDAI Primary Dealers Association of India
PDO Public Debt Office
PDO-NDS Public Debt Office-cum-Negotiated Dealing System
PES Public Enterprises Survey
PF Provident Fund
PIO Persons of Indian Origin
PIO Principal Inspection Officer
PKI Public Key Infrastructure
PLR Prime Lending Rate
PMLA Prevention of Money Laundering Act
PMRY Prime Minister Rojgar Yojna
PO Principal Office
POS Point of Sale
PPP Public-Private Partnership
PRB Primary Revenue Balance
PSB Public Sector Bank
PSE Public Sector Enterprise
PTC Pass-through certificates
PUC Paid Up Capital
QIS Quantitative Impact Study
QRR Quick Review Report
RBI Reserve Bank of India
RBIA Risk-Based Internal Audit
RBS Risk-Based Supervision
RC Reconstruction Company
RCS Registrar of Co-operative Societies
RD Revenue Deficit
RDBMS Relational Database Management System
RE Revenue Expenditure
716
Suggested Abbreviations used in the banking industry
REC Rural Electrification Corporation
REER Real Effective Exchange Rate
RERFA Reserve for Exchange Rate Fluctuations Account
R-GDS Revamped Gold Deposit Scheme
R-GML Revamped Gold Metal Loan Scheme
RFC Residents Foreign Currency
RIB Resurgent India Bonds
RIDF Rural Infrastructural Development Fund
RLA Recoveries of Loans & Advances
RLC Repayment of Loans to Centre
RMB Renminbi (Chinese)
RNBC Residuary Non-Banking Company
RO Regional Office
ROC Registrar of Companies
RPA Rupee Payment Area
RPCD Rural Planning and Credit Department, RBI
RR Revenue Receipts
RRB Regional Rural Bank
RTGS Real Time Gross Settlement System
RTP Reserve Tranche Position
RUF Revolving Underwriting Facility
RWA Risk Weighted Asset
SAA Service Area Approach
SACP Special Agricultural Credit Plan
SAM Social Accounting Matrix
SAO Seasonal Agricultural Operations
SAR Self-Assessment Report
SARFAESI Securitisation and Reconstruction of Financial Assets
and Enforcement of Security Interest
SARS Severe Acute Respiratory Syndrome
SAS Statistical Analysis System
SBI State Bank of India
717
Guidance Note on Audit of Banks (Revised 2019)
SBNs Specified Bank Notes
SC Securitisation Company
SCARDB State Co-operative Agriculture and Rural
Development Bank
SCB Scheduled Commercial Bank
SCB State Cooperative Bank
SCS Size Class Strata
SDDS Special Data Dissemination Standards
SDR Special Drawing Right
SDS Special Deposit Scheme
SEB State Electricity Board
SEBI Securities and Exchange Board of India
SEEUY Self Employment for Educated Unemployed Youths
SEFCs Small Enterprises Financial Centres
SEFT Special Electronic Funds Transfer
SEZ Special Economic Zones
SFAC Small Farmers Agri-Business Consortium
SFC State Financial Corporation
SFMS Structured Financial Messaging System
SGL Subsidiary General Ledger
SGSY Swarn Jayanti Gram Swarojgar Yojna
SHG Self-Help Group
SHPI Self-Help Promoting Institutions
SIDBI Small Industries Development Bank of India
SIDC State Industrial Development Corporation
SIPS Systemically Important Payment System
SI-SPA Systems Improvement Scheme under Special Project
Agriculture
SJSRY Swarna Jayanti Shahari Rojgar Yojna
SLA Service Level Agreement
SLAF Second Liquidity Adjustment Facility
SLBCs State Level Bankers' Committees
718
Suggested Abbreviations used in the banking industry
SLEPCS State Level Export Promotion Committees
SLR Statutory Liquidity Ratio
SLRS Scheme for Liberalisation and Rehabilitation of
Scavengers
SMA Special Mention Account
SME Small and Medium Enterprise
SMG Standing Monitoring Group
SNA System of National Accounts
SPV Special Purpose Vehicle
SRWTO Small Road & Water Transport Operators
SSC Special Sub-Committees
SSI Small Scale Industry
SSSBEs Small Scale Service & Business Enterprises
ST Scheduled Tribe
STBD Short Term Bank Deposit
StCB State Co-operative Bank
STCCS Short-Term Co-operative Credit Structure
STP Straight Through Processing
STR Suspicious Transaction Report
STRIPS Separate Trading of Registered Interest and Principal
of Securities
SWG Second Working Group on Money Supply
SWIFT Society for Worldwide Financial Telecommunication
TAFCUB Task Force for Urban Co-operative Banks
TBs Treasury Bills
TC Temporary Change
TEV Techno-Economic Viability
TFCI Tourism Finance Corporation of India
TLI Term Lending Institutions
TT Telegraphic Transfer
UBB Uniform Balance Book
UBD Urban Banks Department
719
Guidance Note on Audit of Banks (Revised 2019)
UCB Urban Co-operative Bank
UCIC Unique Customer Identification Code
UCN Uniform Code Number
UIA United India Assurance Company Ltd.
UIDAI Unique Identification Authority of India
UPI Unified Payments Interface
US United States
USD US Dollars
UTI Unit Trust of India
UTLBC Union Territory Level Bankers' Committee
VaR Value at Risk
VC Venture Capital
VCF Venture Capital Fund
VKC Village Knowledge Centre
VPN Virtual Private Networks
VRS Voluntary Retirement Scheme
VSAT Very Small Aperture Terminal
WADR Weighted Average Discount Rate
WCDL Working Capital Demand Loan
WCTL Working capital term loan
WEO World Economic Outlook
WGMS Working Group on Money Supply: Analytics and
Methodology of Compilation
WGRFIS Working Group on Future Role of Financial Institutions
WPI Wholesale Price Index
WSS Weekly Statistical Supplement
YTM Yield to Maturity
ZO Zonal Office
XBRL Extensible Business Reporting Language
720
4
Illustrative list for Basis of
Selection of Advance Accounts in
case of Bank Branch Audit
The list given for Bank Branch Auditors is only illustrative in nature. Members
are expected to exercise their professional judgment while using this list
depending upon facts and circumstances of each case.
Basis of selection of Advances accounts to be No. of
examined by Branch Auditor Accounts
1. All Large accounts. (as defined- Rs. 2.00 crores or 5% of
the Portfolio, whichever is less)
2. Accounts wherein process under IBC is mandated but
not initiated by branch
3. Borrowers wherein process of IBC initiated by any of the
creditors including bank
4. NPA accounts upgraded to Standard during the year.
5. Advances where Restructuring Proposals/ requests are
pending approval/disposal at year end.
6. Accounts Restructured in the earlier years to determine
their year-end status, if in default or not classified as per
RBI norms.
7. Accounts Restructured during the year to determine their
year-end classification.
8. Restructured advances with moratorium of Interest
where interest is accrued contrary to RBI applicable
norms.
9. FITL cases arising out of Restructuring where
corresponding provisions are held in "Sundry Liabilities
Account (Interest Capitalization)".
10. Advances accounts where there is an initiation of
721
Guidance Note on Audit of Banks (Revised 2019)
proceedings involving Investigation, vigilance, enquiry
and those where fraud is reported.
11. Staff Advances where the persons have ceased to be
employees of the Bank; and accounts in default.
12. BIFR cases classified as Standard.
13. SSI/SME cases under rehabilitation as at the year end.
14. Standard advances in litigation.
15. Central Government guaranteed cases which are
Standard non-performing.
16. Standard accounts where there is Interest Suspense/
Unapplied Interest.
17. Advances in the list of willful defaulters of the RBI.
18. Cases where one time settlement (OTS) has been
sought; and those in which OTS was accepted but there
is default in compliance.
19. Advances subject to re-financing.
20. Accounts which are not renewed regularly or adhoc not
regularised for more than 180 days
21. Accounts which are classified as NPAs and also
upgraded during the year
22. Accounts which are reported to CRILC during the year
23. Fresh NPAs identified by the Branch.
24. NPA cases where the assessed realizable value of the
securities has a significant shortfall 50% or more.
25. NPA cases where the realizable value of the security as
assessed by the Bank/approved valuers /RBI is less
than 10% of the outstanding.
26. Standard Accounts with temporary deficiencies as per
Para 4.2.4 of Master Circular on Advances.
27. Quick Mortality Cases.
28. Advances comprising frauds detected. (Para 4.2.9.(ii) of
the IRAC Master Circular dated 1.7.2015)
29. Other Accounts, not covered above, with adverse
comments in the existing/latest Reports. (as per Para 1
of Annexure I to the initial letter to Branch)
30. Comments accounts as per latest RBI AFI Report
722
5
Illustrative Bank Branch Audit
Programme for the Year
ended March 31, 2019
Introduction
In present scenario of audit of branches of banks, the most important aspect
is proper planning. Planning means advance thinking and that should be
done based on knowledge of branch business. It is important to have
knowledge about Composition of Business of a particular branch which is
under audit. Because of variety of products and diversified bank business,
auditor cannot apply the same yardstick for the branches under audit. Today,
the whole process of banking is computerized however; the Audit Report is
required to be signed manually after physical checking of records, documents
and accounts maintained under CBS.
Many of the Banks implemented a web application for posting & online
submission of Branch Audit Report, Long Form Audit Report, Tax Audit
Report and various certificates, therefore review the closing instruction of the
Bank prior to commencement of the audit is utmost need to understand the
manner and structure in which reporting is required to be made on online
web base application. The report in these cases signed digitally.
In absence of clear understanding and the pre-requisite information like
borrower account No/ Customer ID's details of the facility, security, sector
etc. it would not be even possible to report any change in classification and
any adverse finding in the main report as well as in Long Form Audit Report.
In view of this it is important to understand the reporting structure and auditor
should prepare their comments / Memorandum of changes in the similar
format and manner for reporting, by getting system format as circulated by
the respective Banks with the closing instructions.
723
Guidance Note on Audit of Banks (Revised 2019)
The branch audit generally may be bifurcated into
following Components
Type of Report Coverage
Branch Statutory Audit 1. Audit of Advances and reporting on
divergence in assets classification and income
recognition, which is generally reported
through Memorandum of Changes which form
part of Main Audit Report;
2. Audit of all other items of Assets and
liabilities and Income and expenditure
appearing in the financial statement.
Tax Audit Reports and These reports are separate from Branch Audit
Long Form Audit Report Report:
1. As per Section 44AB of Income Tax Act,
1961, the Bank is under statutory
obligation to get the Tax Audit conducted
by Chartered Accountant; and
2. Long Form Audit Report covers reporting
on the operational aspects of the Branch
working as per RBI requirements.
Certificates Required to be verified as per respective
Banks Closing Instruction keeping in view RBI
Guidelines, Guidelines of the respective
schemes notified by the Central / State
Government.
Following are the generally followed steps for conducting of
Branch audit:
1. Appointment / engagement letter for Branch Statutory audit, with closing
circulars.
2. NOC from the previous auditor.
3. Pre-Audit discussion with branch.
4. Audit planning, to include Understanding of the Branch software and
commands for view of borrower accounts and generation of various MIS /
Critical / exceptional reports.
5. Execution of the audit as given in the Annexure I.
724
Illustrative Bank Branch Audit Programme
6. Discussion of the draft branch audit report with bank.
7. Preparation of Memorandum of Changes and effect of the same in books
of account of bank.
8. Review of the Post Memorandum (Post MOC) trail balance and
reconciliation with the pre memorandum (Pre MOC) trial balance to
ensure the correct accounting effect of memorandum of changes,
wherever applicable.
9. Submission of audit report to branch and copy to central statutory
auditors.
Following are the area wise documents to be collected and
reviewed for conducting branch audit:
1. Trial Balance as on 31st March.
2. Closing circular issued by Bank's head office for conducting branch audit
Every bank issued the closing circular which contain the concern areas
and list of certificates required to be certified by the branch auditor.
3. Review of previous years auditor report / LFAR.
4. Latest RBI master circular for "Income recognition and assets
classification" & other relevant circulars.
5. List of comments of RBI inspection report towards the branch.
6. Latest branch concurrent audit report /Internal inspection report/
Diligence Report / Credit Audit Report with their compliances.
7. Copy of vigilance enquiry or any special investigation reports.
8. Comparative analysis of the trial balance with the last year's audited trail
balance.
9. Review of Ghosh and Jilani committee Recommendations.
10. Documents related to verification of advances
List of stress advances (SMA-2) as on 15th March. (stress advances
/ SMA-2 report indicate the list of advances which are overdue for
more than 60 days and if the same is not regularized before year
end i.e. 31st march than the advance will become NPA)
List of new sanction made during the year.
List of account referred for Restructuring
725
Guidance Note on Audit of Banks (Revised 2019)
Accounts wherein process under IBC is mandated but not initiated by
branch
Borrowers wherein process of IBC initiated by any of the creditors
including bank
List of Bank guarantee and Letter of credit.
11. Documents related to NPA's:
List of NPA accounts as on 31st March.
List of accounts upgraded during the financial year.
List of accounts downgraded during the year.
List of early mortality cases for the year under audit.
Details of the NPA classification with secured /unsecured details and
NPA provision amount.
Review of the valuation report of loan account. Valuation report older
than 3 years cannot be consider as security (1 year in case of stock)
and 100% provision need to provide on the expired secured portion.
12. Fixed Assets:
Fixed Assets register as on 31st March.
List of new assets purchased during the year.
List of fixed assets sold during the year.
Physical verification report of branch fixed assets if conducted during
the year.
Depreciation working as on 31st March.
13. Bank reconciliation:
List of bank account which branch maintained with other banks.
Reconciliation statement of all banks account as on 31st march.
14. Inter branch reconciliation:
Inter branch reconciliation statement.
Provision for net outstanding debit balance for more than 6 month.
(refer RBI circular DBOD No. BP.BC. 73 /21.04.018/2002-03)
15. Cash
Physical cash balance verification during branch audit period (cash
on hand as well as cash at ATM, if applicable).
726
Illustrative Bank Branch Audit Programme
Report of the physical cash verification conducted by branch on 31st
March.
Audit of Advances
Audit of advances is discussed elsewhere in the ICAI's Journal under
appropriate article. However from the angle of planning following aspects
must be kept in mind:
1. Obtain top exposure accounts: It may be advisable for a branch
auditor to ask the list accounts/ exposures along with all the details such
as status, overdue amount and security etc. before starting of the audit.
2. Obtain the list of stressed accounts: The banks monitors stressed
accounts on daily basis. The account that generally has overdue beyond
60 days or likely to slip to NPA at the quarter end is termed as stressed
account (some banks may use different terminology). It is advisable to
obtain such list of stressed accounts at least 15 days ahead of the
closing date i.e. say stressed account list as on 15th March. This will
provide the auditor a ready list of such accounts. The auditor then can
scrutinise each to know whether the account has slipped or if not
whether has been kept standard by unusual transaction that cannot be
termed as business transaction. Like deposit and withdrawal of cash, just
to show the credit turnover during the quarter in cash credit account.
3. Obtain the list of restructured accounts: Restructured account
portfolio requires separate additional provisioning. It is necessary to
obtain the list of such accounts and ensure whether the restructure is as
per the RBI directives. As per latest RBI guidelines, all new restructure /
CDR account will be classified as NPA.
4. Obtain the list of accounts covered under revised framework for
resolution of stressed assets: As per latest RBI guidelines, all new
restructure / CDR account will be classified as NPA. The accounts which
have been covered under revised framework for resolution of stressed
assets, the compliance with the terms of the revised framework needs to
be verified
5. Accounts referred to or directed to be referred under IBC
Obtained list of Accounts wherein process under IBC is mandated but not
initiated by branch and / or Borrowers wherein process of IBC initiated by
727
Guidance Note on Audit of Banks (Revised 2019)
any of the creditors including bank. Such accounts needs to be reviewed
carefully by the auditor and adequate provision needs to be made besides
correct classification of such advances.
6. Obtain the list of unsecured exposures above Rs. 25 Lacs.:
Unsecured exposure has significant impact on the bank, if slips to NPA.
Many times such accounts are reviewed in the traditional manner. These
require close monitoring not only from the perspective of financial
parameters of the prudential guidelines but also non-financial parameters
that give signals of the possible ill health. The banking industry has faced
severe damages on account of non-identification of such non-financial
parameters.
7. Early mortality cases: Any advance slippage to NPA within 12 months
of its introduction is called early mortality case. Early mortality cases
invoke penalty to the sanctioning authorities. This will have to be
checked to understand the reason for such happening to avoid such
cases in future and also to find out whether there are any cases
classified as performing on some untenable ground to push it beyond
early mortality.
8. Upgraded accounts during the Year: Review of the upgraded accounts
is one of the important area to be check during audit. As per RBI circular,
the account will get upgraded when arrears of interest and principal are
paid by the borrower. After recovery, the accounts will get upgraded to
standard assets. There should not be any overdue in borrower accounts
as on date of up-gradation. The recovery in the accounts need to be
review specially in cash of cash credit accounts where the borrower
rotate the fund just to keep the account as performing assets.
9. Evergreening of accounts: Evergreening refers to the practice of giving
a fresh loan to repay an old one. Technically, evergreening refers to the
practice of managing the balance sheet through means, which may not
be violating banking laws in letter, but breaching them in spirit. To
Illustrate and to make it more clear : say a bank disburse a loan of Rs
10000 to a borrower and the account become overdue after a year or two
, the same bank sanction a loan of Rs. 20000 or Rs. 30000 which enable
borrower to repay first loan. Therefore, the source of recovery needs to
be review in case of stress accounts.
728
Illustrative Bank Branch Audit Programme
10. Other routine checks: The auditor may engage into other routine check
of advances to satisfy himself such as classification of advances, new
sanctions during the year, monitoring mechanism and provisioning under
prudential norms. It may be pertinent to mention here two broad aspects
that are heavily dependent on the branch auditor relating to advances.
Also these are one of the most strong argument, amongst many, why
branch audits are necessary even in CBS environment:
Checking of documentation : Documentations for newly sanctioned
advances along with their enforceability, review documents and its
appropriate reflection in CBS;
Security value for provisioning: After classification, the most
important aspect in presenting the true and fair view of the financial
statements of a bank is correct provisioning amount. This highly
depends on fair assessment of security value. The base documents
relating to the valuation are usually available at the branches.
Correct depiction thereof in the CBS is a crucial check.
Audit of other Items in Trial Balance
It may not be necessary to elaborate on this point as this has been basic skill
of auditing profession. However, following aspects may require specific
attention of a branch auditor:
1. Suspense, Inter Branch reconciliation and any other pending
reconciliation item in Trial Balance: As per the RBI guidelines, any
debit entry in these accounts appearing for more than 6 months require
100% provision.
2. Provisions other than relating to advances: Year-end accounting
provision that do not get generated through CBS require specific
attention at the branch level. It may be advisable to do a comparative
study of last year end, half year and current year end figure comparison.
This throws lot of insights into the branch operations.
Ensuring various compliances:
Generally the branch requires following various compliances in respect of
audit:
1. Concurrent Audit report: Any comments or remarks in the concurrent
audit report that the branch is required to comply with.
729
Guidance Note on Audit of Banks (Revised 2019)
2. Compliance to RBI Inspection report: If RBI has conducted inspection
in the branch, the comments in the report need compliance. Any non-
compliance under the pretext that the bank has represented to RBI to
reconsider the observation should not be accepted. RBI has clearly
taken a stand that unless auditor is physically shown a letter of reversal
from RBI comments in their report must be adhered to.
3. Compliance to Internal audit report: If the bank has conducted internal
audit, which usually an internal exercise, obtain the report and check for
the compliances thereof.
4. Stock audit report: Generally an account having exposure of Rs. 5 Cr.
and above requires stock audit, the compliance thereof should be
commented upon. Also any adverse comment in the report needs to be
dealt with appropriately.
5. Application of interest in CBS: Generally bankers always argue that
the interest is calculated by the system and requires no cross
verification. While this is true, the correct calculation by the system is
subject to correct input by the branch staff relating to interest. Hence
input of interest rates requires test check.
730
Illustrative Bank Branch Audit Programme
Annexure I
Details of the Authorised Branch Manager:
Persons of the bank
Others (Specify):
Audit Aspects Covered By Extent of
Whom Check
General
1. Engagement letter to the
appointing authority
2. Letter for NOC to previous auditors
3. Meeting and discussion with the
bank branch management and
understanding the profile of the
branch and its business and take a
note on the same.
4. Letter of requirement to the Branch
5. Review of
previous year's audit report/
LFAR;
current period's Internal Audit
Report/ Concurrent Audit
Report;
Revenue Audit Report;
RBI Inspection Report;
compliance of the branch to all
of the above; and
any other special review
report.
6. Physical verification of
cash;
Gold ;(for Gold loan)
and valuable securities.
7. Note down
Shortage of cash appearing in
731
Guidance Note on Audit of Banks (Revised 2019)
Audit Aspects Covered By Extent of
Whom Check
Trial Balance;
Difference in physical
verification of gold.
8. Reconciliation of the current account
maintained with other banks /
Reserve Bank of India
9. Reconciliation of NOSTRO account
with Nostro Mirror Account
10. Physical verification of Investments
(obtain certificate from bank
manager for the same). If
investment is hold /done by the
Branch.
11. Understand the system in CBS at
Branch
verify controls;
verify exceptional report;
understand the editable &
uneditable fields at Branch;
system of downgrading &
upgrading of accounts;
interest calculations;
Generation of reports relating to
advances classification and
Capital Adequacy calculation,
etc.
12. Compliance of instructions issued
by bank's year and closing
circulars, other relevant internal
instructions/circulars, Master
circulars and other notifications
issued by RBI, significant
accounting policies of the bank
Mandatory Accounting
Standards/Auditing Standards and
other notification.
13. Prepare a list of various closing
732
Illustrative Bank Branch Audit Programme
Audit Aspects Covered By Extent of
Whom Check
returns to be verified and certified,
and then checking of the same
during the audit.
Checking of Balance Sheet Items
1. Checking of the advances:
Take list of all advances along with
facility wise limits, outstanding,
Name of Lead bank, Credit Rating,
Credit summations in the account,
last date of submission of stock
statement, date of review of
account, etc. This shall help to
select the accounts for scrutiny in
detail.
Critical review of all large advances
and their reporting as per
prescribed norms.
Classification of advances as per
IRAC norms.
Latest valuation of security given
against advances.
Provisions on NPA as per IRAC
norms.
Review of all major restructured
cases along with the compliance of
norms as per RBI Guidelines.
List of all SMA 2 accounts (and
other accounts mandated for
reporting) and reporting of the
same to concerned authorities
(CRILC).
Loan Accounts (Performing)
I. Review of all large advances with
balance of lower of 5 % or Rs. 2
crore of total advances.
733
Guidance Note on Audit of Banks (Revised 2019)
Audit Aspects Covered By Extent of
Whom Check
II. Review of loans sanctioned during
the year.
III. Review of other advances on test
check basis.
IV. Review of adverse comments by
Concurrent auditors, RBI/internal
inspectors and the reply given and
corrective actions taken by the
branch.
V. Review of suit filed and decree
accounts on sample basis with
respect to provision thereon and
progress of recovery thereof and
Classification as per IRAC norms.
VI. Review of accounts upgraded
during the year from NPA to
standard. and ensure full recovery
of total overdues before
upgradation.
VII. Review of all accounts frequently
exceeding limits/DP and watch-list
accounts.
VIII. Also verify all the credit card dues
which are overdue & debit
balances in SB A/c.
IX. Check Drawing Power calculation
in detail as per the norms of the
bank.
Loan Accounts (Non Performing)
I. Review the accounts which are
classified as NPA during the year
w.r.t Security Value, Interest
Reversed, Date of NPA,
provisioning thereon etc.
II. Review the annual stock audit
report for the NPA with balance of
Rs.5 cr. and above & latest
734
Illustrative Bank Branch Audit Programme
Audit Aspects Covered By Extent of
Whom Check
valuation report for the immovable
properties in case the valuation is
older than 3 years.
NOTE:
(i) 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 and Book
statements, drawing power,
insurance, inspection of
stock/security, operations in the
account, etc.
(ii) All the accounts verified in category
(i) to (ix) should be documented.
2. Verify controls in respect of the
following important items of
assets.
(i) Dual custody of cash;
(ii) Custody and issue of /pay
orders/other stationery items
etc.;
(iii) ATM cash as per books and
actual balance tallied at year
end.
3.Fixed Assets
I. Checking of additions/deduction/
transfers of fixed assets,
supported by proper bills/invoices
and confirmation of date put to
use. Compliance of Accounting
735
Guidance Note on Audit of Banks (Revised 2019)
Audit Aspects Covered By Extent of
Whom Check
Standard related to fixed assets.
II. Checking of Depreciation on
additions, deduction during the
year and on existing assets as
per the policy of the bank.
III. Verification of Fixed Assets
Schedule for furniture & fixtures
and other assets and
reconciliation with figures
appearing in the Balance Sheet
and FA management software
used by the bank (if any).
4. Deposits
a) Verification of Anti Money
Laundering guidelines and
Compliance with KYC norms on
test check basis that overdue
deposits;
b) Check TDS compliance on the
interest paid and on test check
basis checking of Form 15G & 15H
and confirm whether those forms
are submitted with respective
Income Tax Authority;
c) Movement of Deposit vis-à-vis
movement in interest expense.
5. Inter-Office & Suspense A/c:
1. Reconciliation of accounts with
other banks, head office and inter
branch adjustment accounts.
2. Inter Office Reconciliation (IOR)
Accounts:
I. Verify Inter Branch Items In
Transit (IBIT) account for old
entries.
II. Compare on test Check basis,
the balance and the entries in
736
Illustrative Bank Branch Audit Programme
Audit Aspects Covered By Extent of
Whom Check
IOR Accounts with the copies of
the statements submitted to the
IOR department/s.
III. Old un reconciled entries are
being provided/ reported to HO
for provision.
3. Detailed checking of suspense
accounts credit as well as debit
schedules. i.e., Nominal ledger.
Balance Sheet Finalisation
1. Scrutiny of Balance Sheet,
particularly
i) that all the balances are shown
in proper heads and broadly
compare previous year figure to
understand material variance;
ii) Check for any negative balance
in the trial balance. (i.e. assets /
expenses having credit
balances and liability / income
having debit balances)
ii) check in case of advances that:
a) interest accrued but not due
on loans is not included in
advances.
b) credit balances in O/D, CC
inoperative current accounts
should not be netted off with
advances and the same
should be shown under
demand deposits.
c) Verification of Anti Money
Laundering guidelines and
Compliance with KYC norms
on test check basis.
2. Checking:
(i) Liability under Bank Guarantee/
737
Guidance Note on Audit of Banks (Revised 2019)
Audit Aspects Covered By Extent of
Whom Check
L/C and effects of expired BGs.
(ii) Reconciliation of General
Ledger and Subsidiary Ledger.
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). Ensure that interest
provision on overdue F.D. has been
made as per latest RBI guidelines.
Check the system is properly
configured to check the interest
calculation and the changes in
interest rate is changed in system
on respective dates.
2. Test checking of
interest/commission on various
advances, bills, L.C., Guarantees,
etc.
3. Test checking of
discount/commission on bills
discounted and others income like
commitment charges, processing
fees, recovery of insurance/ legal
fees etc.
4. Derive various ratios of items of
income with comparable and
related assets (like Avg. Interest
Income to Average Advances etc.)
and verify major movements or
variances.
5. Checking of interest in NOSTRO
Accounts debit balances.
6. Verification of recovery on account
of locker rent, staff accommodation,
738
Illustrative Bank Branch Audit Programme
Audit Aspects Covered By Extent of
Whom Check
etc., with details of arrears, if any.
7. Commission income on account of
Government Business, i.e.,
collection as well as remittance of
Income tax, sales tax, excise duty,
etc.,
8. Details of Prior Period items of
Income as well as expenses and
complete details of provisions to be
made, if any.
9. Booking of Interest Income on
account of partial recovery in
NPA's.
10 Note down the reasons for material
variances, if any.
Others
1. Checking of statement of frauds
adequacy of provision, timely
reporting to competent authority,
recovery and movement in
balances.
2. Checking of statement of claims
against the bank not acknowledged
as debt.
3. Checking of Foreign Currency
forward exchange contracts
showing sales and purchase
separately. Review of NRE and
FCNR accounts, if any.
4. Checking of Guarantees given on
behalf of Constituents.
5. Checking of Acceptance,
endorsements and other
obligations, i.e., L/C and bills
accepted by the bank on behalf of
customers.
(Particularly check in case of Clause 4 and 5 above, whether the above
739
Guidance Note on Audit of Banks (Revised 2019)
Audit Aspects Covered By Extent of
Whom Check
guarantees and LC issued are within the powers of the authorised person
and proper procedures have been followed for issuing the same. Review the
position of the above as at the year-end)
6. Other contingent liability, if any.
7. Checking of and preparation of
Interest Subsidy certificate (as per
various RBI & Government
schemes), correct accounting &
whether the same are given to the
eligible, borrowers.
8. Checking of write off proposal and
DICGC claims, sharing of recovery,
etc.
9. Checking of annual returns on
protested bills/ recalled debt
accounts (PB/RD).
10. Checking of LFAR schedules and
preparation of LFAR. (Detailed
planning for preparation of LFAR
be done at the time of
commencement of audit and
detailed guidance be sought from
the chapter on LFAR in this
guidance note).
11. Checking of Tax Audit annexures
and preparation of Tax Audit
Report.
Final Audit and Reporting
1. Preparation of Audit Report as per
format prescribed by ICAI under SA
700 (Revised) and under any other
regulatory authority.
2. Preparation of memorandum of
changes for changes to be made in
classification of advances and in
any item of asset/liability and profit
740
Illustrative Bank Branch Audit Programme
Audit Aspects Covered By Extent of
Whom Check
and loss account with other
remarks and/ or information which
requires further attention at
Regional/Zonal Office level.
3. Preparation of Tax Audit Report.
4. Preparation of Long Form Audit
Report (by giving annexures where
ever necessary).
To collect the following Certificates:
1. Physical verification of the fixed
assets carried out on March 31,
2019/During the year.
2. Physical verification of Investment
carried out on March 31, 2019/
During the Year. If investment are
held or appearing in the Trial
Balance.
3. Physical verification of the cash &
other items as on March 31, 2019.
4. Written Representation Letter.
To verify and issue the certificates (as applicable):
Illustrative list
1. Certificate of Ghosh and Jilani
committee Recommendations.
2. Certificate giving details of claims
lodged with DICGC / ECGC
however, rejected by them.
3. Risk weighted assets as per the
capital adequacy report. (BASEL II
& III)
4. Certificate for treating an account
as bad or doubtful of recovery as
per the requirement of DI and CGC.
5. Subsidy claim under Prime Minister
Rojgar Yojna Or any other scheme
of the Central/State Government.
741
Guidance Note on Audit of Banks (Revised 2019)
Audit Aspects Covered By Extent of
Whom Check
6. Certificate for Interest Subvention.
Prepared by: Reviewed by:
742
6
Illustrative Flow Charts for Use of
Core Banking Solution Software in
case of Bank Branch Audit
The advances are categorized in different Schemes and each them is codified.
The Branch auditor is required to get the understanding of the Scheme code and
can generate the report for all account under the Scheme by giving account
Number.
The Branch auditor on start of the audit obtain the Balance Report of the
advances Facility Wise / Scheme wise to identify the Scheme code of facility.
The illustrative Scheme codes are CCAGR Cash Credit Agriculture, CCOTH
Cash Credit Other and TLEDU Term loan Education etc.
Generally, in Branch audit if the Branch auditor can get the dump of the borrower
account for the given period in soft copy, the work of review of the advances can
be completed smoothly, the flow chart for Process of Generate A Pass Sheet will
be quite helpful to generate Scheme wise borrower account of the branch for a
given period (It can be for Four Years if required in case of Agriculture
Advances).
The review of the advances account can be made by generating the report for
each of the Scheme account. The report is generated in Text file (with .rpt
extension) and can be easily opened in note pad / word pad and easily portable
to excel. It's advisable to retain the main copy safe for documentation and
conversion to excel may be made coping the file with another name.
Illustrative important process Flow Chart of widely used banking software like
Finacle are given hereunder for:
1. How to know account number from Customer ID.
2. Flow Chart for review of the Loan account.
3. Flow chart to generate Text file for of Borrowers Accounts product wise /
Individual Account.
4. Flow Chart to Review Fixed Deposit Account Interest / TDS inquiry etc.
743
Guidance Note on Audit of Banks (Revised 2019)
744
Illustrative Flow Charts for Use of Core Banking Solution software
745
Guidance Note on Audit of Banks (Revised 2019)
746
7
List of Relevant Master
Directions issued by RBI
S. Date Direction No. Subject
No
.
1. July 1, 2016 RBI/DBS/2016-17/28 Master Directions on
(Updated July DBS.CO.CFMC.BC.No.1/ Frauds Classification
03, 2017) 23.04.001/2016-17 and Reporting by
commercial banks and
select FIs
2. June 23, 2016 RBI/DBR/2015-16/26 Master Direction -
Master Direction Reserve Bank of India
DBR.FID.No.108/01.02.0 (Financial Statements of
00/2015-16 All India Financial
Institutions -
Presentation,
Disclosure and
Reporting) Directions,
2016
3. May 26, 2016 RBI/DBR/2015-16/25 Master Direction-
(Updated Master Reserve Bank of India
September 25, Direction/DBR.FSD.No.1 (Financial Services
2017) 01/24.01.041/2015-16 provided by Banks)
Directions, 2016
4. May 12, 2016 RBI/DBR/2015-16/24 Master Direction
Master Direction Ownership in Private
DBR.PSBD.No. Sector Banks,
97/16.13.100/2015-16 Directions, 2016
5. April 21, 2016 RBI/DBR/2015-16/22 Master Direction
Master Direction Amalgamation of
DBR.PSBD.No. Private Sector Banks,
96/16.13.100/2015-16 Directions, 2016
Guidance Note on Audit of Banks (Revised 2019)
6. April 21, 2016 RBI/DBR/2015-16/21 Master Direction - Issue
Master Direction and Pricing of shares by
DBR.PSBD.No.95/16.13. Private Sector Banks,
100/2015-16 Directions, 2016
7. March03, RBI/DBR/2015-16/20 Master Direction -
2016 Master Direction Reserve Bank of India
(Updated DBR.Dir.No.85/13.03.00/ (Interest Rate on
March 29, 2015-16 Advances) Directions,
2016) 2016
8. March 03, RBI/DBR/2015-16/19 Master Direction -
2016 Master Direction DBR. Reserve Bank of India
Dir. (Interest Rate on
No.84/13.03.00/2015-16 Deposits) Directions,
2016
9. February 25, RBI/DBR/2015-16/18 Master Direction - Know
2016 Master Direction Your Customer (KYC)
(Updated July DBR.AML.BC.No.81/14.0 Direction, 2016
12, 2018) 1.001/2015-16
10. July 07, 2016 RBI/FMRD/2016-17/32 Master Direction on
FMRD. Master Direction Money Market
No. 2/2016-17 Instruments: Call/Notice
Money Market,
Commercial Paper,
Certificates of Deposit
and Non-Convertible
Debentures (original
maturity up to one year)
11. January 01, RBI/FED/ 2015-16/16 Master Direction
2016 FED Master Direction Opening and
(Updated No.2 /2015-16 Maintenance of
August 31, Rupee/Foreign
2018) Currency Vostro
Accounts of Non-
resident Exchange
Houses
12. October 17, RBI/FIDD/2018-19/64 Master Direction -
2018 Master Direction FIDD Reserve Bank of India
Co.FSD.BC. (Relief Measures by
748
List of Relevant Master Directions
9/05.10.001/2018-19 Banks in Areas Affected
by Natural Calamities)
Directions, 2017
13. July 24, 2017 RBI/FIDD/2017-18/56 Master Direction -
(Updated April Master Direction Lending to Micro, Small
25, 2018) FIDD.MSME & & Medium Enterprises
NFS.12/06.02.31/2017-18 (MSME) Sector
14. July 07, 2016 RBI/FIDD/2016-17/33 Master Direction-Priority
(Updated Master Direction Sector Lending-Targets
December 04, FIDD.CO.Plan.1/04.09.01 and Classification
2018) /2016-17
15. July 05, 2016 RBI/FMRD/2016-17/31 Master Direction - on
(Updated April FMRD Master Direction Risk Management and
02, 2018) No. 1/2016-17 Inter-Bank Dealings
16. July 03, 2018 RBI/DCM/2018-19/62 Master Direction on
Master Direction Levy of Penal Interest
DCM(CC) No.G - for Delayed
5/03.35.01/2018-19 Reporting/Wrong
Reporting/Non-
Reporting of Currency
Chest Transactions and
Inclusion of Ineligible
Amounts in Currency
Chest Balances
17. July 01, 2016 RBI/IDMD/2016-17/29 Master Direction
(Updated Master Direction Operational Guidelines
November 22, IDMD.PDRD.01/03.64.00/ for Primary Dealers
2018) 2016-17
18. October 11, RBI/DPSS/2017-18/58 Master Direction on
2017 Master Direction Issuance and Operation
(Updated DPSS.CO.PD.No.1164/0 of Prepaid Payment
December 29, 2.14.006/2017-18 Instruments
2017)
749
8
List of Relevant Master
Circulars Issued by RBI
S. N. Date Circular No. Subject
1. July 01, RBI/2015-16/101 Prudential Norms on Income
2015 DBR.No.BP.BC.2/21 Recognition, Asset
.04.048/2015-16 Classification and Provisioning
pertaining to Advances
2. July 01, RBI/2015-16/97 Prudential norms for
2015 DBR No BP.BC.6 classification, valuation and
/21.04.141/2015-16 operation of investment
portfolio by banks
3. July 01, RBI/2015-16 /95 Loans and Advances
2015 DBR.No.Dir.BC.10/1 Statutory and Other Restrictions
3.03.00/2015-16
4. July 01, RBI/2015 -16/36 Bank Finance to Non-Banking
2015 DBR.BP.BC.No.5/21 Financial Companies (NBFCs)
.04.172/2015-16
5. July 01, RBI /2015-16/70 Exposure Norms
2015 DBR.No.Dir.BC.12
/13.03.00/ 2015-16
6. July 01, RBI/2015-16/99 Disclosure in Financial
2015 DBR.BP.BC No.23 Statements - Notes to Accounts
/21.04.018/2015-16
7. July 01, RBI / 2015-16/76 Guarantees and Co-
2015 DBR. No. Dir. BC.11 acceptances
/13.03.00/2015-16
8. July 01, RBI/2015-16/98 Cash Reserve Ratio (CRR) and
2015 DBR.No.Ret.BC.24/ Statutory Liquidity Ratio (SLR)
12.01.001/2015-16
9. July 01, RBI/2015-16/31 Credit Card, Debit Card and
List of Relevant Master Circulars
2015 DBR.No.FSD.BC.18/ Rupee Denominated Co-
24.01.009/2015-16 branded Prepaid Card
operations of banks and Credit
Card issuing NBFCs
10. July 01, RBI/2015-16/30 Para-banking Activities
2015 DBR.No.FSD.BC.19/
24.01.001/2015-16
11. July 01, RBI/2015-16/86 Prudential Norms on Capital
2015 DBR.No.BP.BC. Adequacy-Basel I Framework
3/21.01.002/2015-16
12. July 01, RBI/2015-16/85 Prudential Guidelines on
2015 DBR.No.BP.BC.4./2 Capital Adequacy and Market
1.06.001/2015-16 Discipline - New Capital
Adequacy Framework (NCAF)
13. July 01, RBI/2015-16/46 Housing Finance
2015 DBR.No.DIR.BC.13/
08.12.001/2015-16
14. July 01, RBI /2015-16/39 Interest Rates on Rupee
2015 DBR.No.Dir.BC. Deposits held in Domestic,
7/13.03.00/2015-16 Ordinary Non-Resident (NRO)
and Non-Resident (External)
(NRE) Accounts
15. July 01, RBI/2015-16/100 Willful Defaulters
2015 DBR.No.CID.BC.22/
20.16.003/2015-16
16. July 01, RBI/ /2015-16/47 Rupee / Foreign Currency
2015 DBR No.DIR.BC.14/ Export Credit & Customer
04.02.002/ 2015-16 Service to Exporters
17. July 02, RBI/2018-19/07 SHG Bank Linkage
2018 FIDD.FID.BC.No.04/ Programme
12.01.033/ 2018-19
18. July 01, RBI/2015-16/ 35 Guidelines issued under
2015 DBR.AML.BC.No.16/ Section 36(1)(a) of the Banking
14.08.001/ 2015-16 Regulation Act, 1949 -
Implementation of the
provisions of Foreign
Contribution (Regulation) Act,
751
Guidance Note on Audit of Banks (Revised 2019)
2010
19. July 01, RBI/2015-16/58 Basel III Capital Regulations
2015 DBR.No.BP.BC.1/21
.06.201/2015-16
20. July 01, RBI/2015-16/59 Customer Service in Banks
2015 DBR No.Leg.BC.
21/09.07.006/2015-
16
21. July 02, RBI/2018-19/04 Detection and Impounding of
2018 DCM (FNVD) G- Counterfeit Notes
1/16.01.05/2018-19
22. July 02, RBI/2018-19/3 Facility for Exchange of Notes
2018 DCM (NE) No. G - and Coins
2/08.07.18/2018-19
23 July 01, RBI/2016-17/17 Mobile Banking transactions in
2016 DPSS.CO.PD.Mobile India Operative Guidelines for
Banking.No./2/02.23 Banks
.001/2016-2017
24 July 01, RBI/2016-2017/16 Policy Guidelines on Issuance
2016 DPSS.CO.PD.PPI.N and Operation of Pre-paid
o.01/02.14.006/2016 Payment Instruments in India
-17
25 July 04, RBI/2017-18/4 Kisan Credit Card (KCC)
2018 FIDD.CO.FSD.BC.N Scheme
o.7/05.05.010/2018-
19
752
9
List of Relevant General
Circulars
S.No. Date Title of the Circular Circular No.
1 January 1, Micro, Small and Medium RBI/2018-19/100
2019 Enterprises (MSME) DBR.No.BP.BC.18/21.04.04
sector Restructuring of 8/2018-19
Advances
2 December Basel III Framework on RBI/2018-19/98
28, 2018 Liquidity Standards - DBR.BP.BC.No.17/21.04.09
Liquidity Coverage Ratio 8/2018-19
(LCR), FALLCR against
credit disbursed to
NBFCs and HFCs
3 December 7.75% Savings (Taxable) RBI/2018-19/95
24, 2018 Bonds, 2018 - IDMD.CDD.No.1637/13.01.
Operational Guidelines 299/2018-19
4 December Guidelines on Loan RBI/2018-19/87
5, 2018 System for Delivery of DBR.BP.BC.No.12/21.04.04
Bank Credit 8/2018-19
5 December Section 24 and Section RBI/2018-19/86
05, 2018 56 of the Banking DBR.No.Ret.BC.10/12.02.0
Regulation Act, 1949 - 01/2018-19
Maintenance of Statutory
Liquidity Ratio (SLR
6 November Basel III Framework on RBI/2018-19/84
29, 2018 Liquidity Standards Net DBR.BP.BC.No.08/21.04.09
Stable Funding Ratio 8/2018-19
(NSFR) Final
Guidelines
7 October 19, Basel III Framework on RBI/2018-19/62
2018 Liquidity Standards - DBR.BP.BC.No.05/21.04.09
Liquidity Coverage Ratio 8/2018-19
(LCR), FALLCR against
credit disbursed to
Guidance Note on Audit of Banks (Revised 2019)
NBFCs and HFCs
8 September Basel III Framework on RBI/2018-19/51
27, 2018 Liquidity Standards - DBR.BP.BC.No.4/21.04.098
Liquidity Coverage Ratio /2018-19
(LCR), Liquidity Risk
Monitoring Tools and
LCR Disclosure
Standards
9 August 02, Maintenance of CRR/SLR RBI/2018-19/34
2018 on Foreign Currency DBR.Ret.BC.No.01/12.01.0
Assets/Liabilities 01/2018-19
Reference rate for
INR/USD and exchange
rate of other major
currencies
10 August 1, Change in Bank Rate RBI/2018-19/32
2018 DBR.No.Ret.BC.03/12.01.0
01/2018-19
11 July 27, Prudential Norms for RBI/2018-19/28
2018 Classification, Valuation DBR.BP.BC.No.002
and Operation of /21.04.141/2018-19
Investment Portfolio by
banks Valuation of
State Development Loans
12 July 24, Transactions in the `When RBI/2018-19/25
2018 Issued' (WI) market in FMRD.DIRD.03/14.03.007/2
Central Government 018-19
Securities
13 July 6, Prudential Norms for RBI/2018-19/12
2018 Classification, Valuation DCBR.BPD.(PCB/RCB)Cir.
and Operation of No.1/16.20.000/2018-19
Investment Portfolio by
Banks Spreading of
MTM
14 June 19, Priority Sector Lending RBI/2017-18/203
2018 Targets and Classification FIDD.CO.Plan.BC.22/04.09.
01/2017-18
15 June 15, Basel III Framework on RBI/2017-18/201
2018 Liquidity Standards - DBR.BP.BC.No.114/21.04.0
Liquidity Coverage Ratio 98/2017-18
(LCR), Liquidity Risk
754
List of Relevant General Circulars
Monitoring Tools and
LCR Disclosure
Standards
16 June 15, Prudential Norms for RBI/2017-18/200
2018 Classification, Valuation DBR.No.BP.BC.113
and Operation of /21.04.048/2017-18
Investment Portfolio by
Banks Spreading of
MTM losses and creation
of Investment Fluctuation
Reserve (IFR)
17 June 6, Marginal Standing Facility RBI/2017-2018/184
2018 FMOD.MAOG.No.124/01.18
.001/2017-18
18 June 06, Change in Bank Rate RBI/2017-18/185
2018 DBR.No.Ret.BC.107/12.01.
001/2017-18
19 May 17, Basel III Framework on RBI/2017-18/178
2018 Liquidity Standards Net DBR.BP.BC.No.106/21.04.0
Stable Funding Ratio 98/2017-18
(NSFR) Final
Guidelines
20 April 12, Liberalised Remittance RBI/2017-18/161 A.P. (DIR
2018 Scheme (LRS) for Series) Circular No. 23
Resident Individuals
daily reporting of
transactions
21 April 2, Prudential Norms for RBI/2017-18/147
2018 Classification, Valuation DBR.No.BP.BC.102/21.04.0
and Operation of 48/2017-18
Investment Portfolio by
Banks Spreading of
MTM losses and creation
of Investment Fluctuation
Reserve (IFR)
22 March 01, Priority Sector Lending RBI/2017-18/135
2018 Targets and Classification FIDD.CO.Plan.BC.18/04.09.
01/2017-18
23 February Resolution of Stressed RBI/2017-18/131
12, 2018 Assets Revised DBR.No.BP.BC.101/21.04.0
Framework 48/2017-18
755
Guidance Note on Audit of Banks (Revised 2019)
24 February Relief for MSME RBI/2017-18/129
07, 2018 Borrowers registered DBR.No.BP.BC.100/21.04.0
under Goods and 48/2017-18
Services Tax (GST)
25 August 16, Interest Subvention RBI/2017-2018/48
2017 Scheme for Short Term FIDD.CO.FSD.BC.No.14/05
Crop Loans during the .02.001/2017-18
year 2017-18
26 August 3, Natural Calamities Portal RBI/2017-2018/38
2017 Monthly Reporting FIDD.CO.FSD.BC.No.13/05
System .10.006/2017-18
27 August 3, Exclusion of the name of RBI/2017-2018/37
2017 State Bank of Bikaner DBR.No.Ret.BC.80/12.06.0
and Jaipur, State Bank of 04/2017-18
Hyderabad, State Bank of
Mysore, State Bank of
Patiala, State Bank of
Travancore and Bharatiya
Mahila Bank from the
Second Schedule to the
Reserve Bank of India
Act, 1934
28 August 2, Basel III Framework on RBI/2017-2018/36
2017 Liquidity Standards DBR.BP.BC.No.
Liquidity Coverage Ratio 81/21.04.098/2017-18
(LCR), Liquidity Risk
Monitoring Tools and
LCR Disclosure Standard
29 August 2, Change in Bank Rate RBI/2017-2018/34
2017 DBR.No.Ret.BC.82/12.01.0
01/2017-18
30 August 2, Liquidity Adjustment RBI/2017-2018/32
2017 Facility Repo and FMOD.MAOG.No.121/01.01
Reverse Repo Rates .001/2017-18
31 July 27, Appointment of Statutory RBI/2017-2018/29
2017 Central Auditors (SCAs) DBS.ARS.BC.04/08.91.001/
modification of rest period 2017-18
32 July 13, Interest rates for Small RBI/2017-2018/22
2017 Savings Schemes DGBA.GBD.69/15.02.005/2
017-18
33 July 13, Investment in plant and RBI/2017-2018/21
756
List of Relevant General Circulars
2017 machinery for the FIDD.MSME &
purpose of classification NFS.BC.No.10/06.02.31/20
as Micro, Small and 17-18
Medium Enterprises
documents to be relied
upon
34 July 6, Point of Presence (PoP) RBI/2017-2018/16
2017 Services under Pension DNBR(PD)CC.No.087/03.10
Fund Regulatory and .001/2017-18
Development Authority
(PFRDA) for National
Pension System (NPS)
35 July 3, Master Circular - Kisan RBI/2017-2018/4
2017 Credit Card (KCC) FIDD.CO.FSD.BC.No.7/05.
Scheme 05.010/2017-18
36 July 1, Master Circular RBI/2017-2018/10
2017 Deendayal Antyodaya FIDD.GSSD.CO.BC.No.04/
Yojana - National Rural 09.01.01/2017-18
Livelihoods Mission
(DAY-NRLM)
37 July 1, Master Circular - Credit RBI/2017-2018/7
2017 facilities to Scheduled FIDD.CO.GSSD.BC.No.06/
Castes (SCs) & 09.09.001/2017-18
Scheduled Tribes (STs)
38 July 1, Master Circular RBI/2017-2018/5
2017 Deendayal Antyodaya FIDD.GSSD.CO.BC.No.03/
Yojana National Urban 09.16.03/2017-18
Livelihoods Mission
(DAY-NULM)
39 June 22, Exclusion of "The Royal RBI/2016-2017/325
2017 Bank of Scotland N.V." DBR.No.Ret.BC.75/12.07.1
from the Second 50/2016-17
Schedule to the Reserve
Bank of India Act, 1934
40 June 13, , Prudential Guidelines on RBI/2016-2017/321
2017 Capital Adequacy and DBR.No.BP.BC.74/21.06.00
Market Discipline- New 9/2016-17
Capital Adequacy
Framework (NCAF) -
Eligible Credit Rating
Agencies INFOMERICS
Valuation and Rating Pvt
757
Guidance Note on Audit of Banks (Revised 2019)
Ltd. (INFOMERICS)
41 June 7, Section 24 and Section RBI/2016-2017/318
2017 56 of the Banking DBR.No.Ret.BC.71/12.02.0
Regulation Act, 1949 - 01/2016-17
Maintenance of Statutory
Liquidity Ratio (SLR)
42 June 7, Individual Housing Loans: RBI/2016-2017/317
2017 Rationalisation of Risk- DBR.BP.BC.No.72/08.12.01
Weights and Loan to 5/2016-17
Value (LTV) Ratios
43 May 30, Submission of Annual RBI/2016-2017/313
2017 Information Return IDMD.CDD.No.3058/13.01.
relating to issue of Bonds 299/2016-17
for 5 lakh or more
under Section 285 BA of
Income Tax Act, 1961 -
Change thereof
44 May 25, Submission of Annual RBI/2016-2017/309
2017 Information Return IDMD.CDD.No.3031/13.01.
relating to issue of Bonds 299/2016-17
for 5 lakh or more
under Section 285 BA of
Income Tax Act, 1961-
Change thereof
45 May 25, Continuation of Interest RBI/2016-2017/308
2017 Subvention Scheme for FIDD.CO.FSD.BC.No.29/05
short-term crop loans on .02.001/2016-17
interim basis during the
year 2017-18- regarding
46 May 8, National Electronic Funds RBI/2016-2017/300
2017 Transfer (NEFT) system DPSS (CO) EPPD
Settlement at half-hourly No.2612/04.03.01/2016-17
intervals
47 May 5, Timelines for Stressed RBI/2016-2017/299
2017 Assets Resolution DBR.BP.BC.No.67/21.04.04
8/2016-17
48 April 27, Risk Management RBI/2016-2017/294
2017 Systems Role of the DBR.BP.BC.No.65/21.04.10
Chief Risk Officer (CRO) 3/2016-17
49 April 20, Exclusion of KBC Bank RBI/2016-2017/288
2017 N.V. from the Second DBR.No.Ret.BC.24/12.07.1
758
List of Relevant General Circulars
Schedule to the Reserve 18A/2016-17
Bank of India Act, 1934
50 April 20, Alteration in the name of RBI/2016-2017/287
2017 "Coöperatieve Centrale Ref.DBR.No.Ret.BC/21/12.0
Raiffeisen - 7.131A/2016-17
Boerenleenbank B.A." to
"Coöperatieve Rabobank
U.A." in the Second
Schedule to the Reserve
Bank of India Act, 1934
51 April 20, Cessation of KBC Bank RBI/2016-2017/286
2017 N.V. as a banking DBR.No.Ret.BC.23/12.07.1
company within the 18A/2016-17
meaning of sub-section
(2) of Section 36(A) of the
Banking Regulation Act,
1949
52 April 20, Alteration in the name of RBI/2016-2017/285
2017 "Abu Dhabi Commercial DBR.No.Ret.BC/22/12.07.0
Bank Limited" to "Abu 53A/2016-17
Dhabi Commercial Bank
PJSC" in the Second
Schedule to the Reserve
Bank of India Act, 1934
53 April 20, Compliance with Ghosh RBI/2016-2017/284
2017 Committee Ref.
Recommendations DBS.CO.PPD.BC.No.9/11.0
1.005/2016-17
54 April 18, Disclosure in the "Notes RBI/2016-2017/283
2017 to Accounts" to the DBR.BP.BC.No.63/21.04.01
Financial Statements- 8/2016-17
Divergence in the asset
classification and
provisioning
55 April 18, Additional Provisions For RBI/2016-2017/282
2017 Standard Advances At DBR.No.BP.BC.64/21.04.04
Higher Than The 8/2016-17
Prescribed Rates
56 April 18, Guidelines on compliance RBI/2016-2017/281
2017 with Accounting Standard DBR.BP.BC.No.61/21.04.01
(AS) 11 [The Effects of 8/2016-17
Changes in Foreign
759
Guidance Note on Audit of Banks (Revised 2019)
Exchange Rates] by
banks - Clarification
57 April 18, Prudential Guidelines RBI/2016-2017/280
2017 Banks' investment in DBR.No.FSD.BC.62/24.01.0
units of REITs and InvITs 40/2016-17
58 April 13, Grant of `Certificate of RBI/2016-2017/277
2017 Registration' For DBR.CID.BC.
carrying on the business 60/20.16.040/2016-17
of credit information
Transunion CIBIL Limited
59 April 13, Revised Prompt RBI/2016-2017/276
2017 Corrective Action (PCA) DBS.CO.PPD.BC.No.8/11.0
Framework for Banks 1.005/2016-17
60 April 10, Setting up of IFSC RBI/2016-2017/273
2017 Banking Units (IBUs) DBR.IBD.BC.59/23.13.004/
Permissible activities 2016-17
61 April 6, Change in Bank Rate RBI/2016-2017/270
2017 DBR.No.Ret.BC.58/12.01.0
01/2016-17
62 April 6, Marginal Standing Facility RBI/2016-2017/269
2017 FMOD.MAOG.No.119/01.18
.001/2016-17
63 April 6, Liquidity Adjustment RBI/2016-2017/268
2017 Facility Repo and FMOD.MAOG. No. 118
Reverse Repo Rates /01.01.001/2016-17
64 April 6, Interest rates for Small RBI/2016-2017/267
2017 Savings Schemes DGBA.GAD.2618/15.02.005
/2016-17
65 March 29, All payment systems to RBI/2016-2017/260
2017 remain closed on April 1, DPSS.CO.CHD.No./2720/0
2017 3.01.03/2016-17
66 March 25, Payment systems to RBI/2016-2017/257
2017 remain open on all days DPSS.CO.CHD.No./2695/0
from March 25, 2017 to 3.01.03/2016-17
April 1, 2017
67 March 16, Pradhan Mantri Garib RBI/2016-2017/251
2017 Kalyan Deposit Scheme IDMD.CDD.No.2347/14.04.
(PMGKDS), 2016 - 051/2016-17
Clarification
68 March 9, Inclusion of "The Royal RBI/2016-2017/244
2017 Bank of Scotland plc" in DBR.No.Ret.BC.54/12.07.1
760
List of Relevant General Circulars
the Second Schedule to 50/2016-17
the Reserve Bank of India
Act, 1934
69 March 2, Financial Literacy by RBI/2016-2017/236
2017 FLCs (Financial Literacy FIDD.FLC.BC.No.22/12.01.
Centres) and rural 018/2016-17
branches - Policy Review
70 February Forward Rate Agreement RBI/2016-2017/232
16, 2017 (FRA) and Interest Rate FMRD.DIRD.13/14.01.019/2
Swap (IRS) - Withdrawal 016-17
of Fortnightly return
71 February Inclusion of "Capital Small RBI/2016-2017/231
16, 2017 Finance Bank Limited" in DBR.No.Ret.BC.51/12.07.1
the Second Schedule to 45A/2016-17
the Reserve Bank of India
Act, 1934
72 February Inclusion of "Equitas RBI/2016-2017/230
16, 2017 Small Finance Bank DBR.No.Ret.BC.52/12.07.1
Limited" in the Second 43A/2016-17
Schedule to the Reserve
Bank of India Act, 1934
73 February 9, Interest rates for Small RBI/2016-2017/225
2017 Savings Schemes DGBA.GAD.2012/15.02.005
/2016-17
74 February 2, Basel III Capital RBI/2016-2017/222
2017 Regulations- Additional DBR.BP.BC.No.50/21.06.20
Tier 1 Capital 1/2016-17
75 December Facility for exchange of RBI/2016-17/205 DCM (Plg)
31, 2016 Specified Bank Notes No.2170 /10.27.00/2016-17
(SBNs) during Grace
Period Verification of
KYC and Account details
76 December Cash withdrawal from RBI/2016-17/204
30, 2016 ATMs Enhancement of DCM (Plg) No.
daily limits 2142/10.27.00/2016-17
77 December Closure of the scheme of RBI/2016-17/201 DCM (Plg)
30, 2016 exchange of Specified No.2103/10.27.00/2016-17
Bank Notes (SBNs) at
banks on December 30th
2016- Accounting
761
Guidance Note on Audit of Banks (Revised 2019)
78 December Sanction of Additional RBI/2016-17/200
29, 2016 Working Capital Limits to FIDD.MSME &
Micro and Small NFS.BC.No.20/06.02.31/20
Enterprises (MSEs) 16-17
79 December Prudential Norms on RBI/2016-17/198
28, 2016 Income Recognition, DBR.No.BP.BC.49/21.04.04
Asset Classification and 8/2016-17
Provisioning pertaining to
Advances
80 December Master Circular on RBI/2016-17/196
27, 2016 Issuance and Operations DPSS.CO.PD.No.1610/02.1
of Prepaid Payment 4.006/2016-17
Instruments
Amendments to
paragraph 7.9
81 December Withdrawal of Legal RBI/2016-17/191 DCM (Plg)
21, 2016 Tender Character of No. 1911/10.27.00/2016-17
existing 500/- and
1000/- Bank Notes
(Specified Bank Notes) -
Deposit of Specified Bank
Notes (SBNs) into bank
accounts- Modification
82 December Withdrawal of Legal RBI/2016-17/189 DCM (Plg)
19, 2016 Tender Character of No. 1859/10.27.00/2016-17
existing 500/- and
1000/- Bank Notes
(Specified Bank Notes) -
Deposit of Specified Bank
Notes (SBNs) into bank
accounts
83 December Pradhan Mantri Garib RBI/2016-17/188
16, 2016 Kalyan Deposit Scheme IDMD.CDD.No.1454/14.04.
(PMGKDS), 2016 - 050/2016-17
Operational Guidelines
84 December Pradhan Mantri Garib RBI/2016-17/187
16, 2016 Kalyan Deposit Scheme IDMD.CDD.No.1453/14.04.
(PMGKDS), 2016 050/2016-17
85 December Compliance to provisions RBI/2016-17/183
15, 2016 of Master Direction on DBR.AML.BC.48/14.01.01/2
Know Your Customer 016-17
(KYC)
762
List of Relevant General Circulars
86 December Detection of counterfeit RBI/2016-17/179
12, 2016 notes in Specified Bank DCM (Plg) No.
Notes (SBNs) - Reporting 1679/10.27.00/2016-17
87 December Security and Risk DPSS.CO.OSD.No.1485/06
09, 2016 Mitigation measure - .08.005/2016-17
Technical Audit of
Prepaid Payment
Instrument issuers
88 December Financing of DBR.BP.BC.No.42/08.12.01
01, 2016 Infrastructure `Definition 4/2016-17
of 'Infrastructure Lending'
89 December Information from RBI/2016-17/166
01, 2016 Unauthenticated Sources DCM (Plg)
Advisory to banks No.1500/10.27.00/2016-17
90 November Deposit of Specified Bank RBI/2016-17/164DCM (Plg)
29, 2016 Notes (SBNs) Chest No. 1459/10.27.00/2016-17
Balance Limit / Cash
Holding Limit
91 November Accounts under PMJDY - RBI/2016-17/165
29, 2016 Precautions DCM (Plg) No.
1450/10.27.00/2016-17
92 November Chest Guarantee RBI/2016-17/162 DCM (Plg)
28, 2016 Scheme for Specified No.1438/10.27.00/2016-17
Bank Notes (SBNs)
CGSS
93 November Withdrawal of cash from RBI/2016-17/163 DCM
28, 2016 bank deposit accounts - No.1437/10.27.00/2016-17
Relaxation
94 November Chest Guarantee RBI/2016-17/160 DCM (Plg)
27, 2016 Scheme for Specified No. 1430/10.27.00/2016-17
Bank Notes (SBNs) -
CGSS
95 November Reserve Bank of India RBI/2016-17/159
26, 2016 Act, 1934 Section DBR.No.Ret.BC.41/12.01.0
42(1A) Requirement for 01/2016-1
maintaining additional
CRR
96 November Withdrawal of cash RBI/2016-17/158 DCM (Plg)
25, 2016 Weekly limit No. 1424/10.27.00/2016-17
97 November Specified Bank Notes RBI/2016-17/153 DCM (Plg)
(SBNs) - Deposit under No.1383/10.27.00/2016-17
763
Guidance Note on Audit of Banks (Revised 2019)
24, 2016 Guarantee Scheme to
decongest the storage
facilities at banks
98 November Special knowledge or DBR.Appt.BC.No.39/29.39.
24, 2016 practical experience 001/2016-17
useful to banking
companies
99 November Withdrawal of Legal RBI/2016-17/146
21, 2016 Tender Character of DCM (Plg)
existing 500/- and No.1323/10.27.00/2016-17
1000/- Bank Notes
Revisions
100 November Withdrawal of Legal RBI/2016-17/142
21, 2016 Tender Character of DCM (Plg)
Specified Bank Notes No.1317/10.27.00/2016-17
Cash Withdrawal Limit
101 November Withdrawal of Legal RBI/2016-2017/145 DCM
21, 2016 Tender Character of (Plg)
existing 500/- and No.1320/10.27.00/2016-17
1000/- Specified Bank
Notes (SBNs) Cash
withdrawal for purpose of
celebration of wedding
102 November Prudential Norms on RBI/2016-17/143
21, 2016 Income Recognition, DBR.No.BP.BC.37/21.04.04
Asset Classification and 8/2016-17
Provisioning pertaining to
Advances
103 November Withdrawal of Legal RBI/2016-17/139 DCM (Plg)
17, 2016 Tender Character of No.1302/10.27.00/2016-17
existing 500/- and 1000/-
Bank Notes Exchange
over the counters
104 November Standard Operating RBI/2016-17/133
15, 2016 Procedure (SOP) for DCM (Plg)
putting indelible ink on No.1280/10.27.00/2016-17
the finger of the
customers coming to a
bank branch for SBNs
105 November Withdrawal of Legal RBI/2016-17/130 DCM (Plg)
14, 2016 Tender Character of No.1273/10.27.00/2016-17
764
List of Relevant General Circulars
existing 500/- and 1000/-
Bank Notes Applicability
of the Scheme to DCCBs
106 November Withdrawal of Legal RBI/2016-17/129 DCM (Plg)
13, 2016 Tender Character of No.1272 /10.27.00/2016-17
existing 500/- and
1000/- Bank Notes
Revision in limits
107 November Repo / Reverse Repo FMOD.MAOG.No.116/01.01
10, 2016 Transactions with RBI .001/2016-17
108 November Schemes for Stressed DBR.No.BP.BC.34/21.04.13
10, 2016 Assets - Revisions 2/2016-17
109 November Scheme for Sustainable DBR.No.BP.BC.33/21.04.13
10, 2016 Structuring of Stressed 2/2016-17
Assets - Revisions
110 November Withdrawal of Legal RBI/2016-17/112 DCM (Plg)
08, 2016 Tender Character of No.1226/10.27.00/2016-17
existing ` 500/- and `
1000/- Bank Notes
111 October 13, Section 24 and Section DBR.No.Ret.BC.15/12.02.0
2016 56 of the Banking 01/2016-17
Regulation Act, 1949 -
Maintenance of Statutory
Liquidity Ratio (SLR)
112 October 4, Liquidity Adjustment FMOD.MAOG.No.114/01.01
2016 Facility Repo and .001/2016-17
Reverse Repo Rates
113 September Priority Sector Lending - FIDD.CO.Plan.BC.14/
1, 2016 Targets and 04.09.01/2016-17
Classification: Lending to
non-corporate farmers
System wide average of
last three years
114 August 25, Risk- based Internal Audit DBS.CO.PPD.05/11.01.005/
2016 2016-17
115 August 25, Review of Prudential DBR.No.BP.BC.6/21.06.001
2016 Norms Risk Weights for /2016-17
Exposures to Corporates,
AFCs and NBFC-IFCs
116 August 4, Dishonour of cheques DBR.No.Leg.BC.3/09.07.00
765
Guidance Note on Audit of Banks (Revised 2019)
2016 Modification in procedure 5/2016-17
117 July 28, Priority Sector Lending FIDD.CO.Plan.BC.No.8/04.
2016 Targets and 09.001/2016-17
Classification- Bank loans
to MFIs for onlending -
Qualifying asset -
Revised loan limit
118 July 21, Basel III Framework on DBR.
2016 Liquidity Standards BP.BC.No.2/21.04.098/2016
Liquidity Coverage Ratio -17
(LCR), Liquidity Risk
Monitoring Tools and
LCR Disclosure
Standards
119 June 30, Performance Audit of FIDD.No.FSD.BC.28/05.10.
2016 Crop Insurance Schemes 007/2015-16
120 June 23, Implementation of Indian DBR.BP.BC.No.106/21.07.0
2016 Accounting Standards 01/2015-16
(Ind AS)
121 June 23, Reporting Requirements DBR.BP.BC.No.105/21.06.0
2016 under Basel III Capital 01/2015-16
Regulations- Review
122 June 2, Cyber SecurityRBI/2015-16/418
2016 Framework in Banks DBS.CO/CSITE/BC.11/33.0
1.001/2015-16
123 May 19, Repo / Reverse Repo FMRD.DIRD. 10
2016 Transactions with RBI /14.03.002/2015-16
124 May 5, Discontinuation of FIDD. No. FSD.
2016 Statements on Special BC.24/05.05.014/2015-16
Agriculture Credit Plan
(SACP)
125 April 28, Compliance with Jilani Ref.DBS.CO.PPD.BC.No.10
2016 Committee /11.01.005/2015-16
Recommendations
126 April 28, F-TRAC Counterparty FMRD.FMID.8/14.01.02/201
2016 Confirmation 5-16
127 April 21, Guidelines on Investment DBR.No.FSD.BC.94/24.01.0
2016 Advisory Services offered 26/2015-16
by Banks
766
List of Relevant General Circulars
128 April 18, Provisioning pertaining to DBR.No.BP.BC.92/21.04.04
2016 Fraud Accounts 8/2015-16
129 April 7, Revision of interest rates DGBA.GAD.3175/15.02.005
2016 for Small Savings /2015-16
Schemes
130 April 7, Priority Sector Lending FIDD.CO.Plan.BC.23/
2016 Certificates 04.09.01/2015-16
131 April 5, Liquidity Adjustment FMOD.MAOG. No. 112
2016 Facility Repo and /01.01.001/2015-16
Reverse Repo Rates
132 April 5, Marginal Standing Facility FMOD.MAOG. No.113
2016 /01.18.001/2015-16
133 March 31, Risk Based Supervision DBS.CO.PPD.10887/11.01.
2016 Follow up of Risk 005/2015-16
Management Systems in
Banks
134 March 31, Gold Monetisation DBR.IBD.BC.89/23.67.001/
2016 Scheme, 2015 2015-16
135 March 23, Liquidity Risk DBR.BP.BC.No.86/21.04.09
2016 Management & Basel III 8/2015-16
Framework on Liquidity
Standards Liquidity
Coverage Ratio (LCR),
Liquidity Risk Monitoring
Tools and LCR
Disclosure Standards
136 March 17, Framework for Revival FIDD.MSME &
2016 and Rehabilitation of NFS.BC.No.21/06.02.31/20
Micro, Small and Medium 15-16
Enterprises (MSMEs)
137 March 17, Pradhan Mantri Fasal FIDD. No. FSD.
2016 Bima Yojana BC.20/05.10.007/2015-16
138 March 01, Master Circular Basel III DBR.No.BP.BC.83/21.06.20
2016 Capital Regulations - 1/2015-16
Revision
139 February Basel III Framework on DBR. BP. BC. No.
11, 2016 Liquidity Standards 77/21.04.098/2015-16
Liquidity Coverage Ratio
(LCR), Liquidity Risk
767
Guidance Note on Audit of Banks (Revised 2019)
Monitoring Tools and
LCR Disclosure
Standards
140 February Implementation of Indian DBR.BP.BC.No.76/21.07.00
11, 2016 Accounting Standards 1/2015-16
(Ind AS)
141 January 21, Fraud Reporting and DBS.CO.CFMC.BC.No.007/
2016 Monitoring 23.04.001/2015-16
142 January 14, Credit information DBR.CID.BC.No.73/20.16.5
2016 reporting in respect of 6/2015-16
Self Help Group (SHG)
members
143 January 14, Master Circular Basel III DBR.No.BP.BC.71/21.06.20
2016 Capital Regulations - 1/2015-16
Clarification
144 January 07, Non-Fund Based Facility DBR.Dir.BC.No.70/13.03.00
2016 to Non-constituent /2015-16
Borrowers of Bank
145 December Extension of Credit DBR.IBD.BC.No.68/23.37.0
31, 2015 Facilities to Overseas 01/2015-16
Step-down Subsidiaries
of Indian Corporates
146 December Fourth Bi-monthly DBR.No.BP.BC.65
10, 2015 Monetary Policy /21.04.141/2015-16
Statement, 2015-16
SLR Holdings under Held
to Maturity Category
147 December Interest Equalisation DBR.Dir.BC.No.62/04.02.00
4, 2015 Scheme on Pre and Post 1/2015-16
Shipment Rupee Export
Credit
148 November Central KYC Records DBR.AML.BC.No.60/14.01.
26, 2015 Registry (CKYCR) - 001/2015-16
template for Know Your
Customer (KYC) and
reporting requirements
under Foreign Account
Tax Compliance Act
(FATCA)/ Common
Reporting Standards
768
List of Relevant General Circulars
(CRS)
149 November Bank Finance to DBR.BP.BC.No.55/21.04.17
26, 2015 Factoring Companies 2/2015-16
150 November Non-Operative Financial DBR.No.BP.BC.57/21.06.20
19, 2015 Holding Company 1/2015-16
(NOFHC) Application of
Capital Adequacy Norms
151 November Provision of Factoring DBR.No.FSD.BC.
19, 2015 Services by Banks 58/24.01.007/2015-16
Review
152 November Priority Sector Lending FIDD.CO.Plan.BC.13/
18, 2015 Targets and Classification 04.09.01/2015-16
153 November Sovereign Gold Bonds, IDMD.CDD.No.
4, 2015 2015-16 - Operational 968/14.04.050/2015-16
Guidelines
154 November Gold Monetisation DBR.IBD.BC.52/23.67.003/
3, 2015 Scheme, 2015- 2015-16
Amendment
155 November Gold Monetisation DBR.IBD.BC.53/23.67.003/
3, 2015 Scheme, 2015- Interest 2015-16
Rate
156 October 22, Gold Monetisation DBR.IBD.No.45/23.67.003/2
2015 Scheme, 2015 015-16
157 October 15, Financial Inclusion Fund DCBR.RCBD.BPD.No.4/19.
2015 (FIF)- Revised Guidelines 51.010/2015-16
158 October 8, Individual Housing Loans: DBR.BP.BC.No. 44
2015 Rationalisation of Risk- /08.12.015/ 2015-16
Weights and LTV Ratios
159 October 8, Risk Weights for Claims DBR.BP.BC.No.43/21.06.00
2015 on Foreign Central Banks 1/2015-16
160 September Prudential Norms on DBR.BP.BC.No.41/21.04.04
24, 2015 Change in Ownership of 8/2015-16
Borrowing Entities
(Outside Strategic Debt
Restructuring Scheme)
161 September Constitution of the Audit DBS.ARS.BC 4 /
24, 2015 Committee of the Board 08.91.020/2015-16
769
Guidance Note on Audit of Banks (Revised 2019)
162 September Framework for DBR.BP.BC.No.39/21.04.13
24, 2015 Revitalising Distressed 2/2015-16
Assets in the Economy
Review of the Guidelines
on Joint Lenders' Forum
(JLF) and Corrective
Action Plan (CAP)
163 September Half yearly/Quarterly DBS. ARS.No. BC.
23, 2015 Review of Accounts of 5/08.91.001/2015-16
Public Sector Banks
164 September Guidelines on DBR.Dir.BC.No.38/13.03.00
16, 2015 Compensation of Chief /2015-16
Executive Officer/ Whole
Time Directors
Restrictions under
Section 20 of the Banking
Regulation Act, 1949
Loans to Directors
165 September Equity Investment by DBR.No.FSD.BC.37/24.01.0
16, 2015 Banks Review 01/2015-16
166 August 28, Reporting requirement DBR.AML.BC.No.36/14.01.
2015 under Foreign Account 001/2015-16
Tax Compliance Act
(FATCA) and Common
Reporting Standards
(CRS)
167 August 27, Security and Risk DPSS.CO.PD.No.448/02.14
2015 Mitigation Measures for .003/2015-16
Card Present and
Electronic Payment
Transactions Issuance
of EMV Chip and PIN
Cards
168 August 21, Guidelines for relief FIDD No.
2015 measures by banks in FSD.BC.12/05.10.001/2015-
areas affected by natural 16
calamities
169 August 13, Union Budget - 2015-16 FIDD.No.FSD.BC.
2015 Interest Subvention 59/05.04.02/2015-16
770
List of Relevant General Circulars
Scheme
170 July 16, Concurrent Audit System DBS.CO.ARS.No. BC.
2015 in Commercial Banks - 2/08.91.021/2015-16
Revision of RBI's
Guidelines
171 July 16, Priority Sector Lending FIDD.CO.Plan.BC.08/04.09.
2015 Targets and Classification 01/2015-16
172 June 8, Strategic Debt DBR.BP.BC.No.101/21.04.1
2015 Restructuring Scheme 32/2014-15
173 June 4, Submission of Long Form DBS.CO.ARS.BC.8/08.91.0
2015 Audit Report (LFAR) by 01/2014-15
Concurrent Auditors
174 May 7, Framework for dealing DBS.CO.CFMC.BC.No.007/
2015 with loan frauds 23.04.001/2014-15
175 March 11, Guidelines on Managing RBI/2014-15/497
2015 Risks and Code of DBR.No.BP.BC.76/21.04.15
Conduct in Outsourcing 8/2014-15
of Financial Services by
Banks
176 February Ready Forward Contracts FMRD.DIRD.04/14.03.002/2
03, 2015 in Corporate Debt 014-15
Securities
177 December Flexible Structuring of DBR.No.BP.BC.53/21.04.13
15, 2014 Existing Long Term 2/2014-15
Project Loans to
Infrastructure and Core
Industries
178 December Mobile Banking DPSS.CO.PD.No.1017 /
04, 2014 Transactions in India - 02.23.001 / 2014-2015
Operative Guidelines for
Banks
179 October 21, Framework for DBOD.BP.BC.No.45/21.04.
2014 Revitalising Distressed 132/2014-15
Assets in the Economy
Review of the Guidelines
on Joint Lenders' Forum
(JLF) and Corrective
Action Plan (CAP)
771
Guidance Note on Audit of Banks (Revised 2019)
180 October 16, Revisions to Basel II- DBOD.No.BP.BC.43/21.06.
2014 Advanced Approaches of 017/2014-15
Operational Risk-TSA
and AMA
181 October 7, Fourth Bi-monthly DBOD.No.BP.BC.42/21.04.
2014 Monetary Policy 141/2014-15
Statement, 2014-15
SLR Holdings under Held
to Maturity Category
182 September Calculation of Drawing C&I/Circular/2014-15/689
29, 2014 power in consortium issued by Indian Bank
accounts including Association
CDR/bilaterally
restructured Account
183 August 14, Prudential Norms on DBOD.No.BP.BC.33/21.04.
2014 Income Recognition, 048/2014-15
Assets Classification and
Provisioning Pertaining to
Advances Project under
Implementation
184 July 22, Loans against Gold DBOD.No.BP.BC.27/21.04.
2014 Ornaments and Jewellery 048 /2014-15
for Non-Agricultural End-
uses
185 July 15, Flexible Structuring of DBOD.No.BP.BC.24/21.04.
2014 Long Term Project Loans 132/2014-15
to Infrastructure and Core
Industries
186 June 9, Basel III Framework on DBOD.BP.BC.No.120 /
2014 Liquidity Standards 21.04.098/2013-14
Liquidity Coverage Ratio
(LCR), Liquidity Risk
Monitoring Tools and
LCR Disclosure
Standards
187 June 3, Capital and Provisioning DBOD.No.BP.BC.116/21.06
2014 Requirements for .200/2013-14
772
List of Relevant General Circulars
Exposures to entities with
Unhedged Foreign
Currency Exposure-
Clarifications
188 March 21, The Depositor Education DBOD. No. DEAF Cell. BC.
2014 and Awareness Fund No. 101/ 30.01.002/2013-14
Scheme, 2014 - Section
26A of Banking
Regulation Act, 1949
189 February Framework for DBOD.BP.BC.No.97/
26, 2014 Revitalising Distressed 21.04.132 / 2013-14
Assets in the Economy
Guidelines on Joint
Lenders' Forum (JLF) and
Corrective Action Plan
(CAP)
190 February Guidelines on DBOD.No.BP.BC.96/21.06.
11, 2014 Management of Intra- 102/2013-14
Group Transactions and
Exposures
191 February 7, Utilisation of Floating DBOD.No.BP.95/21.04.048/
2014 Provisions/Counter 2013-14
Cyclical Provisioning
Buffer
192 January 20, Lending against Gold DBOD.BP.BC.No.86
2014 Jewellery /21.01.023 /2013-14
193 January 15, Capital and Provisioning DBOD.No.BP.BC. 85
2014 Requirements for /21.06.200/2013-14
Exposures to entities with
Unhedged Foreign
Currency Exposure
194 December Non-Agriculture Loans DBOD.No.BP.79/21.04.048/
30, 2013 against Gold Ornaments 2013-14
and Jewellery
195 December Deferred Tax Liability on DBOD.
20, 2013 Special Reserve created No.BP.BC.77/21.04.018/201
under Section 36(1) (viii) 3-14
of the Income Tax Act,
1961
773
Guidance Note on Audit of Banks (Revised 2019)
196 December Novation of OTC DBOD.No.BP.BC.76/21.04.
9, 2013 Derivative Contracts 157/2013-14
197 November Financing of DBOD.BP.BC.No.66 /
25, 2013 Infrastructure - Definition 08.12.014 / 2013-14
of 'Infrastructure Lending'
198 October 23, Amendments to Banking DBOD.NO.PSBD.BC.62/16.
2013 Regulation Act 1949 -- 13.100/ 2013-14
Banking Laws
(Amendment) Act 2012 -
Applicability to private
sector banks
199 September Export Credit in Foreign DBOD.Dir.BC.No. 57
25, 2013 Currency /04.02.001/2013-14
200 September Section 42(1) of the DBOD.No.Ret.BC.55
20, 2013 Reserve Bank of India /12.01.001/2013-14
Act, 1934 - Change in
Daily Minimum Cash
Reserve Maintenance
Requirement
201 September Housing Sector: DBOD.BP.BC.No. 51
3, 2013 Innovative Housing Loan /08.12.015/2013-14
Products Upfront
disbursal of housing
loans
202 September Base Rate Revised DBOD. No. Dir. BC.
2 , 2013 Guidelines 47/13.03.00/ 2013-14
203 August 26, Rupee Export Credit - DBOD.Dir.BC.No.43
2013 Interest Subvention /04.02.001/2013-14
204 August 23, Investment portfolio of DBOD.BP.BC.No. 41 /
2013 banks Classification, 21.04.141 /2013-14
Valuation and
Provisioning
205 February Security and Risk DPSS (CO) PD
28, 2013 Mitigation Measures for No.1462/02.14.003 / 2012-
Electronic Payment 13
Tractions
206 January 31, Disclosure Requirements DBOD.BP.BC.No.80/21.04.
2013 on Advances 132/2012-13
774
List of Relevant General Circulars
Restructured by Banks
and Financial Institutions
207 November Review of the Prudential DBOD.No.BP.BC.63/21.04.
26, 2012 Guidelines on 048/2012-13
Restructuring of
Advances by
Banks/Financial
Institutions
208 October 12, Reporting Platform for FMD.MSRG.No.72/02.05.00
2012 OTC Foreign Exchange 2/2012-13
and Interest Rate
Derivatives
209 September The Scheme of 1% RPCD.MSME&NFS.BC.No.
18, 2012 Interest Subvention on 30 /06.11.01/2012-13
Housing Loans up to Rs.
15.00 lakh
210 July 23, Prudential Norms for Off- DBOD.No.BP.BC.31
2012 balance Sheet Exposures /21.04.157/2012-13
of Banks
211 May 07, Revisions to the DBOD.No.BP.BC-
2012 Guidelines on 103/21.04.177/2011-12
Securitisation
Transactions
212 May 2, Guidelines on DBOD.No.BP.BC.98
2012 Implementation of Basel /21.06.201/2011-12
III Capital Regulations in
India
213 March 9, Reporting Platform for FMD.MSRG.No.67/02.05.00
2012 OTC Foreign Exchange 2/2011-12
and Interest Rate
Derivatives
214 January 25, Deregulation of Savings DBOD.Dir.BC.
2012 Bank Deposit Interest 75/13.03.00/2011-12
Rate Guidelines
215 December Deregulation of Interest DBOD.Dir.BC. 64
16, 2011 Rates on Non-Resident /13.03.00/2011-12
(External) Rupee (NRE)
Deposits and Ordinary
775
Guidance Note on Audit of Banks (Revised 2019)
Non-Resident (NRO)
Accounts
216 November Prudential Guidelines on DBOD.BP.BC.No.61/21.06.
30, 2011 Credit Default Swaps 203/201112
(CDS)
217 November Comprehensive DBOD.No.BP.BC. 44
2, 2011 Guidelines on /21.04.157/2011-12
Derivatives: Modifications
218 October 25, Deregulation of Savings DBOD.Dir.BC. 42
2011 Bank Deposit Interest /13.03.00/2011-12
Rate - Guidelines
219 August 11, Prudential Norms for Off- DBOD.No.BP.BC. 28 /
2011 balance Sheet Exposures 21.04.157 / 2011-12
of Banks
220 August 2, Comprehensive DBOD.No.BP.BC. 27 /
2011 Guidelines on 21.04.157 / 2011-12
Derivatives: Modifications
221 May 31, Findings of Forensic DBS.
2011 Scrutiny- Guidelines for CO.FrMC.BC.No.10/23.04.0
prevention of frauds _ 01/2010-11
222 May 9, Section 24 of the Banking Ref. DBOD No. Ret. BC. 92
2011 Regulation Act, 1949- /12.02.001/2010-11
Maintenance of Statutory
Liquidity Ratio (SLR)
223 May 4, Mobile Banking DPSS.CO.No.2502
2011 Transactions in India - /02.23.02/ 2010-11
Operative Guidelines for
Banks
224 April 29, Working Group on DBS.CO.ITC.BC.No.6/31.02
2011 Information Security, .008/2010-11
Electronic Banking,
Technology Risk
Management and Cyber
Fraud Implementation
of Recommendations
225 April 27, Implementation of the DBOD.No.BP.BC. 88
776
List of Relevant General Circulars
2011 Advanced Measurement /21.06.014/2010-11
Approach (AMA) for
Calculation of Capital
Charge for Operational
Risk
226 February Guidelines on Base Rate DBOD.Dir.BC. 81
21, 2011 /13.03.00/2010-11
227 February 9, Re-opening of pension DBOD.No. BP.BC.80/
2011 option to employees of 21.04.018/2010-11
Public Sector Banks and
enhancement in gratuity
limits - Prudential
Regulatory Treatment
228 February 2, Classification of loans RPCD.CO.Plan.BC. 51
2011 against gold jewellery /04.09.01/2010-11
229 January 20, Regulatory Capital DBOD.BP.BC.No.75/21.06.
2011 Instruments Step up 001/201011
option
230 January 14, End use of funds DBS.CO.PPD.BC.No. 5
2011 Monitoring /11.01.005/2010-11
231 January 6, Guidelines on the Base DBOD.No.Dir.BC. 73
2011 Rate /13.03.00/2010-11
232 December Know Your Customer DBOD. AML. BC. No.70/14
30, 2010 (KYC) norms / Anti- .01.001/2010-11
Money Laundering (AML)
standards/ Combating of
Financing of Terrorism
(CFT)/Obligation of banks
under PMLA, 2002
233 December Directions for opening RBI/2010-11/339
28, 2010 and operation of DPSS.CO.OSD. No.
Accounts and settlement 1448/06.08.001/ 2010-2011
of payment for electronic
payment transactions
involving intermediaries
234 December Issuance and operation of RBI/2010-11/341
27, 2010 Prepaid Payment DPSS.CO.OSD. No. 1445
Instruments in India /06.12.001/ 2010-2011
Auditor Certificate on the
777
Guidance Note on Audit of Banks (Revised 2019)
balances in Escrow
account
235 December Directions for submission RBI/2010-11/340
27, 2010 of system audit reports DPSS.CO.OSD. No. 1444
from CISA qualified /06.11.001/ 2010-2011
Auditor
236 December Housing Loans by DBOD.No.BP.BC. 69
23, 2010 Commercial Banks LTV /08.12.001/2010-11
Ratio, Risk Weight and
Provisioning
237 December Swarna jayanti Gram RPCD.GSSD.BC.No.30
15, 2010 Swarozgar Yojana /09.01.01/2010 -11
(SGSY) - Group Life
Insurance Scheme
238 December Operation of bank DBOD. AML. BC. No. 65/14
7, 2010 accounts & money mules .01.001/2010-11
239 November Guidelines on Fair DBOD. Leg. BC. 61
12, 2010 Practices Code for /09.07.005/2010 -11
Lenders Disclosing all
information relating to
processing fees / charges
240 October 28, Introduction of Exchange DBOD.No.BP.BC.51 /
2010 Traded Currency Options 21.06.101 / 2010-11
Permitting Banks to
Participate in Currency
Options on Recognized
Stock / New Exchanges
241 October 7, Prudential Guidelines on DBOD.BP.No.
2010 Restructuring of 49/21.04.132/2010-11
Advances by Banks
242 October 1, Prudential Norms for Off- DBOD.No.BP.BC.48 /
2010 Balance Sheet Exposures 21.06.001/2010-11
of Banks Bilateral
netting of counterparty
credit exposures.
243 September Banks' Exposure to DBOD.Dir.BC.46
30, 2010 Capital Market - Issue of /13.03.00/2010-11
Irrevocable Payment
778
List of Relevant General Circulars
Commitments (IPCs)
244 September Bank loans for financing DBOD.No.BP.BC. 42
27, 2010 promoters contribution /21.04.141/2010-11
245 September Dishonour / Return of DPSS.CO.CHD.No. 485 /
1, 2010 Cheques - Need to 03.06.01 / 2010-11
Mention the 'Date of
Return' in the Cheque
Return Memo
246 July 30, Guidelines on trading of RBI/2010-11/147 A.P. (DIR
2010 Currency Options on Series) Circular No. 05
Recognised Stock / New
Exchanges
247 May 6, Working Group to Review RPCD.SME & NFS. BC.No.
2010 the Credit Guarantee 79 /06.02.31/200910
Scheme for Micro and
Small Enterprises (MSEs)
Collateral free loans to
MSEs
248 April 23, Investment in Unlisted DBOD.No.BP.BC. 98/
2010 Non-SLR Securities 21.04.141/ 2009-10
249 April 20, Conversion of term DBOD. No. Dir. BC.
2010 deposits, daily deposits or 91/13.03.00/2009-2010
recurring deposits for
reinvestment in term
deposits
250 April 12, Collateral Free Loans - RPCD.SME&NFS.BC.No.
2010 Educational Loan 69/06.12.05 /2009-10
Scheme
251 April 9, Guidelines on the Base DBOD. No. Dir. BC 88
2010 Rate /13.03.00/2009-10
252 March 31, Implementation of The DBOD. No. BP.BC. 84
2010 Standardised Approach /21.06.001/2009-10
(TSA) for Calculation of
Capital Charge for
Operational Risk
253 March 30, Classification in the DBOD.BP.BC No.81/
2010 Balance Sheet - Capital 21.01.002/2009-10
779
Guidance Note on Audit of Banks (Revised 2019)
Instruments
254 March 15, Additional Disclosures by DBOD.BP.BC.No.79
2010 banks in Notes to /21.04.018/2009-10
Accounts
255 January 13, Retail Issue of DBOD.BP.BC.No. 69 /
2010 Subordinated Debt for 21.01.002/ 2009-10
Raising Tier II Capital
256 December System Audit of the DPSS.AD.No./
7, 2009 Payment Systems 1206/02.27.005/2009-2010
operated under the PSS
Act, 2007
257 November Directions for opening DPSS.CO.PD.No.1102
24, 2009 and operation of /02.14.08/ 2009-10
Accounts and settlement
of payments for electronic
payment transactions
involving intermediaries
258 September Guidelines on Exchange IDMD.PDRD.No.
1, 2009 Traded Interest Rate 1056/03.64.00/2009-10
Derivatives
259 April 27, Policy Guidelines for DPSS.CO.PD.No. 1873
2009 issuance and operation of /02.14.06/ 2008-09
Prepaid Payment
Instruments in India
260 April 22, Guidelines on Managing Ref. DBS.CO.PPD.BC. 5
2009 Risks and Code of /11.01.005/2008-09
Conduct in Outsourcing
of Financial Services by
Banks Compliance
Certificate
261 February Lending under DBOD.No.
10, 2009 Consortium Arrangement BP.BC.110/08.12.001/2008-
/ Multiple Banking 09
Arrangements
262 December Internal assignments in DBS.ARS. No. BC. 02/
31, 2008 banks by statutory 08.91.001/ 2008-09
auditors
780
List of Relevant General Circulars
263 December Guidelines on Managing DBOD.No.BP. 97
11, 2008 Risks and Code of /21.04.158/2008-09
Conduct in Outsourcing
of Financial Services by
Banks
264 December "Lending under DBOD.No.BP.BC.94
08, 2008 Consortium /08.12.001/2008-09
Arrangement/Multiple
Banking Arrangements
265 December "Operations of foreign DBOD.No.BP.BC.89
1, 2008 branches and /21.04.141/2008-09
subsidiaries of the Indian
banks Compliance with
statutory/regulatory/admin
istrative prohibitions/
restrictions
266 October 13, Prudential Norms for Off- DBOD.No.BP.BC.57/
2008 Balance Sheet Exposures 21.04.157/2008-09
of Banks
267 September Lending under DBOD No. BP. BC.46/
19, 2008 Consortium 08.12.001/2008-09
Arrangement/Multiple
Banking Arrangements
268 August 22, Unclaimed Deposits/in DBOD No. Leg.BC.34/
2008 operative accounts in 09.07.005/2008-09
Banks
269 August 8, Prudential Norms for Off- DBOD.No.BP.BC.31/21.04.
2008 Balance Sheet Exposures 157/2008-09
of Banks
270 April 9, Guidelines on Asset- DBOD.No.BP.BC.68/21.04.
2008 Liability Management 098/2007-08
(ALM) System
271 October 29, Guidelines for issuing DBOD.No. BP. BC. 42
2007 preference shares as part /21.01.002/2007-2008
of regulatory capital
272 October 24, Guidelines on Asset- DBOD. No. BP. BC. 38 /
2007 Liability Management 21.04.098/ 2007-08
(ALM) System
781
Guidance Note on Audit of Banks (Revised 2019)
amendments
273 June 26, Guidance Note on Stress DBOD. No. BP. BC.101 /
2007 Testing 21.04.103/ 2006-07
274 April 20, Comprehensive DBOD.No.BP.BC.
2007 Guidelines on Derivatives 86/21.04.157/2006-07
275 April 20, Compliance Function in DBS.CO.PP.BC.6/11.01.00
2007 Banks 5/2006-07
276 March 6, Prudential Limits for Inter- DBOD.BP.BC.66/
2007 Bank Liabilities (IBL) 21.01.002/2006-07
277 December Cheque Drop Box Facility RPCD.CO.RF.BC.NO./40/0
26, 2006 and the facility for 7.40.06/2006-07
acknowledgement of
cheques.
278 November Guidelines on Managing DBOD.NO.BP. 40/
3, 2006 Risks and Code of 21.04.158/ 2006-07
Conduct in Outsourcing
of Financial Services by
banks
279 September Section 17 (2) of Banking DBOD.BP.BC.31/21.04.018/
20, 2006 Regulation Act, 1949 2006-07
Appropriation from
Reserve Fund
280 April 5, Guidelines on compliance DBOD.BP.BC.No.76/21.04.
2006 with Accounting Standard 018/2005-06
(AS) 11 (revised 2003) -
'The Effects of Changes
in Foreign Exchange
Rates
281 December Donations by banks DBOD. No. Dir. BC. 50/
21, 2005 13.01.01/ 200506
282 March 15, Guidelines on compliance DBOD No.BP.BC.76
2005 with Accounting Standard /21.04.018/2004-05
(AS) 11(revised 2003)
`The Effects of Changes
in Foreign Exchange
Rates'
283 June 26, Risk Based Supervision DBS.CO.PP.BC. 14
2004 Follow up of Risk /11.01.005/2003-04
Management Systems in
Banks
782
List of Relevant General Circulars
284 April 30, Guidelines on compliance DBOD No.BP.BC. 82
2004 with Accounting /21.04.018/2003-04
Standards (AS) by banks
285 April 30, Information System Audit DBS.CO.OSMOS.BC/ 11
2004 - A review of Policies and /33.01.029/2003-04
Practices
286 April 20, Appointment of statutory DBS.ARS.No. B.C. 09
2004 auditors in banks /08.91.001/2003-04
abstention of declaration
of indebtedness
287 June 3, Guidelines on Exchange IDMC. MSRD.
2003 Traded Interest Rate 4801/06.01.03/2002-03
Derivatives
288 March 29, Guidelines on compliance DBOD.No.BP. BC. 89
2003 with Accounting /21.04.018/2002-03
Standards (AS) by banks
289 February Inter-branch Accounts- DBOD.No.BP.BC.73/21.04.
26, 2003 Provisioning for net debit 018/2002-03
balance
290 February Guidelines for DBOD.No.BP.BC.72/21.04.
25, 2003 consolidated accounting 018/2001-02
and other quantitative
methods to facilitate
consolidated supervision
291 October 21, Certification of Borrower's DBOD.No.BP.BC.
2002 Account by Chartered 33/21.04.018/2002-03
Accountants
292 August 24, Reconcilation of Nostro DBOD.BP.BC.16/21.04.018/
2001 Accounts- Old 2001-02
Outstanding Credit
Entries
293 June 14, Internet Banking in India DBOD.COMP.BC.No.130/
2001 Guidelines 07.03.23/ 2000-01
294 July 7, Forward Rate MPD.BC.187/07.01.279/199
1999 Agreements/ Interest 9-2000
Rate Swaps
295 February Asset - Liability DBOD BP.BC.
10, 1999 Management (ALM) 8/21.04.098/99
System
783
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