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Andheri Branch of WIRC of ICAI Long Form Audit Report Based on Presentation By CA. Niranjan Joshi Now spoilt By CA. Nitant Trilokekar Email: nitanttrilokekar @yahoo.com Internet: nptbanking.blogspot.com

Certain Definitions GAAP CPA FCPA The difference between Accounting theory & practice Can t Produce Anything Finally Caught Pinching Assets EBIDTA Earnings Before I Tricked the Dumb Auditor EBIT CEO CFO NAV EPS LFAR Earnings Before Irregularities & Tampering Chief Embezzlement Officer Chief Fraud Officer Net Andersen Valuation Eventual Prison Sentence Letting Fellow Accountants Rejoice

Background LFAR is a detailed questionnaire prepared by RBI. LFAR has been in use since 1992-93. To be submitted by the Auditors of Public sector banks, Private sector banks and foreign banks (including their branches). Current format is applicable from the year ending 31.3.2003.

General Study LFAR Questionnaire thoroughly Plan the LFAR along with statutory audit right from day one Use the Questionnaire as an Audit Planning Tool Complete & submit Main Audit Report as well as LFAR simultaneously

Teamwork Peer Review Admin Partner Logistics Partner IT Partner ICAI Communication Partner HR Partner Client P R QC/ QA Partner CA

General... Be specific while replying LFAR No vague/ general comments Give instances of shortcomings/ weaknesses Do not make current year s LFAR a replica of previous year Branch LFAR should be addressed to Bank s Chairman and a copy thereof sent to CSAs

General... Main Audit Report and LFAR are two separate reports. Comments in LFAR should not be qualificatory in nature Include Audit Qualifications in Main Audit Report and not in LFAR

General Main Audit Report should be a self contained document LFAR should be sufficiently detailed and quantified for expeditious consolidation and rectification by Bank

Perspective Alert LFAR is not a substitution of the statutory report, neither a part of the said report. LFAR is actually a management Report. Every adverse comment would not result in qualification in main audit report Complete LFAR before main report.

Major Categories in LFAR Assets Liabilities Profit And Loss Account General

Assets» Cash» Balance with RBI,SBI and other banks» Money at call and short notice» Investments» Advances» Other Assets

Cash Branches carry cash depending upon the limit fixed by controlling authority Adequate insurance cover of the cash in hand and cash in transit Effective Joint Custody Some small branches maintain cash in custody of a single official Cash balance checked at proper intervals

Cash Sample Response As mentioned in management letter dated Head office /regional office vide letter dated has fixed cash retention limit of Rs. 10 lakhs. Xerox of letter is not produced to us. On 105 occasions carrying cash is more than retention limit. On 54 occasions it has exceeded 40lakhs. Excess carrying cash is not reported to controlling authorities.

Balances with RBI, SBI & Other Banks Whether balance confirmation certificates obtained & reconciled Cash transactions remaining unresponded Revenue items requiring adjustments/ write off Item deserves special attention Old outstanding balances remaining unexplained/ unadjusted

Investments Investments portfolio is managed at H O Kept for safe custody at some branches Physically verify Investments Certificate Dividend/ interest received/ credited to H O account

Investments-2 Income on investments kept at Branch for safe custody reported to Head office Matured or overdue investments should have been encashed RBI guidelines regarding valuation of Investments complied with

Advances Outstanding amount is in excess of 5% of the aggregate advances of the branch or Rs.2 crore whichever is less are LARGE ADVANCES Fresh Loans: Whether appraised properly? Whether adverse remarks of field officer are over ruled by seniors? Sensitive Areas identified by RBI: Real Estate/ Securities/ Commodities Housing Loans Advances given to a specific group during the year?

Advances Loans approved by an authority just prior to his/ her retirement Stipulated installments/interests are being paid regularly Terms and conditions of the loan complied Credit facilities sanctioned beyond delegated authority or limit fixed by Bank

Advances. Review/monitoring/supervision Assess procedures for Periodic balance confirmation/ acknowledgement of debts. Analysis of accounts overdue for review/renewal between 6 months & 1 year and over 1 year Stock/debts statements and other periodic operational data and financial statements etc received regularly from borrowers and duly scrutinized Physical verification of securities charged to banks

Advances. (contd) Review/monitoring/supervision Frequent/ unauthorized overdrawing beyond limits Guidelines of security creation, asset inspection, insurance etc in case of leasing finance activities Branch identified and classified advances into standard/sub-standard/doubtful assets as per RBI Physical verification of securities charged to banks

Guarantees and LCs Critically Scrutinise Sanctioning Devolvements/ Invocations Sanctioning huge non fund based limits without proper margins Over exposure of such facilities to certain parties Whether opening of such documents are for genuine trade transactions LCs, Financial guarantees

Stationery and Stamps Internal control over issue and custody of security items like TDRs, Drafts, Pay Orders, Cheque Books, Gift Cheques) Cases of missing/ lost items of such stationery

Suspense Accounts/ Sundry Assets Adjustment accounts where some debit transactions are temporarily posted whose authorisation is pending for approval Expeditious clearance of items debited Reasons for delay in adjusting entries Irrecoverable balances provisioning? Unusual items in these accounts?

Liabilities»Deposits»Other Liabilities»Contingent liabilities

Deposits New Accounts opened & soon closed KYC forms Anti Money Laundering Act Heavy transactions during a period Only clearing entries appear in the account: No actual deposit or withdrawal Trace entries to see final deposit or withdrawal in which account and report Accounts of different parties proposed by a single person/ Group Overdue/matured term deposits at the year end

Deposits Conduct and operations of Inoperative Accounts Movement in inoperative accounts Followed prescribed Guidelines? Report where guidelines are not followed Transfer of such Accounts from operative accounts ledger Unusual large movements in aggregate deposits held at the year end after the balance sheet date?

Sundry Deposits/ Bills Payable Adjustment accounts in which certain credit transactions are temporarily posted whose authorisation is pending for approval Obtain a year wise break up Obtain details of each old entry Whether Register maintained for such entries? Check movement in old entries and its authorisation

Contingent Liabilities Ensure that all contingent liabilities are identified and disclosed Rent? Impact on Capital Adequacy

» Discrepancies in interest/ discount» Income recognition norms» System of estimating and providing interest accrued on overdue/matured term deposit» Divergent trends in major item of income and expenditure

Profit & Loss Account Interest on Advances Do not rely on software Manually check and compare results with software generated results change of interest rates If errors observed, whom does it benefit a few borrowers/ group? Interest on Deposits Test check if errors benefit a few depositors/ group Effect of changes in accounting policies on items of income and expenditure

Profit & Loss Account Commission Income Check sudden spurt in Commission income: From Guarantees/ LCs? Whether rates of commission are normal? Check sanctions, invocations, devolvements Whether income is from few parties?

Profit & Loss Account Variance analysis Interest to weighted average deposits/ advances compare current year with previous year Check System to detect discrepancies in interest/ discount and for timely adjustment thereof If discrepancies exist in many cases, consider its impact and ascertain qualification in auditors report?

General» Books and records» Reconciliation of Control and subsidiary records» Inter branch accounts» Audits/ Inspections» Frauds» Miscellaneous

Inter-Branch accounts Branch forwards on a daily basis to a designated cell / Head office, a statement of debit/credit transactions in relation to other branches Fraud Prone Area Outstanding debts in the head office account in respect of inter-branch transactions Isolate old/large outstanding transaction/entries as at the year end which remained unexplained Major adverse comments rising out of the latest reports of the previous auditors,concurrent auditors,stock auditors or internal auditors or RBI inspectors.

Inter Branch Accounts Inter-Branch Reconciliation Department Branch Daily Statement Originating branch/ Originating Transaction Responding branch/ Responding Transaction Check effectiveness of system of identifying errors Check adequacy of system of receipt and monitoring of data

Inter Branch Accounts Whether the branch responds promptly to error advices received from H.O. Whether the branch is vigilant about expeditious clearance of high-value entries? Whether IBR st. are regularly received from HO & promptly attended? Whether branch has written details on IBR st. for pending entries? Test-check IBR St. to ascertain existence of high-value items Whether originating debit entries/ cash transactions are liquidated within a reasonable period of time?

Inter Branch Accounts Year Entries over Two Years No. of o/s entries (in Lacs) Amount o/s (Rs. Crores) Average entry size (Rs.) 1996 22.58 50,706 2,24,561 2000 14.74 3,824 25,943 2004 33.73 2,622 7,775

Frauds Particulars of frauds discovered during the year together with recommendations to minimize recurrence Obtain register of frauds Recommend ways and means to minimise occurrence of frauds

Miscellaneous Does the accounts indicate possible window dressing? Other matters for consideration of management/ CSA s

Foreign Exchange Transactions.. concurrent auditors Material adverse features pointed out in various reports internal auditors RBI s inspection report in relation to NRE/ NRO/ NRNR/ FCNR B/ EEFC/ RFC and other similar deposit accounts

Foreign Exchange Transactions Irregularities Deposits Advances Export Bills Bills for Collection Dealing room operations Effectively, a Consultants job!

Foreign Exchange Transactions Foreign currency bank accounts kept with overseas branches/ other banks abroad Periodically reconciled NOSTRO Accounts Year No. of Entries (Lacs) Amount (Rs. crs.) Average (Rs.) 1996 14.68 2,24,539 15,30,000 Periodic balance confirmations? Regularly Operated? 2000 8.60 83,491 9,71,000 2004 73,568 3,793 5,15,562

Vostro Accounts Accounts kept in Indian Branches by Overseas branches/ foreign banks

Asset Recovery Branches Accounts upgraded from Non Performing to Standard during the year and reasons therefore Ensure that accounts are upgraded only after proper and adequate recovery in the account

Fixed Assets Inter branch transfer: Whether accounted properly? Assets in employees residences, shifted alongwith transferred employees Depreciation With Depreciation, we talk of Growth!

Q & A? Thank you