Area
of concern
1.
Internal audits shall be converting it into a stronger Risk
Based Internal Audit (RBIA) function and to
strengthening the Concurrent Audit by bringing Risk focus into the
Concurrent Audit could reduce some of
the other Audits ( BRANCH STATUTORY AUDITS) in the Branches wherein RBIA, CA are
conducted.
2.
There was a lopsided empanelment and appointment procedure for
Concurrent audits followed by Banks. The Committee feels that there is urgent
need to rectify the position in order to make the Concurrent Audit System
effective.
3.
Statutory Branch Audit has become routine and not much effective
post implementation of CBS in PSBs.
NEW General Guiding Principles
1.
The Banks should move to Software based Audit process.
2.
The team should consists of a proper mix of audit officers
/ Chartered Accountants / Cost Accountants/ CISA Qualified / Seniors having experience in all the
Banking functions/ Juniors having basic knowledge of various banking functions
3.
All the Audit team members should be made to sign Do's
& Don'ts given in the manual attached.
Guiding Principles on Information Systems
(IS)Audit:
1.
The Banks should form
separate IS Audit teams with persons having adequate IT experience and suitably
CISA
qualified Professionals. The IS Audit should be carried out on a continuous basis
adopting Risk based Approach as per the IS Audit policy.
Guiding
Principles on Concurrent Audit:
1.
For Concurrent Audit Chartered Accountant Firms should be
appointed from the RBI panel as per the gradation based on the size of the Branch. The
remuneration of Concurrent Auditors may be enhanced suitably based on the
coverage of audit, quality of the audit, skill sets required, number of staff
required etc
2.
The performance of Concurrent Auditor should be reviewed on Annual basis
3.
Suitable deterring
provisions should be incorporated in the Concurrent Auditors engagement for
delayed submission of Reports and unsatisfactory performance
4.
The functions performed by the statutory auditor should be transferred to Concurrent
Auditors.
Concurrent Auditors should be advised to provide various Certifications done
presently by Branch Statutory Auditors, covering NPA provisioning, Insurance coverage, P
& L Account, ALM, CRAR, DICGC, LFAR etc., similarly, Certification
regarding Tax Audit may also be taken from the Concurrent Auditors.
5.
With regard to other Branches not covered under Concurrent Audit
but is covered under the Branch Statutory Audit the threshold limit of advances should
be enhanced suitably, ensuring adequate coverage of Urban, Semi-Urban and Rural
branches keeping in view the inflation over time, on the following lines:
6.
All the branches not subjected to concurrent audit but covered
under the Branch Statutory Audit, with the enhanced threshold limit of advances and
1/5th of remaining branches should be subjected to certification by external
Chartered Accountants under Branch Statutory Audit System in the banks, where the CBS
is not stabilized, for a maximum period of two years.
7.
However, in case of banks where the CBS is stabilized and
running well, the certification as per the above norms should be done at
central level by the Central Statutory Auditor.
8.
The above aspect of Annual Certifications should be kept in view
while revising Fees of Concurrent Auditors as suggested earlier. This is
expected to result in reduction in overall cost to the Banks and improvement in
quality of CA on adopting this suggestion
9.
Thus, going forward the existing Branch Statutory Auditor appointment system
gets phased out, in view of the above suggested guiding principles.
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