Audit of Profit and Loss account Bank branch statutory auditors have to certify in their Statutory Audit Report that the Profit and Loss account gives a true and fair view of the Profit or Loss of the branch of the Bank for the year under review. Hence verification of the accuracy of the numbers appearing in the Profit and Loss ensuring there is no material mis-statement is the primary duty of the auditor. Apart from that there is a duty to report in the LFAR as per the questions asked specifically or on any other matters which needs to be brought to the notice of the Central Statutory auditors or the Management in terms of Process or Control inadequacies etc The auditor states in his audit report that he has done his audit in accordance with the Standards of Auditing and hence the auditor has to be duly aware of the various Standards of Auditing more specifically SA 230 Audit Documentation SA 240 Responsibility in relation to Fraud SA 300 Planning an audit of financial statements SA 315 - Identifying and assessing the risk of material mis-statement through u dersta di g of the e tity a d it s e viro e t SA 320 Materiality SA 530 Audit Sampling SA 600 / 610 / 620 Using work of another auditor / expert SA 520 Analytical procedures SA 580 Written representations Auditor will primarily need to verify and ensure the following 1) Numbers appearing under each head in the Profit and Loss account as per the prescribed format are materially accurate 2) Reporting is done under appropriate heads 3) Netting off wherever needs to be done has been done.
4) Prior period or Abnormal items if any are disclosed separately and specifically. 5) Figures of the Current year are in comparison with figures of the previous year and appropriate groupings wherever necessary are done and disclosed. 6) The accounting policies of the Bank have been duly followed while arriving at these numbers. These policies are in sync with the Accounting standards issued by the ICAI. 7) Estimates have been consistently followed over the year. Any change in estimates impacting the numbers materially as compared to the previous year is disclosed appropriately. 8) Contingent Liabilities do not need any provisioning in the accounts. 9) NPA have been correctly identified as any additional identification will impact profitability due to additional provisioning and reversal of income not realized. Security valuation for doubtful accounts is fair resulting in adequate provisioning. 10) Booking of Expense or Income or any provision of any asset or liability appearing at the branch is done in the books of the branch itself and not done at the Regional (RO) or Head Office (HO). Auditor will have to disclose the same appropriately as his Statutory audit report is for the branch only. E.g Depreciation of an asset in books of the branch if provided for at RO or HO level will have to be disclosed appropriately. Similar will be the case for provision of leave encashment benefits etc. 11) No cases of postponement or pre-ponement of any asset, liability, income or expense Cases of ever greening or window dressing Since the Branch finalizes the accounts and submits it onwards for consolidation, any changes will have to be reported through a Memorandum of Change (MOC) only. The auditor has limited time at his disposal as his appointment is usually in the last fortnight of March. He at maximum would get 4 weeks or minimum 2 weeks to complete the entire audit. Hence he needs to carefully plan his audit work to ensure that the Profit and Loss account is correctly stated to give a true and fair view of the profits or losses of the Branch of the Bank.
There could be a risk of lack of detection of material mis-statement of the financial statement with reference to the Profit and Loss and hence the auditor has to be duly aware of the risk and conduct his audit in a manner that the same is detected and the risk of mis-statement is at n acceptable level below threshold considered material. Focus of the audit has to be on processes, risks, materiality, controls, gap analysis and prioritization of mitigating key residual risks. An under or over statement of the assets / liabilities has a corresponding impact on the profit and loss account and thus to a large extent the audit will be comprehensively integrated - The flow of work of a Statutory auditor towards verification of the Profit and Loss account will typically be as under 1) Going through the Guidance Note on audit of Banks 2017 edition & other relevant materials issued by the WIRC / ICAI 2) Obtaining Closing Circulars issued by the Bank 3) Obtaining the Profit or Loss account of the Branch under audit for the year and comparing with the previous year Variances over 20% under any head subject to a materiality threshold fixed for any income or expense head fixed by the auditor to be marked for detailed checking 4) Obtaining the Profit and Loss account for each of the 4 quarters over the year to verify any abnormal deviations under any Income or Expense head in any quarter 5) Testing key ratios as Average Cost of Deposits / Return on Advances and comparing them quarter on quarter or Previous year or with the Bank Average to arrive at a first level divergence for additional checks. 6) Obtaining the accounting policies of the Bank and understanding the same. Ensuring that the policies are in sync with the Accounting standards issued by the ICAI and there is no change in the policies followed vis a vis the previous year. 7) Obtaining the schedule of charges for the year. If there is any revision in charges in the year, there may be more than 1 schedule of charges.
8) Obtaining list of delegated authorities with their financial approval limits for the year if there is any change during the year, then there could be more than 1 list for the year. 9) Obtaining Reports of Revenue Auditors / Concurrent or Internal auditors last year MOC or LFAR to ensure any issues noted which impacted the Profit and Loss account. 10) Discussion with the Branch Head and other officials on the internal process and controls on Income & expense booking that ensures timely, accurate booking under correct heads of Income & Expenditure, process gaps if any are identified and corrected timely so that there is no deviation, divergence. It is the primary duty of the Bank i.e. the Branch to ensure that the Profit and Loss is correctly prepared and gives a True and Fair view. A detailed discussion with Branch Head and other relevant officials on the processes, controls and gaps if any will enable the auditor to primarily ascertain the adequacy of controls over Income and expense Booking and financial reporting so as to draw up his audit program. Based on a review of all the above, auditor will need to draw up his detailed audit program duly incorporating the requirements as per the Standards of Auditing. The main Income for the Bank is Interest on Advances & Interest on Deposits and Salaries constitute the main 3 areas of Profit and Loss and hence the primary duty is to ascertain that these 3 items are absolutely in order and correct. Interest on advances is charged as per the acknowledged and Borrower accepted Sanction letter and as per current Bank schedule of charges. The key is the correct feeding of the interest rate from the correct date. This is because the rates keep on changing during the year. Further there should be no unauthorized changes / alterations to the interest rates. Hence Access controls assume great importance. If the auditor is satisfied about the implementation of controls over the feeding in of
interest rates and of modifications thereon and the operative effectiveness, then he just has to test check a few sample entries end to end to ensure that the actual computation is accurate. The auditor should in parallel check the Application controls at the Bank level by verifying on the system audit conducted at the Bank level. Necessary Written representations could be obtained from the Branch Head. There exists a risk of error due to viruses / bugs even though the feeding is correct and the audit sample not being able to detect it completely. Here the use of other corroborative ratio analytics, other audits, representative sample choice would reduce the risk to an acceptable threshold level. Another area of verification is the reversal of interest subsequently or concessions / waiver etc. This ought to be duly authorized. Auditor should obtain relevant MIS reports of interest reversals / waivers or debits to income accounts and ensure they are duly authorized and as per bank approved policy. A key area in this regard is the reversal of interest income in case of NPA and necessary provisioning thereon. Hence NPA identified by the auditor in course of his audit will impact the Profitability and entries will have to be passed through the Memorandum of Changes appropriately. Provisioning as per RBI norms is the minimum provisioning and auditor can insist on higher provisioning in case of absence or shortfall of security. Security valuation is of key importance in Doubtful accounts and auditor should ensure that the valuation on record is the latest and prudent. Recent demonetization & slowdown in Real Estate has lead to a softening of property prices & in that background, collateral valuation need to be realistic and possibly conservative as per bank policy. Similar audit checks would need to be done to verify the interest on deposits. These would be as per bank schedule and need to be checked especially as they change more frequently compared to interest on advances. Also if they are withdrawn prematurely, then the interest has to be reworked on the tenor for which they are held. The interest charged on Loans / Overdrafts against these deposits will also need to be reworked if withdrawn prematurely. Auditor should also check that back
dating of Deposits is done as per Bank policy which may vary from Bank to Bank. Provision on Matured Deposits not renewed till Balance Sheet date needs to be consistently done as per Bank policy. Salaries & provisions for Leave encashment benefits are done at HO and passed in the Bank books. Branch has no control over this centralized posting and the Branch auditor may just make appropriate disclosures in this regard as done in the previous year. Other items of Income that need to be checked are 1) Income from Investments which are usually centralized or at few select branches 2) Commission from Letters of Credit / Guarantees which as per bank policy consistently adopted would be accounted upfront and duly amortized monthly or quarterly as the case may be. Auditor to ensure that the Income pertaining to future periods which if collected is amortized correctly. 3) Other operating charges like Commitment charges for unutilized sanctions / draw downs Penalty on premature repayments Cheque book issuance and cheque bouncing charges Stock inspection charges or reimbursements of stock audits done as per accepted sanction terms Reimbursement of legal fees accepted as per sanction terms Processing Fees Care should be taken to ensure that processing fees are collected for the entire year and no miss outs happen for delayed renewal of advances. Penal Interest on over drawings / violation of sanction terms Non or delayed submission of stock statements or renewals or Insurance Auditor should note that incorrect calculation of funding eligibility as per draw power calculated from submitted stock statements may impact the penal charges if the same is below sanctioned limit.
Stop payment Charges DD / PO / RTGS / NEFT charges Charges for non maintenance of minimum balances Folio charges Locker rent auditor should note that vacant lockers are an opportunity loss to the bank and should report in LFAR on steps taken to market usage of lockers. Debit / Credit / ATM / Rupay Card issuance charges or annual charges if any or duplicate card or pin issuance charges Custody or Certification charges Godown or Shop rent Scrap or Newspaper sales Commission on Insurance / Mutual Fund or sale of 3 rd party products Auditor should specifically check the accuracy of interest subvention claimed by the Bank as per Government sponsored Education, Housing & other applicable schemes. As Foreign exchange Income is handled at few specialized branches, the same is not discussed here. The guidance Note on Audit of Banks Chapter on profit and Loss Account could be referred for the same Other items of Expenses that need to be checked are 1) Printing & Stationery Auditor should specifically note whether the same is expenses out on initial purchase or shown as Stock. In case it is shown as Stock then he should verify whether the items in stock exist or are usable. Necessary provisions for impairments may be made accordingly. 2) Lease Rent Necessary provision and payment has to be made as per agreement. Attention to be drawn to disputes on increase of rent or non refund of security deposit of vacated premises for necessary disclosures and provisions. For Improvements to Leasehold premises, the depreciation on such assets ahs to be over the primary lease period as per consistent bank policy.
3) Professional / Legal / Audit Fees Payments made towards the same has to be provided on accrual basis or completion of service basis. Care has to be taken to ensure that these are accounted on accrual and not on payment. 4) Telephones Provision to be on accrual basis. Non refundable Security deposits to be provided for. 5) Electricity Charges as per accrual basis. 6) Fees paid to 3 rd party vendors for other outsourced services like provision of Security, Delivery, Office & Maintenance Boys 7) Depreciation on Fixed assets which are in use. Physical verification needs to be done and impairments if any to be provided for. Assets at 3 rd party locations other than the Branch need to be verified. Maintenance of updated fixed asset register duly numbered and coded should be verified. 8) Insurance on branch assets. Auditor should note that insurance on cash retention or deposits (DICGC premium) is done at Head Office level. Necessary documentation available with the branch if any to be noted. 9) Advertisement, Marketing & Publicity expenses to be verified with contractual agreements and provided for on accrual basis as per contract or service completion as the case may be. 10) Payment of taxes like Tax Deducted at Source Tax or Service Tax which is on a monthly basis needs to be verified for accuracy of calculation, timeliness of payments & return filing with the appropriate authorities on time. Auditor should note that shortfall in assets like cash or receipt of fake notes needs a provision in the accounts. Similarly old debit balances in reconciliations, suspense or inter office adjustments need to be appropriately provided. Any shortfall in Deposits or non refundable deposits or deposits with missing original security receipts need appropriate provisioning on a case to case basis. Any likely devolvement of Contingent liability needs provisioning. Auditor to be guided by legal opinion, requirements of AS-29, adverse decision of lower
courts if applicable, payment of amounts in higher court on appeal thereon, his own judgment about the facts and circumstances on a case to case basis. Depreciation on Fixed assets has to be provided on the day the asset is put to use. Auditor should carefully note this date as in some occasions, the depreciation is done from date of accounting which could be on receipt of invoice, date of payment or date of accounting which is different from the date of use would lead to incorrect calculation & impact on the profitability. Banks may also need to repay in case they are in receipt of funds through fraudulent alterations on cheques or other financial instruments and this will be an impact on the profitability. Realizations of primary / collateral securities charged to the Bank by borrowers may not fetch the Bank the amount equivalent to the Principal & Interest including unrealized uncharged & the shortfall would be a hit to the banking books. At the times the same may need additional provisioning and subsequent write offs. Regulators may charge Branches / banks on violation of Regulatory norms like non compliance with KYC AML guidelines / Delayed or inaccurate submission of MIS returns etc by levying a penalty which apart from an expense is a significant reputational risk. Conclusion - Auditor should thus be aware of the various ways in which Revenue leakages can happen & note the steps taken by the Branch to plug these leakages. Inefficiencies in the system leading to duplication of efforts is an extra cost which is also an income leakage. Cost optimization under a balanced Risk acceptance Control Remediation scenario is the goal for a Bank. A thorough understanding of the various components of assets, liabilities, income and expense and their linkages will help the auditor in going about his fundamental responsibility to certify that the Profit and Loss account gives a True & fair view of the Profit or Loss as the case may be of the Bank Branch for the year under audit. Any qualitative suggestion or input can be made in the LFAR under the respective question or under Other Matters that need to be brought to the notice of the Central Statutory auditor or the Management. It should be noted that there is no restriction on the comments made in the LFAR and it is not restricted to the questionnaire only.