Revised LFAR Textile Market Surat
Revised LFAR Textile Market Surat
Revised LFAR Textile Market Surat
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Disclaimer
These are my personal views and can not be construed to be the
views of the ICAI/RBI/Bank or my firm, Member applied his
decision with his professional skepticism and concept of
Materiality (SA – 320).
No representations or warranties are made by the Study
Circle/Branch/bank/RBI with regard to this presentation.
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Background:-
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Why new format is important:-
• Asked for the details in advance from branch before your visit.
• Some items are specifically added in new format which were
already there in ICAI Guidance note issued earlier.
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Approach to prepare LFAR :-
• Plan the LFAR along with audit from the day one.
• Prepare the LFAR from your own and update it on daily basis
(Not after finishing the audit on the last day).
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Highlight on Modification/ Newly added Point in LFAR
• Definition of large advances
• Transaction audit/ specific details for large advances
• List and Percentage of Accounts examined
• Data integrity
• Details of ECGC claims
• Verification of documents and record held at CPC/ HO/CO Level;
• Impact of Interchangeability between FB and NFB facilities
• Compliances of minimum balance requirement ;
• Interest rate verification & Credit Rating
• DP Computation and Stock statement
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Important Points for CSA
The mandate and scope of the audit will be as per this format
and if the SCA feels the need of any material additions, etc.,
this may be done by giving specific justification by the SCA
and with the prior intimation of the bank’s Audit Committee
of board (ACB).
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I ASSETS
1 Cash
(a) Does the system ensure that cash maintained Joint Custody of Key
is in effective joint custody of two or more
officials, as per the instructions of the
controlling authorities of the bank?
(b) Have the cash balances at the branch/ATMs ATM has been specifically
been checked at periodic intervals as per the added in new format .
procedure prescribed by the controlling ATM was not mentioned in
earlier format but, we were
authorities of the bank?
already doing the same .
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I ASSETS
1 Cash
(c) (i) Does the branch generally maintain / carry
cash balances, which vary significantly from the
limits fixed by the controlling authorities
of the bank?
(ii) Does the figure of the balance in the branch This para is newly added
books in respect of cash with its ATM(s) tally with for ATM machines .
the amounts of balances with the respective ATM was not mentioned
ATMs, based on the year end scrolls generated by in earlier format but, we
the ATMs? If there is any were already doing the
difference, same should be reported. same .
(d) Whether the insurance cover available with the
branch adequately meets the requirement
to cover the cash-in hand and cash-in transit?
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I ASSETS
2 Balance with RBI ,SBI , and other banks ( For branches with Treasury
Operations )
Were balance confirmation certificates Take Balance Confirmation
(a) obtained in respect of outstanding balances as from other Banks and RBI.
at the year-end and whether the aforesaid
balances have been reconciled? The nature and
extent of differences should be reported.
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I ASSETS
2 Balance with RBI ,SBI , and other banks ( For branches with
Treasury Operations )
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I ASSETS
2 Balance with RBI ,SBI , and other banks ( For branches with Treasury
Operations )
(iv) Where the branch maintains an account This para is newly added
with RBI, the following additional matter
may be reported: Link branch to which currency chest attached
has originated deposit/ withdrawal entries
relating to operations in currency chest prior
Entries originated prior to, but to year end on the branch which maintains
communicated / recorded after the year end account with RBI .
in relation to currency chest operations at But the branch which maintains the account
the branch/other link branches, involving with RBI got communication for these entries
after the year end should be reported
deposits into/withdrawals from the
currency chest attached to such branches These entries will be lying in inter branch
(Give details) reconciliation and MOC for the should be
suggested
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I ASSETS
2 Balance with RBI ,SBI , and other banks ( For branches with Treasury
Operations )
(c ) In case, any matter deserves special attention
of the management, the same may be reported.
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I ASSETS
3 Money at call and short Notice
(b) Has the year-end balance been duly This para is newly added
confirmed and reconciled? But, we were already doing the same
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I ASSETS
4. Investments (for branches outside India)
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I ASSETS
4. Investments (for branches outside India)
(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 and / or has not been
serviced? If so, give details?
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I ASSETS
5 Advances
General Instructions
(i) The answers to the following questions may be based on the auditor’s examination
of all large advances.
For this purpose, large advances are those in respect of which the outstanding
amount is in excess of 10% of outstanding aggregate balance of fund based and
non-fund based advances of the branch or Rs.10 crores, whichever is less.
Care- For all accounts above the threshold, the transaction audit/account specific
details to be seen and commented, whereas below the threshold, the process needs
to be checked and commented upon.
Comments of the branch auditor on advances with significant adverse features,
which might need the attention of the management / Statutory Central Auditors,
should be appended to the LFAR.
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I ASSETS
5 Advances
General Instructions
Modification in definition of large advances :
Now it is 10% of outstanding aggregate balance of fund based and non fund
based advances of the branch or 10 CR which ever is less
Earlier it was in excess of 5% of the aggregate advances of the branch of RS.2
crore whichever is less
For all account above the threshold ,the transaction audit/account specific
details to seen and commented ,
For all account above the threshold ,the transaction audit/account specific
details to be seen and commented , whereas below the threshold, the process
needs to be checked and commented upon .
Transaction Audit – It is very wide term , it meant operations of account
Specific Details – Details provided by bank in large account format to be
verified.
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I ASSETS
5
Advances
General Instructions
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I ASSETS
5 Advances
(a) List of Account examined for audit
Account No Account Balance as at year Balance as at year Total
Name end –Funded end – Non-Funded
A B C = A+B
Total
X Y Z=X+Y
Total Outstanding
of the branch
Percentage A as % of X B as % of Y C as % of Z
Examined
Newly added clause :- This is new clause. Now onwards auditors have to give details of
all advances account examined during the audit.
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I ASSETS
5 Advances
(b) Credit Appraisal
(i) 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. What, in your
opinion, are the major shortcomings in credit
appraisal, etc.
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I ASSETS
5 Advances
(b) Credit Appraisal
Have you come across cases of quick Newly added clause
(ii) mortality in accounts, where the facility
became non-performing within a period of Verify all newly detected NPA account
12 months from the date of first sanction? and see when same were first
Details of such accounts may be provided in sanctioned . This data can easily be
collected by auditor
following manner:-
Account No.
Account Name
Balance as at year end
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I ASSETS
5 Advances
(b) Credit Appraisal
(iii) Whether in borrowal accounts the Newly added clause
applicable interest rate is correctly (a) Rate of interest ay the year end
(b) Modification during the year
fed into the system? Audit trails required – Ask for audit trail of modification
in rate of interest of loan with value date and verify with
the document verified.
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I ASSETS
5 Advances
(b) Credit Appraisal
(v) Have you come across cases of Newly added clause
frequent renewal / rollover of short-
Audit trails required- Ask for audit trail generated from
term loans? If yes, give the details of system with regards to accounts renewed/rolled over in
such accounts. system impact – MOC if any
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I ASSETS
5 Advances
(b) Credit Appraisal
(vi) Whether correct and valid credit rating, if Newly added clause
available, of the credit facilities of bank's (1) Ask the bank policy in this regards
borrowers from RBI accredited Credit (2) Verify the credit rating obtained as per
Rating Agencies has been fed into the bank policy
system? (3) Verify whether in system it is correctly
updated
In terms of para 6 of the circular , six domestic credit rating agencies viz. CARE
,CRISIL, FITCH, ICRA BRICKWORK and SMERA have been accredited for
the purpose of risk weighting the banks claims for capital adequacy purposes.
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I ASSETS
5 Advances
(c) Sanctioning / Disbursement
(i) In the cases examined by you, have you come across instances of: Generally
(a)credit facilities having been sanctioned beyond the delegated happen in case
of short
authority or limit fixed for the branch?
renewal or
(b) Are such cases promptly reported to expiry
higher authorities?
(ii) Whether advances have been disbursed without complying with the
terms and conditions of the sanction? If so, give details of such cases.
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I ASSETS
5 Advances
(c) Sanctioning / Disbursement
(iii) Did the bank provide loans to Newly added clause
Auditors should verify whether any buy back
companies for buy-back of Shares
has taken place during the year
/securities?
It is controversial issues .
(a) Word “bank provide” means loan given by bank for buy-back of shares which seems
to be impossible as it is not permitted . It can be verified
(b) Loan given for “x” purpose but used for buy-back . It is difficult to very by auditor.
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I ASSETS
5 Advances
(d) Documentation
In the cases examined by you, have you
come across instances of:
(i) Credit facilities released by the branch without execution Like, Charge Creation,
of all the necessary documents? If so, give details of Mortgage, Guarantee
such cases. papers etc.
(ii) Deficiencies in documentation, including non-
registration of charges, non-obtaining of guarantees,
etc.? If so, give details of such cases.
The words “the related
(iii) Advances against lien of deposits have been granted
without marking a lien on the bank’s deposit receipts and account "added- means lien
the related accounts in accordance with the guidelines of marked in system also to
verified. We were doing
the controlling authorities of the bank.
earlier also
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I ASSETS
5 Advances
(e) Review/Monitoring/Supervision
Is the procedure laid down by the Line marked in red is newly added
(i) controlling authorities of the bank, for
periodic review of advances, including We were doing earlier also.
periodic balance confirmation /
acknowledgement of debts, followed by Period is modified in line of RBI NPA
the branch? Provide analysis of the guidelines
accounts overdue for review/renewal.
What, in your opinion, are major
shortcomings in monitoring, etc.
a) between 3 to 6 months, and In old format
it was “between 6 months and 1 year and
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I ASSET
5 Advances
(e) Review/Monitoring/Supervision
(ii) (a) Are the stock/book debt statements and
other periodic operational data and No Change
financial statements, etc., received
regularly from the borrowers and duly
scrutinized? Is suitable action taken on
the basis of such scrutiny in appropriate
cases?
(b) Is the DP properly computed? Newly added clause
Audit trails required : Ask for audit trails of
DP modification done system during the
year along with value date verify the data
updated in system with stock statement
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I ASSET
5 Advances
(e) Review/Monitoring/Supervision
(iii) (a) Whether there exists a system of No Change
obtaining reports on stock audits
periodically?
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I ASSET
5 Advances
(e) Review/Monitoring/Supervision
(v) Does the branch have on its record, a dueNewly added clause
diligence report in the form and manner
required by the Reserve Bank of India inEarlier in seminars we were discussing
respect of advances under consortium andthis issues always and in borrower
multiple banking arrangements. Give the list ofand Consortium accounts we were
accounts where such certificate/report is notdoing .Now this clause has been
obtained or not available on record. (In case,specifically added to verify the
the branch is not the lead bank, copy ofcompliance of followings RBI circulars
certificate/report should be obtained from
lead bank for review and record)
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Compliance of RBI guidelines :
Lending –under lending under Consortium Arrangement / Multiple Banking Arrangement
Auditor should verify that in case of lending under consortium Arrangement / Multiple banking
Arrangement/,’banks ,any sanction of fresh loans /ad hoc loans /renewal of loans to new/existing
borrowers should be done only after obtaining/ sharing necessary information among banks .
Report the case where prescribe guidelines are not followed
Auditor should verify that bank branch has on its record a due diligence certificate / report in the
form and the manner required by the Reserve Bank of India in respect of advances under
consortium and multiple banking. Give the list of account where certificate is not obtain or on
record
For above auditors can refer to following circular issued by RBI
DBOD.NO.BP.BC.46/08.12.001/2008-09 dated September 19,2008
DBOD..BP.BC.94/08.12.001/2008-2009 dated December 8,2008
DBOD.NO.BP.BC.110/08.12.001/2008-2009 dated February 10,2009
DBOD..BP.BC.NO.62/21.04.103/2012-13 November 21,2012
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I ASSET
5 Advances
(e) Review/Monitoring/Supervision
(vi) Has the inspection or physical verification of
securities charged to the bank been carried out No Changes
by the branch as per the procedure laid down
by the controlling authorities of the bank?
Whether there is a substantial deterioration in Newly added clause
value of security during financial year as per We were already verifying this clause 4.2.9
latest valuation report in comparison with of master circular regarding erosion in
value of security
earlier valuation report on record?
Now specific clause is added in LFAR
IMPACT- MOC
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I ASSET
5 Advances
(e) Review/Monitoring/Supervision
(vii) In respect of advances examined by you, have
you come across cases of deficiencies,
including in value of securities and inspection
thereof or any other adverse features such as
frequent/ unauthorized overdrawing beyond
limits, inadequate insurance coverage, etc.?
(viii) Whether the branch has any red-flagged Newly added clause
account? If yes, whether any deviations were Ask for list of SMA, fraud and RED
observed related to compliance of bank's Flagged accounts reported branch
policy related with Red Flag Accounts? and bank , policy in this regards –
IMPACT – MOC
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I ASSET
5 Advances
(e) Review/Monitoring/Supervision
For Red Flag reporting guideline refer to fraud circular clause 8.3.4-42 items of EWS
given in Annexure II
Classification and reporting by commercial banks dated July 1, 2016
(updated as on July 03,2017)
(ix) Comment on adverse features considered
Newly added clause
significant in top 5 standard large advancesThis issues are already being reporting in
and which need management's attention. large accounts statements if above
threshold
If there is no large account i.e.10% of
outstanding aggregate balance of fund
based and non-fund based advances of the
branch or Rs. 10 Croers whichever is less.
Comment at least 5 standard top accounts
of branch
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I ASSET
5 Advances
(e) Review/Monitoring/Supervision
(x) 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?
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I ASSET
5 Advances
(f) Asset Classification, Provisioning of Advances and Resolution of Stressed Assets
(i) (a) Has the branch identified and classified The words “ without manual
advances into standard / substandard / intervention “ newly added
doubtful / loss assets through the computer NPA classification statement are being
system, without manual intervention? prepared by HO and provided for audit
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I ASSET
5 Advances
(f) Asset Classification, Provisioning of Advances and Resolution of Stressed Assets
(i)
(e) List the accounts (with outstanding in Newly added clause
excess of Rs. 10.00 crore) which have
either been downgraded or upgraded with We are already doing this only
regard to their classification as Non- specific clause added
Performing Asset or Standard Asset during
the year and the reason thereof.
(f) Whether RBI guidelines on income Newly added clause
recognition and provisioning have been Earlier covered on P&L and elsewhere
followed. only modified
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5 Advances
F Asset Classification, Provisioning of Advances and Resolution of Stressed Assets
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5 Advances
(v) Whether there are any accounts wherein Newly added clause
a) Ask the list of cases, wherein
process under IBC is mandated but not process under IBC has been
initiated by the branch? mandated by bank- but same is
not initiated.
Whether there are any borrowers at the
branch against whom the process of IBC is b) If yes give list and verify
adequate provision has been
initiated by any of the creditors including made or not. Provision we are
bank? If yes, provide the list of such already verifying
accounts and comment on the adequacy of
provision made thereto?
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5 Advances
(vi) (a) Have appropriate claims for credit Item c newly added
guarantee (ECGC and others), if any, been
duly lodged and settled? IMPACT - MOC
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5 Advances
(viii) 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
excess of Rs.50.00 lakhs may be given.
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5. Advances
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5 Advances
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5 Advances
(i) List of borrowers with details of LCs devolved Earlier it was at the end of the year
or guarantees invoked during the year. Obtain these details through audit
trail from bank
Verify where debit is being done
Sr. No. Invocation Party Name Beneficiary Amt Recovery Date
Date Name
(ii) List of borrowers where the LCs have been Only New format given below
devolved or guarantees have been invoked
but not paid with amount thereof.
Sr. No. Invocation Party Name Beneficiary Amt Reason for
Date Name Non
Payment
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5 Advances
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6 Other Assets
(i) Does the system of the bank ensure Period for 90 days added only for
expeditious clearance of items debited to outstanding entries
Suspense Account? Details of outstanding
entries in excess of 90 days may be obtained No other change
from the branch and the reasons for delay in
Amount not recoverable required
adjusting the entries may be ascertained.
provision/write-off no period limit
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.
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6 Other Assets
(ii) Does your test check indicate any unusual Red marked items added
items in these accounts? If so, report their
nature and the amounts involved. Are there We are already
any intangible items under this head e.g. recommending provision of any
losses not provided/pending investigation? losses not provided for bank
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II. LIABILITIES
1. Deposits
(a) Does the bank have a system of identification of
dormant/inoperative accounts and internal
controls with regard to operations in such
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.
(b) 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 branch
And give your comments thereon.
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II. LIABILITIES
1. Deposits
(c) Whether the scheme of automatic renewal of deposits New Clause added
applies to FCNR(B) deposits? Where such deposits
have been renewed, report whether the branch has Ask for audit trail for the same
satisfied itself as to the ‘non-resident status' of the
depositor and whether the renewal is made as per the From the audit trail take sample and
applicable regulatory guidelines and the original ask the bank to provide proof of
receipts/ soft copy have been dispatched. non resident
(d) Is the branch complying with the regulations on Ask for audit trail of all the accounts
minimum balance requirement and levy of charges on at the year and having balances
non-maintenance of minimum balance in Individual below the minimum limit and verify
savings accounts? on sample basis the compliance in
this regard
Rbi cir No.
DBR.Dir.BC.No.47/13.03.00/2014-15
November 20, 2014)
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II. LIABILITIES
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III. PROFIT AND LOSS ACCOUNT
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III. PROFIT AND LOSS ACCOUNT
(d) Does the bank have a system of estimating and Words marked In red colour
providing interest accrued on overdue/ added.
matured/ unpaid/ unclaimed term deposits This policy is applicable to all
including in respect of deceased depositors? overdue deposits
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IV. GENERAL
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IV. GENERAL
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IV. GENERAL
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IV. GENERAL
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IV. GENERAL
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IV. GENERAL
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IV. GENERAL
4. Frauds
Furnish particulars of: Newly added clause
(i) Frauds detected/ classified but confirmation Ask list of frauds detected
of reporting to RBI not available on record at from branch and verify
branch. reporting to RBI
(ii) Whether any suspected or likely fraud cases are Newly added clause
reported by branch to higher office during the Ask List of frauds detected and
year? If yes, provide the details there of related to reported from branch with
status of investigation. present status
(iii) In respect of fraud, based on your overall Newly added clause
observation, please provide your comments on the Give your observations on frauds
potential risk areas which might lead to
perpetuation of fraud
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IV. GENERAL
4. Frauds
(e.g. falsification of accounts/false representation by the borrower; misappropriation of funds especially
through related party/ shell company transactions; forgery and fabrication of financial documents like
invoices, debtor lists, stock statements, trade credit documents, shipping bills, work orders and
encumbrance certificates and avail credit; Use of current accounts outside consortium where Trust and
Retention Account(TRA) is maintained, to divert funds; List of Debtors/ Creditors were being fabricated and
receivables were not followed up/write off of debt of related parties; Fake export/shipping bill, etc.; Over
statement of invoice amounts, stock statements, shipping bills, turnover; fly by night operations- including
the cases where vendors, related/associate parties, manufacturing units etc. aren’t available on the
registered addresses; Round Tripping of funds, etc.)
(iv) Whether the system of Early Warning Newly added clause
Framework is working effectively and, as
required, the early warning signals form the Take list of SMA/ Red flag accounts
basis for classifying an account as RFA. and comment on process
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IV. GENERAL
Whether the branch followed the KYC/AML KYC – Sample verification of AOF
guidelines based on the test check carried out AML– difficult issue- AC-ICAI
by the branch auditors should issue guidelines- it is
concurrent audit issue
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IV. GENERAL
Whether the branch has the proper systems and Newly added clause
procedures to ensure data integrity relating to
all data inputs which are to be used for MIS at
corporate office level and for supervisory It pertains to HO
reporting purposes. Have you come across any
instances where data integrity was
compromised?
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IV. GENERAL
7. Miscellaneous
(a) In framing your audit report/LFAR, have you Modified clause coverage
considered the major adverse comments arising more specified
out of the latest reports such as:
i) Previous year’s Branch Audit Report/ LFAR;
ii) Internal audit/ Snap Audit/ concurrent audit
report(s);
iii) Credit Audit Report;
iv) Stock audit Report;
v) RBI Inspection Report, if such inspection took
place;
vi) Income and Expenditure (Revenue) Audit;
IS / IT/ Computer/ Systems Audit; and
vii) Any special inspection/ investigation report?
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IV.0 GENERAL
7. Miscellaneous
(b) Are there any other matters, which you, as Any special Point in relation to
branch auditor, would like to bring to the notice deficiency or any thing else you
of the management or the Statutory Central want to bring to the management
Auditors? or statutory auditor.
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[email protected]
CA. Rohit Porwal
+91-7566958480 M.Com, ACA, DISA, CCFAFD, CCCAB, CCFXTM
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